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, 2005 Rosemarie C. Boniface, Superintendent Marlborough Public Schools 17 Washington Street Marlborough, MA 01752 Re: Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action Plan Verification and Special Education Mid-cycle Review Dear Superintendent Boniface: 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 July 30, 2002. We are pleased to indicate that the Department of Education has found your district's approved Corrective Action Plan to be substantially implemented and effective in remedying previously identified noncompliance issues in the areas of special education, civil rights and English learner education. The findings of the Department are included in the attached Follow-up Monitoring Report. You and your entire staff are to be congratulated for your efforts in implementing the necessary improvements. While the Department of Education found most noncompliance issues to be resolved, others were partially corrected and the Department’s onsite team identified a few new issues. 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 11, 2005. Your staff's cooperation throughout these Follow-up Monitoring activities is greatly appreciated. Should you require additional clarification of information included in our report, please do not hesitate to contact the Chairperson at (781) 338-3728. Thank you. Sincerely, Vani Rastogi, 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 Dennis Hunt, School Committee Chairperson Ann Williams, District Program Review Follow-up Coordinator Encl.: Follow-up Monitoring Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION COORDINATED PROGRAM REVIEW MARLBOROUGH PUBLIC SCHOOLS ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Action Plan Submitted on September 25, 2002 Progress Reports Submitted on January 5, 2003, April 1, 2003, June 30, 2003, December 8, 2003 Onsite Visit Conducted on January 19-20, 2005 Date of this Report January 31, 2005 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 student records did not consistently include written documentation of the Team’s determination Submit to the Department by June 1, 2005, an agenda for staff training that includes the requirements for determination Special Education Requirements SE 3 Special requirements for Record Review and Interviews Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 determination of specific learning disabilities of eligibility due to the presence of a specific learning disability. 2 of a specific learning disability. Also submit completed SLD checklists from five student records for students evaluated since the Mid-Cycle Review. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 6 Determinatio n of transition services (Emphasis on practices in determining needed transition planning and services and consideration of courses of study related to needed transition) SE 13 Progress Reports and content Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Record Review Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Record Review The records indicate that the progress reports include information on the progress towards the annual goals and information on the extent to which such progress is sufficient to enable the student 3 While the Team determines appropriate transition services for students, it appears that students are not always appropriately informed of the transfer of parental rights at the age of majority and parents continue to sign IEPs after the student has reached eighteen years of age. Submit to the Department, by June 1, 2005, a copy of the agenda from the staff training that includes the transfer of parental rights at the age of majority and student participation. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified to achieve the goals by the end of the year. 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) SE 15 Outreach by the School District (Child Find) SE 17 Initiation of services at age three and Early Intervention transition procedures SE 18A IEP development and content Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 For students who require special education and English learner education services, IEP Teams are not consistently indicating that the students have language needs in the PLEP B section of the IEPs. This information should be included; it will help guide students’ Submit to the Department by June 1, 2005, a copy of the agenda from staff training that includes this topic and reminds staff of the need to complete the PLEP B section of the IEPs for special education/English learner education students. Documentatio n Review The district conducts extensive outreach throughout the community. Record Review The district encourages referrals and has procedures in place to ensure effective transitions of young children with disabilities from Early Intervention Programs. Record Review 5 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 educational programming. 6 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 18B Determinatio n of placement; immediate provision of IEP to parent SE 20 Least restrictive program selected SE 22 IEP implementation and Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 Record Review and Interviews Record Review, Interviews and Documentatio IEP Teams develop IEPs at the meetings with the participation of all the Team members. The placement selected is the least restrictive environment, consistent with the needs of the students. In general, parents are provided with a copy of the IEP immediately following the Team meetings. The district’s commitment to inclusion and the least restrictive environment is commendable. The district offers several in-district placement options and students are included throughout all grade levels, consistent with their needs. The district does not delay implementation of IEPs, and at the beginning of the school year the district has an IEP in effect 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) 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)) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified n Review for each eligible student. Staff are informed of their responsibilities and teachers sign off when they receive a copy of the IEP. 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) SE 26 Parent participation in meetings (Emphasis on district’s attempts to ensure parent participation at IEP Team meetings) SE 28 Parent provided the IEP or notice of no eligibility together with notification of procedural safeguards and parents' rights Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 The district has a high level of parent participation in Team meetings. Record Review Parents are provided with copies of the IEP immediately following the Team meeting. 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) SE 29 Communications are in English and primary language of home SE 32 Parent advisory council for special education SE 50 Responsibilities of the School Principal and Administrator Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 The district provides interpreters for Team meeting and translates materials for parents in a timely manner. Documentatio n Review Document Review The district has an active Parent Advisory Council (PAC). The district submitted PAC by-laws, PAC meeting agendas, school committee agendas that indicate consultation with the PAC, and information on training sessions. The PAC actively advises the district on matters pertaining to program planning. The district has a curriculum accommodation plan that sets forth the continuum of general education supports, including MCAS support, reading support and ESL support services. 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) of Special Education SE 54 Professional development regarding special education SE 56 Special education programs and services are evaluated Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 Review of records indicated that special education/English learner education students are not consistently evaluated in their native language. Submit to the Department, by June 1, 2005, a plan to ensure that special education/ELE students will be evaluated in their native languages. Document Review Document Review The district offers a significant amount of professional development opportunities to staff. In addition to providing training in the district, staff are sent to seminars, workshops and courses. The district consistently evaluates all aspects of the special education program, obtaining input from staff, the PAC and outside professionals. Other Requirements SE 1 Assessments Record Review 11 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 5 Participation in General State and District-Wide Assessment Program SE 8 Evaluation Team Composition SE 9 Eligibility Determinatio n SE 21 School Day and School Year Requirements Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 The IEP Team, including the parents, determine how each student will participate in the MCAS examination. Record Review and Interviews Review of student records indicates that IEP Team meetings consistently include the required members. The district is translating IEPs for limited English proficient parents in a timely manner. Records Record Review and Interviews The Team determines the need for extended school year services and these services are identified if the student has demonstrated or is likely to demonstrate substantial 12 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) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 regression and/or difficulty in relearning skills if an extended program is not provided. SE 33 Involvement in the General Curriculum Record Review and Interviews SE 34 Continuum of Alternative Services and Placement Interviews Observations Interviews and Observation SE 42 Programs for Children Three and The district has greatly expanded the placement options at the high school. In addition, there is a continuum of services and placements available to meet the needs of students with disabilities throughout the district. The ABA program throughout the district is commendable; the ABA program is highly staffed with well-trained personnel. 13 While special education/ELE students are appropriately assessed for ELE, the special education students are not consistently receiving English language instruction. See ELE 5. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Four Years of Age SE 43 Behavior Interventions Record Review and Interviews SE 49 Related Services Record Review and Interviews The ABA program runs throughout the different grade levels and the program at the preschool is no longer overcrowded. Staff have been trained on behavioral interventions, Behavioral Intervention Plans are developed for students whose behavior impedes learning. Staff are consistently changing and updating the plans to ensure that these plans continue to be appropriate for the students. The district provides a significant amount of counseling services to students. While counselors are available in the district, the district also sends students to private counselors outside of the district when it is deemed to be 14 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) MOA 2 Program Modification for Limited English Proficient Students MOA 4 Placement of Disabled, Linguistic and Racial Minority, Homeless, and Female/Male Students Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 and Documentatio n Review appropriate. The district has focused on ensuring that therapeutic counseling services are available to students. The district has developed an outstanding program for limited English proficient students throughout the different grade levels. The district makes necessary program modifications to effectively serve limited English proficient students. Interviews and Documentatio n Review 15 ELE students at the high school do not have access to guidance counseling services in their native language. Also, at the high school, ELE students do not have access to advanced courses. See ELE 11. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) MOA 9 Hiring and Employment Practices of Prospective Employers of Students MOA 11A Designation of Liaison/coord inator(s); Grievance Procedures MOA 17A Use of Physical Restraint on any Student Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Interviews and Documentatio n Review The district requires that employers recruiting at the high school sign a statement setting forth that they do not discriminate in hiring or employment practices. Documentatio n Review The district’s handbooks include a policy covering harassment with a definition of harassment based on the protected categories. The handbooks refer the public to review the full policy that is written in the Marlborough Public Schools Policy Manual that is available in the District Education Center and in each school building. The district has provided training and written information on the requirements of physical restraints. Training is conducted prior to the start of the school Interviews and Document Review 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) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification ELE 1 Annual Assessment ELE 2 MCAS Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Enrolled in a PubliclyFunded Education Program MOA 25 Institutional SelfEvaluation Comments Regarding Corrective Action Plan Implementation year and whenever new staff are hired. Interviews and Documentatio n Review Record Review and Documentatio n Review Record Review, Interviews and Documentatio The district conducts numerous evaluations on the effectiveness of the programs, and also has an ongoing evaluation process that examines the policies and procedures to ensure that they do not limit educational access. Staff also complete a “Civil Rights Assessment Survey.” The district appropriately assesses the English proficiency of all limited English proficient students. Limited English proficient students participate in the annual administration of the MCAS exam as required and in 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) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification ELE 4 Waiver Procedures ELE 5 Program Placement and Structure 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 While special education/ELE students are appropriately assessed for ELE, the special education students are not consistently receiving English language instruction. Submit to the Department, by June 1, 2005, a roster of ELE/special education students indicating which staff member is providing English language instruction and how often. n Review ELE 3 Initial Identification Comments Regarding Corrective Action Plan Implementation Record Review, Interviews and Documentatio n Review Interviews and Documentatio n Review Interviews and Documentatio n Review accordance with the Department’s guidelines. The district screens all incoming students who may be limited English proficient using a home language survey, which has been translated into other languages. If the home language survey indicates that the primary language is not English, the student is assessed for English proficiency. The district has appropriate waiver procedures in place. 18 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) ELE 6 Program Exit and Readiness ELE 7 Parent Involvement Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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, Interviews and Documentatio n Review Interviews and Documentatio n Review The district uses appropriate and multiple measures before redesignating a student from limited English proficient to formerly limited English proficient. The district does a commendable job with parental involvement. The district has taken extraordinary steps to involve parents of limited English proficient students in their children’s education. The district provides and underwrites an evening ESL class for parents, for which the district provides babysitting. The district holds ELE parent meetings, and actively recruits parents to participate in PTO and school councils. The district provides native language translators at meetings with 19 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) ELE 8 Declining Entry to a Program Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified ELE 9 Instructional Grouping ELE 10 Parental Notification 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, Interviews and Documentatio n Review Interviews, Documentatio n Review and Classroom Observations Record Review, Interviews and Documentatio n Review limited English proficient parents. The district provides English language support to students whose parents have declined entry to a sheltered English immersion, two-way bilingual or other ELE program. The district has appropriate instructional groupings for limited English proficient students. The district provides appropriate notification to parents or guardians, written in English and the primary language of the home, when a student is placed in an ELE program. ELE 11 Equal Access to Academic Programs and 20 Although the district has made great strides in the training of teachers, including school Submit to the Department, by June 1, 2005: 1) Description of the mechanism by which Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified adjustment counselors and teachers of specials, ELE students at the high school do not have access to guidance counseling services in their native language. Also, at the high school, ELE students do not have access to advanced courses. At Jaworek Elementary School, ELE students are not considered for Title I services. Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Services ELE 12 Equal Access to Nonacademic and Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Interviews and Documentatio n Review The district provides support to limited English proficient students to ensure that they have equal access to nonacademic programs and extracurricular 21 ELE students at the high school are provided guidance counseling services. 2) Information on the training being provided to higher-level content instructors at the high school in Structured English Immersion. 3) Provide evidence on restructuring the program at Jaworek Elementary School so that students who qualify may receive Title I and ELE services. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Extracurricular Programs ELE 13 Follow-Up Support ELE 14 Licensure and Fluency Requirements ELE 15 Professional Development Requirements Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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, Interviews and Documentatio n Review Interviews and Documentatio n Review Interviews and Documentatio n Review activities that are available to their English-speaking peers. The district provides follow-up support to students and monitors students who have exited an English learner education program. The district has appropriately licensed educators and provides a significant amount of professional development to staff. The district is to be commended for the professional development provided to staff. Staff receive high-quality training in second language learning and teaching, sheltering content instruction, assessment of speaking and listening, and teaching reading and writing of limited English proficient students. 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) ELE 16 Equitable Facilities ELE 17 DOE Data Submission Requirements and Program Evaluation ELE 18 Records of LEP Students Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 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 ELE records did not have a log of access. Additionally, information from another student appeared in one record. Include a log of access in each ELE record and conduct an internal review of the ELE records to ensure that another student’s information is not included in any of the ELE records. Submit the results of the internal review on or before June 1, 2005. Interviews and Observation Interviews and Documentatio n Review The district ensures that LEP students are provided with facilities, materials and services comparable to those provided to the overall student population. The district follows appropriate reporting requirements and conducts evaluations of the effectiveness of the ELE programs. Record Review 23 24