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 August 22, 2006 Ann Bradshaw Superintendent Mashpee Public Schools 150A Old Barnstable Road Mashpee, MA 02649 Re: Mid-cycle Coordinated Program Review Report Dear Superintendent Bradshaw: 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 Mashpee Public Schools Coordinated Program Review Report issued on April 14, 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 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. 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 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. 1 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 Wednesday, September 13, 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 781-338-3726. Sincerely, Thomas Taylor, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Mary Rose Grady, School Committee Chairperson Jane Beaudin, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT Mashpee Public Schools ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION Date of Coordinated Program Review (CPR): January 13-17, 2003 Date of Coordinated Program Review Corrective Action Plan Approval: June 5, 2003 Dates of Corrective Action Plan Progress Reports: January 5, 2004 Dates of this Mid-cycle Review Onsite Visit: June 13-14, 2006 Date of this Report: August 22, 2006 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 1 of 16 Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Partial Student Record Review and Documentation See comments to the right Student Record Review and Staff Interviews The district has demonstrated to the onsite team that regular education teachers regularly attend Team meetings Also, a person to commit the district resources attends the Team meetings. (Refer to full text of 20052006 CPR requirements) Special Education Criteria created or revised in response to IDEA-2004 SE 6 Determination of Transition Services SE 8 IEP Team composition and attendance 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 Partial Some student records did not contain the Transition Planning Chart and the IEP lacked transition goals. The age of majority form was not present in those eligible students’ records. Review the requirements with the responsible staff and then submit five samples of student records at age 15 and above that have transition goals and objectives. Submit three copies of completed age of majority forms. Please submit documentation by Monday, October 30, 2006. Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 2 of 16 SE 9 Timelines for determination of eligibility and provisions of documentation to parent SE 12 Frequency of re-evaluation SE 13 Progress Reports and content SE 14 Review and revision of IEPs SE 15 Outreach by the School District (Child Find) Student Record Review and Staff Interviews The district ensures that every parent receives a draft IEP at the Team meeting and a final IEP is received within 3 school working days after the Team meeting. Student Record Review, Documentation and Staff Interviews The district monitors the timelines for re-evaluation and adheres to the three- year time frame. Student Record Review, Documentation and Staff Interviews Progress reports are given as often as regular education students receive report cards. Progress reports contained information on goals and benchmarks. The progress reports documented the progress toward meeting the annual IEP goals. Student Record Review, Documentation and Staff Interviews The onsite team found that the district conducts initial, annual and re-evaluations within the timelines and monitors them. Documentation and Staff Interviews The district has submitted documentation to verify that they utilize a variety of avenues to conduct outreach to all required groups within the Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 3 of 16 community. SE 18A #1 & #2 IEP development and content SE 18B Determination of placement, provision of IEP to parent SE 20 Least restrictive program selected Student Record Review and Documentation Parent concerns and vision of the student are documented in the IEP. The district has clearly designated personnel that are able to commit the district resources and attend Team meetings. Student Record Review and Documentation The onsite team found that the Team develops the student’s IEP and that placement is in the least restrictive environment. The parent is provided a draft IEP at the Team meeting and a final IEP follows immediately after the Team meeting. Student Record Review and Staff Interviews The onsite team found special education students on all levels attending regular education classes with modification to the curriculum as indicated on their Individual Education Program. Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 4 of 16 SE 22 IEP implementation and availability SE 25B Resolution of disputes SE 27 Content of team meeting notice to parent SE 32 Parent advisory council for special education Student Record Review and Staff Interviews The onsite team found that IEP services were implemented without delay upon the parental acceptance of the IEP. Teachers and providers were informed of their specific responsibilities and the students’ accommodations and modifications on the IEP. Student Record Review and Documentation The district has a policy and procedure in place to address resolution of disputes and the 15-day requirement to convene the Team for resolution of the dispute. Partial Partial Student Record Review and Staff Interviews Documentation and Staff Interviews Partial Student records indicated that on many records the Notice of School District Action (N1) was incomplete and did not adequately describe the district’s action. Review the requirements with the responsible staff and then submit a sample of five N1 forms from student records. Please submit these records by Monday, October 30, 2006. Partial The district has submitted documentation to verify the establishment of a Parent Advisory Council (PAC). The district PAC provides training sessions, has established by-laws, and has regular meeting dates. However the membership of the PAC The district must submit evidence (flyers, personal letters, phone logs, etc.) of focused recruitment efforts to encourage the participation of parents of special education students in the PAC and provide a plan for electing parent officers. Please submit evidence to the Department by See comments to the right See comments to the right Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 5 of 16 overwhelmingly contains school district personnel. Also, there are no elected officers. SE 46 Procedures for suspension of students with disabilities more than 10 days SE 49 Related Services SE 54 Professional development regarding Student Record Review and Documentation The district has in place a policy and procedure to address suspensions for students with disabilities more than 10 days. The policy includes suspension logs kept by the special education department, behavioral intervention plans, functional behavior assessments and manifestation determinations. Student Record Review, Documentation and Staff Interviews The district has submitted documentation that a variety of related services are provided to special education students as indicated on their IEP. The district has experienced from time to time difficulty in obtaining service providers due to the availability of service personnel. However, the district is aware of their obligation to notify parents of this situation and the provision of compensatory services (see 603 CMR 28.06 (2)(d)(2)). Documentation and Staff Interviews The district provides training to all staff regarding special education issues. The district has a professional development Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 6 of 16 Monday, October 30, 2006. special education coordinator and distributes a needs survey to all staff regarding professional development. Recent training has been provided in inclusion, accommodating diverse learning styles, and special education policies and procedures. A weakness appears to be in the area of parental involvement. Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 7 of 16 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 Review of data reports The review of the district’s data indicates that any disproportionate representation in populations is too low in number to be statistically relevant. 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 Civil Rights (MOA) and Other General Education Requirements 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 Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 8 of 16 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements special ed, special ed placements, or disability categories MOA 9 Hiring employment practices of prospective employers of students MOA 10A Student handbook and codes of conduct MOA 15 Nondiscriminatory administration of scholarships, prizes and Documentation and Staff Interviews The district has submitted a copy of a statement of assurance that prospective employers sign that they comply with applicable state and federal laws prohibiting discrimination in hiring or employment practices. Documentation and Staff Interviews The student handbook contains student codes of conduct, due process procedures, disciplining students with special needs and students with 504 Accommodation Plans, and a non-discrimination policy and procedure. Student handbooks are distributed to all students, parents and school personnel annually. Documentation and Staff Interviews The district has provided documentation that scholarships, prizes or awards administrated or sponsored by the district are free of restrictions and are non-discriminatory. Private Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 9 of 16 awards and restricted scholarships are posted and printed materials are made available to the students. Mashpee 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 Comments Based on the Department’s Review of Local ELE Self-Assessment The district utilizes a home language survey and the MCAS to assess limited English Proficient (LEP) students. The home language survey is only provided in English and no other assessment tools are utilized to determine English proficiency. Required Corrective Action, Timelines for Implementation, and Progress Reporting The district needs to demonstrate that the home language survey is provided in other languages (Spanish and Portuguese) and that the district utilizes other assessment instruments (MEPA, MELA-O, IPT and LAS). Please provide samples from two student records by Monday, October 30, 2006. ELE 2 MCAS Participation The district has administered the MCAS to all limited English proficient students. ELE 3 Initial Identification The district is providing home language surveys in English only. The district must submit home language surveys that they utilize for identifying LEP student in languages other than English. Please provide copies of this letter by Monday, October 30, 2006. The district does not have a wavier procedure in place to address the following: parent notification of their right to apply for a waiver, program description in a language parents The district must forward a waiver procedure addressing the required criteria of ELE 4. Please provide a copy of the waiver procedure by Monday, October 30, 2006. ELE 4 Waiver Procedures Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 10 of 16 ELE Criterion Number and Topic Comments Based on the Department’s Review of Local ELE Self-Assessment Required Corrective Action, Timelines for Implementation, and Progress Reporting can understand. ELE 5 Program Placement and Structure ELE 6 Program Exit and Readiness ELE 7 Parent Involvement ELE 8 Declining Entry to a Program ELE 9 Instructional Grouping The district lacks a formal program placement and procedure for LEP students. The district relies on a tutorial approach and the designated tutor has an ESL training certificate, but is not licensed through the Department. If needed, the district will seek interpreters through community networking. As of this Mid-Cycle Review the district has identified nineteen students as LEP. The district must submit to the Department a copy of a formal placement and procedure program manual for LEP students. The manual must address instructional methods, content instruction based on the Massachusetts Curriculum Frameworks, English language development instruction that is based on the English Language Proficiency Benchmarks and Outcomes, and the utilization of assessment data to plan and implement educational programs for students at different instructional levels. The district needs to consider hiring an ESL teacher to service the LEP student population. Please submit this manual and evidence of hiring an ESL teacher to the Department by Monday, October 30, 2006. There is a lack of documentation that assessment data or academic success is used to re-designate an LEP student to Formerly Limited English Proficient (FLEP) and that the student is proficient in the English language. The district must submit to the Department a plan and process to address a program exit and readiness for re-designated LEP students. Please submit this document by Monday, October 30, 2006. The district encourages parent involvement through their participation on school councils and other parent groups. The district must document its efforts to solicit parent participation. For example, what written notifications were provided to parents of LEP students to participate in school councils? The district will document its activities to the Department by Monday, October 30, 2006. The district submitted documentation that indicated that they provided tutorial support for students whose parents have declined entry to a sheltered English immersion, two-way bilingual, or other ELE program. The district has submitted documentation that the district groups students of different ages together in instructional settings if their levels of English proficiency are similar. Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 11 of 16 ELE Criterion Number and Topic ELE 10 Parental Notification ELE 11 Equal Access to Academic Programs and Services ELE 12 Equal Access to Nonacademic and Extracurricular Programs ELE 13 Follow-up Support ELE 14 Licensure and Comments Based on the Department’s Review of Local ELE Self-Assessment Required Corrective Action, Timelines for Implementation, and Progress Reporting The district provides parents or guardians of LEP student’s report cards and progress reports in the same manner and with the same frequency as general education reporting. There was no evidence to indicate that this was done in the primary/home language. The district must submit copies of parental notices in the primary/home language. Please submit these copies by Monday, October 30, 2006. The district through documentation and student record review has demonstrated to the onsite team that LEP students have equal access to all academic and extra-curricular programs and services. Announcements of academic, nonacademic and extra curricular programs and services in the native languages have been provided to the onsite team. The district through documentation and student record review has demonstrated to the onsite team that LEP students have equal access to all academic and extra-curricular programs and services. Announcements of academic, nonacademic and extra curricular programs and services in the native languages have been provided to the onsite team. The district did indicate to the onsite team that they did provide follow up services for LEP students primarily through tutorial services. There was no evidence of a formal monitoring procedure. Furthermore, the district does not provide adult education in English language and literacy skill instruction. The district must submit to the Department a formal monitoring procedure that highlights the follow up support programs in place when an LEP student exits an English learner education program. Please submit information by Monday, October 30, 2006. The district was unable to assure the onsite team that teachers The district must ensure that instructional staff with LEP students are trained in Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 12 of 16 ELE Criterion Number and Topic Fluency Requirements Comments Based on the Department’s Review of Local ELE Self-Assessment Required Corrective Action, Timelines for Implementation, and Progress Reporting that have LEP students in their classrooms are properly trained in sheltered English immersion (SEI). The documentation submitted to the Department did not have appropriate licensure for the ESL teacher. SEI. Also, ensure that the ESL teacher is appropriately licensed through the Department. Please submit information by Monday, October 30, 2006. ELE 15 Professional Development Requirements The district lacked documentation to support efforts in providing appropriate training for instructional staff working with LEP students. The district must develop a professional development plan for all staff working with LEP students. Professional development should be focused in the following areas: second language learning and teaching, sheltered content instruction, assessment of speaking and listening, and teaching reading and writing to LEP students. Please submit information by Monday, October 30, 2006. ELE 16 Equitable Facilities (To be reviewed during next CPR visit) Through staff interviews, observations and documentation the district has demonstrated to the onsite team that all facilities, materials and services provided to LEP students are comparable to those provided to the overall student population. ELE 17 DOE Data Submission Requirements and Program Evaluation ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) The district has not done a self -evaluation of ELE programming. The district has not utilized the Department data to evaluate the ELE program. The district must demonstrate how data is used to evaluate the effectiveness of the ELE program. Please submit information by Monday, October 30, 2006. The onsite team conducted a preliminary review of ELE student records and found them to be lacking all of the required documentation. ELE student records will be reviewed during the next Coordinated Program Review. The school district is encouraged to review the requirements for records of LEP students and prepare for the Coordinated Program Review. Mashpee Public Schools Coordinated Program Review Mid-cycle Report August 15, 2006 Page 13 of 16