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
June 5, 2006
Dr. Theresa Kane, Superintendent
Ludlow Public Schools
63 Chestnut Street
Ludlow, MA 01056
Re: Mid-cycle Coordinated Program Review Report
Dear Superintendent Kane:
Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report (MidCycle 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 Ludlow Public Schools Coordinated Program Review
Report issued on May 9, 2002. 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 selfassessment, 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 DowlingGrant in Program Quality Assurance Services at 781-338-3732. You may also consult with staff
in the Department’s Office of Language Acquisition and Achievement at 781-338-3534 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 along with noncompliance with ELE criteria. 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 June 20, 2006.
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 413-858-4591.
Sincerely,
Martha von Mering, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
James Harrington, School Committee Chairperson
Christine DeBarge, District Program Review Follow-up Coordinator
Encl.: Mid-cycle Coordinated Program Review Report
Mid-cycle Progress Report Form
MASSACHUSETTS DEPARTMENT OF EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
LUDLOW PUBLIC SCHOOLS
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION
Date of Coordinated Program Review (CPR): September 24 – 28, 2001
Date of Coordinated Program Review Corrective Action Plan Approval: June 23, 2005
Dates of Corrective Action Plan Progress Reports: October 11, 2005
Dates of this Mid-cycle Review Onsite Visit: February 14 – 16, 2006
Date of this Report: June 5, 2006
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS
Ludlow Public Schools Coordinated Program Review Mid-cycle Report
June 5, 2006
Page 1 of 9
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective

SE 3
Special
requirements for
determination of
specific learning
disabilities
SE 7
Transfer of
parental rights at
age of majority
and student
participation and
consent at the
age of majority

SE 19
Extended

Method(s)
of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Basis of Determination
Action
that Implementation of
Determined
Corrective Action was
Not to have
Incomplete or
been
Ineffective Or
Implemented
Basis of Finding of New
or Not to
Noncompliance
have been
Effective
Or
New Issues
Identified

Special Education Criteria Originally Cited in CPR Report and Monitored in Mid-cycle
Statutory requirements for the
determination of specific
learning disabilities have been
revised under the recently
reauthorized IDEA 2004.
Therefore, until final
implementing regulations have
been adopted, the Department
is not making findings related
to school district practices
under this criterion.
Student
The district ensures that every
Records
student, one year prior to
reaching eighteen, is informed
Staff
of his/her right to make all
Interviews
decisions in relation to special
education at age 18 and the
district obtains consent from
the adult student to continue
his/her special education
program.
Student
The Team, with the parents’
Records
consent, agrees to and
Ludlow Public Schools Coordinated Program Review Mid-cycle Report
June 5, 2006
Page 2 of 9
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s)
of
Verification

evaluation
Staff
Interviews
SE 22
IEP
implementation
and availability
SE 54
Professional
development
regarding special
education
SE 6
Determination of
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

Interviews indicate that
while staff members are
provided access to a
student’s IEP, ready
access to an IEP during
instruction is not possible.
The district will provide copies
of IEPs to staff members who
are providing services to those
students as described in the
IEPs. A letter of assurance to
this effect will be provided to
the Department on or before
September 30, 2006.
appropriately uses the extended
evaluation process in the event
a student is found eligible for
special education but finds the
evaluation information
insufficient to develop a full or
partial IEP.
Documents
The district ensures that it
considers the needs of all staff
Staff
in developing training
Interviews
opportunities and provides a
variety of offerings including
all required topics.
Special Education Criteria Created or Revised in Response to IDEA-2004

Student records and staff
interviews indicate that
Ludlow Public Schools Coordinated Program Review Mid-cycle Report
June 5, 2006
Page 3 of 9
The district will provide a
memo to all applicable staff
Criterion
Number
and
Topic
(Refer to full
text of 20052006 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

Transition
Services
SE 8
IEP Team
composition and
attendance

SE 12
Frequency of reevaluation

Student
Records
Staff
Interviews
Student
Records
Staff
Interviews
SE 13
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 district has begun to
use the Department’s
recommended transition
planning chart. However
required transition
information (IEP 3 and
IEP 8) is not consistently
being documented on the
IEP.
reminding them of the
requirement to document
required transition information
on the applicable IEP pages. A
copy of the memo will be
provided to the Department on
or before September 30, 2006.
Student records and staff
The district will provide a
The district ensures that IEP
Teams are composed of all
required persons unless the
parent and district agree to use
alternative means or the parent
gives written consent to excuse
a member’s attendance.
The district ensures that a reevaluation is conducted, with
parental consent, every three
years consistent with the
requirements of federal law or
unless otherwise agreed to by
the parent and district.

Ludlow Public Schools Coordinated Program Review Mid-cycle Report
June 5, 2006
Page 4 of 9
Criterion
Number
and
Topic
(Refer to full
text of 20052006 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

Progress Reports
and content
SE 14
Review and
revision of IEPs

Student
Records
Staff
Interviews
SE 25B
Resolution of
disputes

Documents
Staff
Interviews
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
interviews indicate
progress reports are
provided to parents of
special education students
as often as parents are
informed of the progress
of non-disabled students.
However progress reports
to not consistently address
whether the student’s
progress is sufficient to
enable the student to
achieve the goal by the
end of the IEP period.
memo to all applicable staff
reminding them of the
requirement to not only address
the progress toward the goal
but also address whether that
progress is sufficient to enable
the student to achieve the goal
by the end of the IEP period.
A copy of the memo will be
provided to the Department on
or before September 30, 2006.
The district ensures that IEPs
are reviewed on or before the
anniversary date of their
implementation date to
consider the student’s progress
and develop a new IEP.
The district ensures that
required resolution dispute
procedures are followed
including convening a meeting
Ludlow Public Schools Coordinated Program Review Mid-cycle Report
June 5, 2006
Page 5 of 9
Criterion
Number
and
Topic
(Refer to full
text of 20052006 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 30
Notice of
procedural
safeguards

Documents
SE 46
Procedures for
suspension of
students with
disabilities more
than 10 days

Student
Records
Staff
Interviews
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
to attempt resolution and
completing a legally binding
agreement if the resolution
session is successful or seeking
mediation when agreed to by
the parent and district.
The district is using the
Massachusetts Interim Notice
of Procedural Safeguards and
provides it to parents as
required.
The district ensures students
with disabilities, who are
suspended 10 consecutive days
or 10 cumulative days that
constitute a pattern, are
provided all required
procedural safeguards
including a Team meeting to
conduct a manifestation
determination and provides a
functional behavioral
assessment, and behavior
intervention plan if the
Ludlow Public Schools Coordinated Program Review Mid-cycle Report
June 5, 2006
Page 6 of 9
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 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
behavior is determined to be a
manifestation of the student’s
disability.
Ludlow Public Schools Coordinated Program Review Mid-cycle Report
June 5, 2006
Page 7 of 9
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
LUDLOW PUBLIC SCHOOLS
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
ELE 1
Annual
Assessment
ELE 2
MCAS
Participation
ELE 3
Initial
Identification
ELE 4
Waiver Procedures
ELE 5
Program
Placement and
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
Documentation indicates the district inconsistently assesses,
on an annual basis, the English proficiency of students who
have been identified as limited English proficient (LEP).
Interviews indicate all LEP students participate in MCAS
testing scheduled for their respective grades regardless of the
program and services they are receiving. However a review
of student records indicate MCAS scores are not consistently
being placed in the record.
Interviews indicate that the district does have wellestablished procedures for the initial identification of LEP
students. However a review of student records indicate
required documentation is not consistently being placed in
the record e.g. home language surveys.
Documentation indicates the district does not have wellestablished procedures to provide parents of LEP students
with program descriptions of the district’s ELE programs in
a language they can understand and of the parent’s right to
apply for a waiver.
Documentation indicates the district’s program placement
and structure do not meet all requirements under this
criterion.
The district will develop procedures that ensure the annual assessment of limited
English proficient students. A copy of the procedures will be provided to the
Department on or before January 30, 2007.
The district will provide a memo to all applicable staff reminding them of the
requirement to place copies of MCAS scores into students’ ELE records. A copy
of the memo will be provided to the Department on or before January 30, 2007.
Documentation indicates the district does not have wellestablished procedures to appropriately determine an LEP
student’s program readiness and exit level.
The district will provide a memo to all applicable staff reminding them of the
requirement to provide a home language survey to all parents of newly
registering students and to place the completed home language survey in the
students’ files. A copy of the memo will be provided to the Department on or
before January 30, 2007.
The district will develop procedures that ensure parents of LEP students are
provided with program descriptions of the district’s ELE programs in a language
they can understand and of the parent’s right to apply for a waiver. A copy of the
procedures will be provided to the Department on or before January 30, 2007.
The district will develop a program placement and structure plan for LEP
students that meet all requirements under this criterion. A copy of the program
placement and structure plan will be provided to the Department on or before
January 30, 2007.
The district will develop procedures that ensure the appropriate determination of
an LEP student’s program readiness and exit level. A copy of the procedure will
be provided to the Department on or before January 30, 2007.
Ludlow Public Schools Coordinated Program Review Mid-cycle Report
June 5, 2006
Page 8 of 9
ELE Criterion
Number and
Topic
ELE 7
Parent
Involvement
ELE 8
Declining Entry to
a Program
ELE 9
Instructional
Grouping
ELE 10
Parental
Notification
ELE 11
Equal Access to
Academic
Programs and
Services
ELE 12
Equal Access to
Nonacademic and
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
Documentation indicates the district does not have well
established mechanisms in place that consistently include
parents/guardians of LEP students in matters pertaining to
their children’s education.
The district will develop mechanisms that consistently include parents/guardians
of LEP students in matters pertaining to their children’s education. A description
of the variety of methods and/or multiple opportunities provided to parents will
be provided to the Department on or before January 30, 2007.
Documentation indicates the district does not have wellestablished procedures for parents/guardians of LEP students
who choose to decline entry to a district program. To date
only one parent of an LEP student, designated for an
advanced ELL class, declined entry to a district program.
See ELE 5
The district will develop procedures for parents/guardians of LEP students who
choose to decline entry to a district program. A copy of the procedure will be
provided to the Department on or before January 30, 2007.
Documentation indicates the district inconsistently notifies
parents, on an annual basis, of their child’s level of English
proficiency, program placement, and right to apply for a
waiver. Student records indicate that while the district
provides parents of LEP students with report cards and
progress reports in the same manner and with the same
frequency as general education reporting, such information
is not provided in a language understandable to the parent to
the maximum extent possible.
The district will provide a copy of its revised parental notification letter to the
Department on or before January 30, 2007. This revised notice letter must be
mailed upon placement of any student in the district’s ELE program and annually
thereafter in both English and the student’s primary/home language. The
notification letter must incorporate the following elements:
a. reasons for identification of the student as LEP;
b. child’s level of English proficiency;
c. program placement and/or method of instruction used in the program;
d. parent’s right to apply for a waiver or to decline to enroll their child in
the program.
The district will also provide a letter of assurance that it will provide parents of
LEP students with report cards and progress report in a language understandable
to the parent to the maximum extent possible. A copy of the memo and letter of
assurance will be provided to the Department on or before January 30, 2007.
None
District practices and documentation indicate that all LEP
students have equal access to academic programs and
services.
See ELE 5
District practices and documentation indicate that all LEP
students have equal access to non-academic and
extracurricular programs.
Ludlow Public Schools Coordinated Program Review Mid-cycle Report
June 5, 2006
Page 9 of 9
None
ELE Criterion
Number and
Topic
Extracurricular
Programs
ELE 13
Follow-up Support
ELE 14
Licensure and
Fluency
Requirements
ELE 15
Professional
Development
Requirements
ELE 16
Equitable Facilities
(To be reviewed
during next CPR
visit)
ELE 17
DOE Data
Submission
Requirements and
Program
Evaluation
ELE 18
Records of LEP
Students
(To be reviewed
during next CPR
visit.)
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
Documentation indicates the district does not have wellestablished procedures to appropriately monitor formerly
limited English proficient (FLEP) students.
Documentation indicates the district has appropriately
licensed and fluent teachers/educational staff.
The district will develop procedures that ensure appropriate monitoring of FLEP
students. The district will provide a copy of the procedures to the Department on
or before January 30, 2007.
None
Documentation indicates that while the district has begun to
provide high quality training to district staff to ensure the
progress of LEP students in developing oral comprehension,
speaking, reading, and writing of English, and in meeting
academic standards, continuous/on-going training is needed
to secure staff competencies across all grade levels.
Not Rated
The district will provide an updated professional development plan to the
Department on or before January 30, 2007.
Documentation indicates the district does not consistently
conduct periodic evaluations of the effectiveness of its ELE
program.
The district will develop a plan that ensures its ELE program will be periodically
evaluated on a consistent basis. The district will provide a copy of the plan to the
Department on or before January 30, 2007.
None
Not Rated
Ludlow Public Schools Coordinated Program Review Mid-cycle Report
June 5, 2006
Page 10 of 9
None