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
July 7, 2006
Marilyn Fratrturelli
Superintendent of Schools
Leominster Public Schools
24 Church Street
Leominster, MA 01453
Re: Mid-cycle Coordinated Program Review Report
Dear Superintendent Fratturelli:
Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report (Mid-Cycle Report). This
report contains findings based on onsite monitoring conducted to verify the implementation and effectiveness of
corrective action approved by the Department to address findings of noncompliance included in the Leominster Public
Schools Coordinated Program Review Report issued on April 4, 2003. The Mid-cycle Report also contains findings based
on onsite monitoring of special education compliance criteria that have been newly created or substantially changed in
response to IDEA 2004.
As you know, another component of the Department’s Mid-cycle Review is the review of your school district or charter
school's self-assessment in the area of English learner education (ELE). (In the remainder of this letter, please read
“district” as meaning “school district or charter school.”) The purpose of this review is to determine whether your district
is implementing the significant changes in M.G.L. Chapter 71A, governing the education of limited English proficient
students, that were adopted by voters by means of Question 2 in 2002. The Department has reviewed your district’s ELE
self-assessment documents and, based solely on that self-assessment, is providing you in this report with comments on
your ELE program and, where necessary, corrective action to be implemented. Your district is urged to request technical
assistance in relation to any of these comments or prescribed corrective action. To secure assistance, you may consult with
your Mid-cycle Review Chairperson or call Robyn Dowling-Grant in Program Quality Assurance Services at 781-3383732. You may also consult with staff in the Department’s Office of Language Acquisition and Achievement at 781-3383534 and obtain additional ELE guidance documents through the Department’s web site at http://www.doe.mass.edu/ell/ .
While the Department of 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, either
noncompliance with special education criteria added or substantially changed in response to IDEA 2004, noncompliance
with ELE criteria, or other new noncompliance. Where the district has failed to implement its approved Corrective Action
Plan, the Department views these findings to be serious.
In all instances where noncompliance has been found, the Department has prescribed corrective action for the district that
must be implemented without delay. You will find these requirements for corrective action included in the attached 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 implemented by your school district within the timelines
specified. Your statement of assurance must be submitted to the Mid-cycle Review Chairperson by July 3, 2006.
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 1 of 17
Your staff's cooperation throughout these follow-up monitoring activities is appreciated. Should you like clarification of
any part of our report, please do not hesitate to contact the Mid-cycle Review Chairperson at 781-338-3747.
Sincerely,
Joel Krakow, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
cc:
David P. Driscoll, Commissioner of Education
Mayor Dean Mazzarella, School Committee Chairperson
Susan Hitchcock, District Program Review Follow-up Coordinator
Encl.: Mid-cycle Coordinated Program Review Report
Rev. 3/24/06
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 2 of 17
MASSACHUSETTS DEPARTMENT OF EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
Leominster Public Schools
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION
Date of Coordinated Program Review (CPR): October 28-November 1, and December 1, 5, and 6, 2002
Date of Coordinated Program Review Corrective Action Plan Approval: October 8, 2003
Dates of Corrective Action Plan Progress Reports: 4/16, 5/11, 10/13, 2004 and 7/20, 2005.
Dates of this Mid-cycle Review Onsite Visit: May 3-4, 2006.
Date of this Report: July 6, 2006
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Criterion
Number
and
Topic
(Refer to full text
of 2005-2006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective

Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Special Education
Criteria
Originally Cited
in CPR Report
and Monitored in
Mid-cycle
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 3 of 17
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full text
of 2005-2006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Basis of Determination
that Corrective Action
was Implemented and
has been Effective
Review of data
The district was not cited
for noncompliance in this
area in the most recent
CPR in 2003.

MOA 4
Disproportionality
[included in this
report if the CPR
report included a
finding under MOA 4
of noncompliance
with respect to
racial/ethnic
distribution in special
ed, special ed
placements, or
disability categories]
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified


SE 2
Optional
Assessments
SE 3
Specific learning
Disability
Method(s) of
Verification
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
Review of records showed
that evaluator
recommendations were
not completed for the
Woodcock Johnson III
test.
Please submit a sample of 4-6
student records including
WJIII test evaluations to the
Department by October 16,
2006.
Not Rated
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 4 of 17
Criterion
Number
and
Topic
(Refer to full text
of 2005-2006 CPR
requirements)
SE 7
Transfer of
Rights
SE 16
Screening
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective
Review of
student
records, and
documentation
Review of student records
and documentation
demonstrated that the
requirements for the
transfer of parental rights
at the age of majority are
being met.
Review of
student records
and
documentation
Review of records
demonstrated that the
district is completing
required health screenings.




SE 18B
Determination of
Placement
SE 19 Extended
Evaluation
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified


Review of
student
records,
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
Review of records showed
that IEP placement forms
are not always signed.
Please submit a sample of 4-6
IEPs to the Department by
October 16, 2006.
Review of student records
and interviews
demonstrated that extended
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 5 of 17
Criterion
Number
and
Topic
(Refer to full text
of 2005-2006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective
documentation
and interviews.
evaluations are completed
as required.

SE 20
Least Restrictive
Program

Review of
student
records,
documentation
and interviews.
Review of student records
and interviews
demonstrated that the least
restrictive program is
appropriately selected for
students
SE 22
IEP
Implementation
and Availability

Review of
student
records,
documentation
and interviews.
Review of student records
and interviews
demonstrated that IEPs are
implemented upon parental
acceptance.
SE 25
Parental Consent
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
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
Review of records showed
that the district is not
consistently documenting
written parental consent in
all required situations.
Please submit a sample of 4-6
IEPs, including signed consent
forms to the Department by
October 16, 2006.
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 6 of 17
Criterion
Number
and
Topic
(Refer to full text
of 2005-2006 CPR
requirements)
SE26
Parent
Participation
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective


Review of
records
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
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
Please submit a sample of 4-6
student records to the
Department by October 16,
2006.
Review of student records
showed that parents are
active participants at Team
meetings.
SE 27
Content of Team
Meeting Notices
to parents

Review of student records
showed that notices to
parents do not
consistently include all
components.
SE 29
Communications
in English and
Primary Home
Language

Review of records
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 7 of 17
Review of student records
showed that although IEPS are
provided in the primary
language of the home, progress
reports are not.
Please submit a sample of 4-6
student records to the
Department by October 16,
2006.
Criterion
Number
and
Topic
(Refer to full text
of 2005-2006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective

SE 31
Educational
Surrogate
Parents

Review of
records
Review of records showed
that the district is meeting
regulatory requirements
pertaining to educational
surrogate parents
SE 32

Review of
documentation
The district has established
a PAC that is involved in
the review of special
education policies and
programs. The PAC has
also established bylaws.
SE 36
IEP
Implementation,
Accountability
and Financial
Responsibility

Review of
documentation
Review of documentation
showed that the district has
procedures in place for IEP
implementation,
accountability and
financial responsibility.
SE 37
Out of District

Review of
documentation
Review of documentation
showed that the district has
Parent Advisory
Council
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 8 of 17
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full text
of 2005-2006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
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
Review of documentation
showed that the district’s
policy statement does not
include a parent’s right to
opt out of the building
based referral process at
any time during the TAT
process.
Please submit an updated
policy statement to the
Department by October 16,
2006.
a process in place for the
oversight of out-of district
placements.
Placements

SE 39
Students Enrolled
in Private Schools
at Private
Expense
SE 40
Instructional
Groupings

Review of
documentation
Review of documentation
demonstrated that the
district’s instructional
groupings meet all
regulatory requirements
pertaining to class size.
SE 41
Age Span
Requirements

Review of
documentation
Review of documentation
demonstrated that the
district’s instructional
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 9 of 17
Criterion
Number
and
Topic
(Refer to full text
of 2005-2006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
groupings meet all
regulatory requirements
pertaining to age.
SE 50
Administrative
Responsibilities

Review of
documentation
Review of documentation
demonstrated that the
district’s administrator of
special education is
meeting all statutory
requirements.
SE 51
Teacher
Certification

Review of
documentation
Review of documentation
demonstrated that the
teachers are appropriately
certified.
SE 53
Use of
Paraprofessionals

Review of
documentation
Review of documentation
demonstrated that
paraprofessionals are
appropriately trained and
utilized.
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 10 of 17
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full text
of 2005-2006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective

SE 54
Professional
Development

Review of
documentation
Review of documentation
demonstrated that the
district is providing
required training for staff.
SE 56
Evaluation of
Special Education
Services and
Programs

Review of
documentation
Review of documentation
demonstrated that the
district is engaged in the
evaluation of its special
education services and
programs.
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 11 of 17
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
Review of
records
Review of records
demonstrated that the district
plans for transition activities
for students with disabilities
(Refer to full
text of 20052006 CPR
requirements)
Criterion
Determined
to be
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
Review of records
demonstrated that regular
education teachers and
some specialists are not
always in attendance at
Team meetings.
Please submit a sample of 4-6
student folders to the
Department by October 16,
2006
Special
Education
Criteria
created or
revised in
response to
IDEA-2004
SE 6
Determination
of Transition
Services


SE 8
IEP Team
composition
and attendance
SE 12
Frequency of
re-evaluation

Record review
Review of student records
and interviews demonstrated
that evaluations are
completed at least every
three years
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 12 of 17
SE 13
Progress
Reports and
content

SE 14
Review and
revision of
IEPs

Record and
documentation
review
Review of student records
demonstrated that IEPs are
reviewed annually.
SE 25B
Resolution of
disputes

Review of
documentation
and staff
interviews
Staff interviews indicated
that the district follows
procedural requirements
pertaining to the BSEA
process.
SE 30
Notice of
procedural
safeguards

Review of
documentation
and student
records
Documentation was provided
demonstrating that parents
had received a copy of the
Notice of Procedural
Safeguards.
Review of
documentation
and records
Review of documentation
demonstrated that the district
is appropriately
implementing procedures for
the suspension of students
with disabilities for more
than 10 days.
SE 46
Procedures for
suspension of
students with
disabilities
more than 10
days

Review of student records
showed that the full
complement of progress
reports were missing from
some records
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 13 of 17
Please submit a sample of 4-6
student folders to the
Department by October 16,
2006.
Leominster
English Learner Education (ELE) Requirements
Mid-Cycle Review Comments and Corrective Action Based on the Department’s Review Of Local Self-Assessments
(Please refer to full text of 2005-2006 CPR-ELE legal requirements and related implementation guidance at
http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc )
ELE Criterion
Number
and
Topic
Comments Based on the Department’s Review of Local
ELE Self-Assessment
ELE 1
Annual
Assessment
Document and record reviews and interviews demonstrated
that the district is conducting required MEPA and MELA-O
assessments.
ELE 2
MCAS
Participation
Document and record reviews and interviews demonstrated
that English Language Learners participate in MCAS.
ELE 3
Initial
Identification
Document and record reviews and interviews demonstrated
that the district appropriately conducts a home language
survey.
ELE 4
Waiver
Procedures
Document and record reviews and interviews demonstrated
that the district adheres to appropriate waiver procedures.
ELE 5
Program
Placement and
Documentation review and interviews indicated that
LEP students receive services in Sheltered English Emersion.
The district has conducted staff training in Sheltered English
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
Please provide documentation that staff that provide instruction in English
language skills are fluent in English. Due by October 16, 2006.
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 14 of 17
ELE Criterion
Number
and
Topic
Structure
ELE 6
Program Exit
and Readiness
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
Immersion, but documentation was not provided
demonstrating that all teachers are fluent in English.
Review of records and interviews indicated that the district
appropriately uses assessment data (MELA-O, MEPA) for
program exit determinations.
ELE 7
Parent
Involvement
Review of records and interviews indicated that the district
has procedures for including parents of limited English
proficient students in their children’s education. The district
did not provide documentation that it has conducted a parent
survey.
ELE 8
Declining Entry
to a Program
Interviews indicated that the district has appropriate
procedures pertaining to the parent’s decision to decline entry
into the ELE program.
ELE 9
Instructional
Grouping
Interviews indicated that the district’s instructional groups are
determined appropriately on the basis of English language
proficiency.
ELE 10
Parental
Notification
Review of documentation indicated that parents receive
required notification letters in appropriate languages.
Please submit a copy the district’s parent survey to the Department by October
16, 2006.
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 15 of 17
ELE Criterion
Number
and
Topic
Comments Based on the Department’s Review of Local
ELE Self-Assessment
ELE 11
Equal Access to
Academic
Programs and
Services
Interviews indicated that Limited English proficient students
have equal access all academic programs and services.
ELE 12
Equal Access to
Nonacademic
and Extracurricular
Programs
Interviews indicated that Limited English Proficient (LEP)
students have equal access to extracurricular and nonacademic
programs.
ELE 13
Follow-up
Support
Interviews indicated that the district has procedures in place in
place to actively monitor and follow up with students who
have exited the program for a period of three years.
ELE 14
Licensure and
Fluency
Requirements
The district did not provide documentation of its procedures
for determining English fluency or copies of educator
licenses.
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
Please provide a description of the district’s criteria to determine English
language teacher fluency and copies of teacher licenses and waivers to the
Department.
Due date: October 16, 2006.
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 16 of 17
ELE Criterion
Number
and
Topic
ELE 15
Professional
Development
Requirements
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
Review of documentation and interviews indicated that the
district adequately provides staff with professional
development opportunities.
ELE 16
Equitable
Facilities (To be reviewed
during next
CPR visit)
Interviews indicated that LEP students are provided equitable
resources, materials and facilities.
ELE 17
DOE Data
Submission
Requirements
and Program
Evaluation
Interviews indicated that the district submitted its data to the
Department and has developed program evaluation
procedures.
ELE 18 Records
of LEP
Students(To be reviewed
during next
CPR visit.)
Review of records indicated that the district maintains ELE
records in accordance with regulatory requirements.
Mid-cycle Report Format 2006.doc
Leominster Public Schools Coordinated Program Review Mid-cycle Report
June 20, 2006
Page 17 of 17