Massachusetts Department of Elementary and Secondary Education 75 Pleasant Street, Malden, Massachusetts 02148-4906 Telephone: (781) 338-3700 TTY: N.E.T. Relay 1-800-439-2370 June 14, 2011 Dr. Theresa Kane, Superintendent Ludlow Public School District 63 Chestnut Street Ludlow, MA 01056 Re: Mid-cycle Report Dear Superintendent Kane: Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Report based on the Mid-cycle Review conducted in your district on March 31, 2011. In this Mid-cycle Review the Department monitored selected special education criteria to determine your district’s compliance with special education laws and regulations. The review consisted of information gathered from one or more of the following activities: staff interviews, review of student records, examination of documentation, and/or classroom observation. The Department found one or more of the criteria monitored in your district to be “Partially Implemented” or “Not Implemented.” In all instances where noncompliance has been found, the Department has prescribed corrective action for the district. This corrective action must be implemented 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 submitting progress reports using the enclosed form. Please provide the Department with your written assurance that all of the required corrective action will be implemented by your district within the timelines specified in the report. You must submit your statement of assurance to Darlene Lynch, Director, Program Quality Assurance Services, by June 30, 2011. Your staff's cooperation throughout this Mid-cycle Review is appreciated. If you have 1 questions about this letter or the enclosed report, please do not hesitate to contact Paula Twomey at 781-338-3730. Sincerely, Paula Twomey, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services cc: Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education Vani Rastogi-Kelly, Supervisor, Program Quality Assurance Services Michael Kelliher, School Committee Chairperson Christine DeBarge, Local Program Review Coordinator Encs: Mid-cycle Report Mid-cycle Progress Report Form 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REPORT Ludlow Public School District Date of the Mid-cycle Review Onsite: March 31, 2011 Date of this Report: June 14, 2011 PLEASE NOTE THAT THIS REPORT IS IN TWO SECTIONS. Required Special Education Criteria Monitored in this Mid-cycle Review Current special education criteria available by scrolling down to the special education instrument at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion SE 7 Transfer of parental rights at age of majority and student participation and consent at the age of majority Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation PI Document Review Interviews Student Records Basis of Determination about Criterion The district’s practice is to inform all students and their parents of the transfer of parental rights during the summer when the students are already 17 years of age, instead of informing the student and the parent one year prior to the student reaching the age of 18. If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation Revise the district’s procedures for the transfer of parental rights requirements to include one year prior to the student reaching age 18, informing the student and the parent/guardian of the rights that will transfer from the parent/guardian to the student upon the student’s 18th birthday. Train appropriate staff on the transfer of parental rights requirements. See Administrative Advisory SPED 2011-1 on the Age of Majority www.doe.mass.edu/sped/advisories/11_1.html. Ludlow Public School District Coordinated Program Review Mid-cycle Report June 14, 2011 Page 1 of 9 (b) Progress Report Due Date(s) and Required Elements Submit a copy of the revised procedures and evidence of staff training, including an agenda and signed attendance sheets (indicating role Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation Develop an internal oversight and tracking system to ensure that the district is informing students and their parents/guardians one year prior to the student reaching age 18 of the rights that will transfer to him or her upon the student’s 18th birthday. Develop a report of the results of an internal review of student records, for those students who have reached the age of majority subsequent to the district’s implementation of corrective action, for evidence of compliance with notifying the students and parent/guardian of the transfer of rights one year prior to the student reaching age 18. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Ludlow Public School District Coordinated Program Review Mid-cycle Report June 14, 2011 Page 2 of 9 (b) Progress Report Due Date(s) and Required Elements of staff), on the requirements for the transfer of parental rights. Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system’s implementation. Submit this information by October 31, 2011. Submit a report of the results of an internal review of records for students who have reached the age of Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation (b) Progress Report Due Date(s) and Required Elements majority subsequent to the district’s implementation of corrective actions for evidence of appropriate age of majority procedures. Include the following: Number of records reviewed; Number of records that included notification to the student and parent/ guardian one year prior to the student reaching age 18; Results of the root Ludlow Public School District Coordinated Program Review Mid-cycle Report June 14, 2011 Page 3 of 9 Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation (b) Progress Report Due Date(s) and Required Elements cause analysis of any records not in compliance; Specific corrective actions taken by the district to remedy any noncompliance. Submit the report by January 31, 2012. SE 52A Registration of educational interpreters Document Review Interviews The district does not have any students enrolled at this time who require the services of an educational interpreter for the deaf and hard of hearing. The district has procedures in place that indicate that an employee acting in this capacity would be registered with the Massachusetts Commission for the Deaf Ludlow Public School District Coordinated Program Review Mid-cycle Report June 14, 2011 Page 4 of 9 Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation and Hard of Hearing, as required. Ludlow Public School District Coordinated Program Review Mid-cycle Report June 14, 2011 Page 5 of 9 (b) Progress Report Due Date(s) and Required Elements Additional Special Education Criteria Monitored in this Mid-cycle Review Current special education criteria available by scrolling down to the special education instrument at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion SE 8 IEP Team composition and attendance Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion Document Review If the student is involved in a general education program, a general education teacher of the student is now in attendance at the IEP Team meeting at the high school level. Interviews SE 9 Timeline for determination of eligibility and provision of documentation to parent SE 10 End of school year evaluations Student Records Student Records Interviews Student Records Interviews If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation The school district determines whether the student is eligible for special education and provides either a proposed IEP and proposed placement or a written explanation of the finding of no eligibility within 45 school working days after receipt of the parent’s written consent to an initial evaluation or a reevaluation. If consent is received between 30 and 45 school working days before the end of the school year, the school district ensures that a Team meeting is scheduled so as to allow for the provision of a proposed IEP or written notice of Ludlow Public School District Coordinated Program Review Mid-cycle Report June 14, 2011 Page 6 of 9 (b) Progress Report Due Date(s) and Required Elements Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) PI SE 12 Frequency of re-evaluation Method(s) of Investigation Student Records Basis of Determination about Criterion the finding that the student is not eligible no later than 14 days after the end of the school year. The school district does not consistently conduct reevaluations every three years. Interviews If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation Review the dates of the reevaluations that have been conducted this past school year and analyze this data to establish the root cause(s) for the noncompliance. Based on this root cause analysis, indicate the specific corrective actions taken to remedy the non-compliance. Develop an internal oversight and tracking system to ensure that reevaluations are conducted every three years, unless the parent and district agree that it is unnecessary. The tracking system should include supervisory oversight at the school level and periodic reviews to ensure compliance. Develop a report of the results of an internal review of student records from all grades in which a reevaluation was conducted since the implementation of all of the district’s corrective actions for evidence of compliance with reevaluations being conducted every Ludlow Public School District Coordinated Program Review Mid-cycle Report June 14, 2011 Page 7 of 9 (b) Progress Report Due Date(s) and Required Elements Provide the outcomes of the root cause analysis with the specific proposal(s) for remedying the non-compliance. Submit a description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system’s implementation, for ensuring that re-evaluations are conducted every three years. Submit this information by October 31, 2011. Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation (b) Progress Report Due Date(s) and Required Elements three years. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Ludlow Public School District Coordinated Program Review Mid-cycle Report June 14, 2011 Page 8 of 9 Submit a report of the results of an internal review of records in which a re-evaluation was conducted since implementation of the oversight and tracking system for compliance with timelines. Include the following: Number of records reviewed; Number of records in which a reevaluation was conducted every three years; Results of the root cause analysis of any records not in compliance; Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation (b) Progress Report Due Date(s) and Required Elements Specific corrective actions taken by the district to remedy any noncompliance. Submit the report by January 31, 2012. SE 14 Review and revision of IEPs SE 18B Determination of placement; provision of IEP to parent Student Records Interviews Student Records Interviews At least annually, on or before the anniversary date of the IEP, a Team meeting is held to consider the student’s progress and to review, revise, or develop a new IEP or refer the student for a re-evaluation, as appropriate. Immediately following the development of the IEP, the district provides the parent with two copies of the proposed IEP and proposed placement along with the required notice. Ludlow Public School District Coordinated Program Review Mid-cycle Report June 14, 2011 Page 9 of 9 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REVIEW School District: Ludlow Public School District M I D – CY C L E P R O G R E S S R E P O R T Date Prepared: ____________________________________ Prepared by: __________________________________________________________________ (name and title) Criterion: _______________________ Topic: ________________________________________________________________________ For each criterion for which you prepare a progress report, please make a copy of this cover page, fill in the information requested above, and attach a complete description of the corrective action taken and any accompanying documentation. (Description of corrective action for each criterion and any accompanying documentation should include all of the “Progress Report Required Elements” for that criterion in the Mid-cycle Report.) Send the whole set of completed progress reports to: Darlene Lynch, Director Program Quality Assurance Services Massachusetts Department of Elementary and Secondary Education 75 Pleasant Street Malden, MA 02148-4906