Massachusetts Department of Elementary and Secondary Education 350 Main Street, Malden, Massachusetts 02148-5023 Telephone: (781) 338-3700 TTY: N.E.T. Relay 1-800-439-2370 September 17, 2008 Nancy Gustafson, Superintendent Millis Public Schools 245 Plain Street Millis, MA 02054 Re: Mid-cycle Report Dear Superintendent Gustafson: Enclosed is the Department of Education's Mid-cycle Report. This report contains findings based on onsite monitoring the Department conducted to determine the effectiveness of corrective action it approved or ordered to address noncompliance identified in your district’s last Coordinated Program Review Report, dated June 23, 2004. The Mid-cycle Report also contains findings based on onsite monitoring of special education compliance criteria that have been created or substantially changed in response to IDEA 2004. Another component of the Department’s Mid-cycle Review is the review of your school district or charter school's self-assessment—documentation and any written analysis of compliance--in the area of English learner education (ELE). 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 and, based solely on that self-assessment, is providing you in this report with findings 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 findings or this prescribed corrective action from me or from staff in the Department’s Office of Language Acquisition and Achievement at 781338-3503. ELE guidance documents are available on the Department’s website 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 Coordinated Program Review Corrective Action Plan, the Department views these findings to be serious. The Office of Special Education Programs of the U.S. Department of Education requires that all special education noncompliance be corrected as soon as possible, but in no case later than one year from the time of identification; where the district has failed to implement its CPR Corrective Action Plan, this one-year period has long since passed. 1 In all instances where noncompliance has been found, the Department has prescribed corrective action for the district that must be implemented without delay. (In the case of new findings of noncompliance, this corrective action must be corrected 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 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 district within the timelines specified. You must submit your statement of assurance to me by October 6, 2008. Your staff's cooperation throughout this Mid-cycle Review is appreciated. Should you like clarification of any part of our report, please do not hesitate to contact me at 781-338-3755. Sincerely, Michelle Griffin, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education Chris Gove, Chairperson, School Committee Susan Donelan, District Program Review Follow-up Coordinator Encl.: Mid-cycle Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE REPORT MILLIS PUBLIC SCHOOLS Date of Coordinated Program Review (CPR) Final Report: June 23, 2004 Date Coordinated Program Review Corrective Action Approved or Ordered: October 8, 2004 Dates of Corrective Action Plan Progress Reports: January 26, 2005; June 6, 2005; October 4, 2005 Dates of this Mid-cycle Review Onsite Visit: May 20 and 21, 2008 Date of this Report: September 17, 2008 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Special Education Criteria Cited in CPR Report and Monitored in Mid-cycle Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Number/ Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 7 Age of Majority Partially Implemented Interviews Document Review Record Review A review of documentation and interviews indicate that the district has forms and procedures for implementing the requirements of this criterion. Staff are familiar with the requirement that student consent must be obtained, or, in the alternative, evidence of Corrective Action Not Implemented or Not Effective or New Issues Identified Partially Implemented 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 and documentation indicate that there is confusion about the appropriate way to secure a student’s decision to share or delegate decision-making. Interviews indicate that an 18-year old student must Revise the age of majority forms and procedures consistent with the requirements of this criterion. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 1 of 33 Provide training to all staff responsible for Team discussions concerning age of majority requirements, and for Criterion Number/ Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified guardianship or the student’s decision to share or delegate decision-making at age 18. 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 wait for the next Team meeting to make a decision in this regard. However, in the absence of any court actions to the contrary (e.g, guardianship), the student must make the decision to retain educational decision-making rights (and therefore consent to any services), delegate or share decision-making upon reaching the age of majority. There are different processes for making the decision to share or delegate decision-making, which are not distinguished in the district’s forms and practices. In addition, the district at times permits the form letters to be completed at home (and, therefore, out of the presence of the Team or a representative of the school district and other securing student consent or decision-making with regard to educational decisions upon reaching the age of majority. Ensure that the training includes the requirements of this criterion. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 2 of 33 Provide the revised form(s) and procedures, and a copy of agenda, training materials and attendance sheets by November 14, 2008. Develop an internal oversight and tracking system to ensure that age of majority procedures are appropriately implemented, including district obligations at the student’s 18th birthday. Submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight. Submit this information to the Department by November 14, 2008. Criterion Number/ Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 9 (currently SE 9A) (See also MOA 18) Elements of the eligibility determina- √ Interviews Corrective Action Not Implemented or Not 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 witness). Complete an internal review of records to ensure that age of majority procedures were appropriately followed for all students who reached the age of 18 since the training. Provide a report of this review by March 16, 2009, including the following information: Number of records reviewed; Number of records found in compliance with the requirements of this criterion; Name and role of staff completing the review; Actions taken to remedy any areas of non-compliance. Interviews indicate that general education teachers provide services and accommodations, and that there are active child study teams or processes at each level. See also CR 18. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 3 of 33 Criterion Number/ Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not 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 Record review and interviews indicate that the Team develops an IEP at the Team meeting using the most current IEP format provided by the Department. Specially designed instruction was seen in IEPs. Partially Implemented Record review indicates that page IEP 3/PLEP B is at times left blank, even for students with documented history of behavioral issues. Interviews indicate that the district does work with students and families to provide some services and accommodations for students with behavioral needs, but this is not documented in IEPs. Provide training to all special education staff on the following: That the IEP must be completed addressing all elements of the most current IEP format, including page IEP 3/PLEP B. Provide evidence of the training, including agenda, training materials and signed attendance sheets, indicating role, by November 14, 2008. tion; general education accommoda -tions and services for ineligible students SE 18A IEP development and content Partially Implemented Record Review Document Review Interviews Though there was a finding in the CPR report concerning the Team making decisions solely based on the availability of district resources, this information is no longer part of this criterion. Interviews, however, indicate that in some cases this still happens. The district should address this, as it implicates other areas of special education law not reviewed as part of this report. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 4 of 33 Develop an internal oversight and tracking system to ensure that IEPs are completed appropriately, specifically, to ensure that page IEP3/PLEP B is not left blank. Submit a description of the internal Criterion Number/ Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not 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 oversight and tracking system, including person(s) responsible for the oversight. Submit this information to the Department by November 14, 2008. SE 20 Least Restrictive Environment Partially Implemented Document Review Interviews Record Individual staff commitment to educating students in the least restrictive environment was evident in staff interviews. Documentation further indicates that administration and staff Partially Implemented Interviews indicate that at times, because of a lack of alternative placements within the district, the program selected is not always the least restrictive Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 5 of 33 Complete an internal review of IEPs developed since the training. Provide a report of this review by March 16, 2009, including the following information: Number of records reviewed; Number of records found in compliance with the requirements of this criterion; Name and role of staff completing the review; Actions taken by the district to remedy any areas of noncompliance. See SE 43 for corrective action. Criterion Number/ Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective review SE 24 √ Notice to parent SE 32 Parent Advisory Council Partially Implemented Record review Document Review Interviews Corrective Action Not Implemented or Not Effective or New Issues Identified consult with one another and review the requirements of the least restrictive environment. Record review indicates that written notices are sent at all appropriate junctures, and that they answer all questions as required by federal regulations. Documentation and interviews indicate that the school district has established a district-wide parent advisory council (PAC) on special education. The school district conducts, in cooperation with the parent advisory council, at least one workshop annually within the district on the rights of students and their parents and guardians under the state and federal special education laws. 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 environment for students. Specifically, interviews indicate that students at the high school level are at times placed out of district because of a lack of programming for students with emotional/behavioral needs. See also and SE 43. Partially Implemented Documentation and interviews indicate that the parent advisory council does not participate in the planning, development and evaluation of the school district’s special education programs. The district was, at the time of the review, considering means of obtaining participation of parents in Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 6 of 33 Provide a description of how the PAC will participate in the planning, development and evaluation of the district’s special education programs by November 14, 2008. Criterion Number/ Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance the evaluation of the special education programs, including the possible use of a parent survey. Interviews SE 34 √ Continuum of Services Record review Document Review SE 50 Administrator of Special Education Some components of SE 50 in the CPR √ Interviews Document Review Documentation and interviews indicate that each school has documented “Pyramids of Support and Intervention,” which indicates that general education modifications and accommodations are seen as part of the continuum of services. In addition, the district has hired an ABA therapist and a behavior specialist for the next school year to increase the programming for students with emotional and behavioral needs. Interviews and documentation indicate that the school district has an appointed person who acts as the Administrator of Special Education, specifically, the Director of Pupil Personnel Services (herein, the director). The director is appropriately licensed to supervise all special Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 7 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/ Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective report are now included in criterion CR 18. SE 54 Professional development Partially Implemented Document Review Interviews education for the school district and ensure compliance with all federal and state special education laws. The district considers the needs of all staff in developing training opportunities for professional and paraprofessional staff and provides a variety of professional development offerings, including through professional learning communities established by the district. The district also has held mandatory workshops for paraprofessionals on specific therapies, collaboration and emotional development. Documentation of offerings to professional staff includes topics such as differentiated instruction and state and federal special education requirements. Interviews clarified that all paraprofessional and professional staff are required to attend these trainings, and that they cover the required training topics. Interviews indicate that the transportation coordinator meets Corrective Action Not Implemented or Not 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 Partially Implemented The district submitted no evidence of in-service training for transportation providers or samples of information provided on students’ needs and problems and appropriate emergency measures, as is required by this criterion. Provide evidence that the district provides in-service training for all locally hired and contracted transportation providers, as required by this criterion. Transportation providers include drivers of regular and special education vehicles and any attendants or aides identified by a Team for either type of vehicle. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 8 of 33 Provide evidence of this training, including agenda, training materials, sign-in attendance sheets (including roles of attendees), and examples of student-specific information provided to transportation providers. Provide all of the above by November 14, 2008. Criterion Number/ Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 56 Special education programs and services are evaluated √ Document Review Interviews Corrective Action Not Implemented or Not 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 with transportation drivers at that start of the school year to review medical and IEP issues. Documentation indicates that the district’s special education programs and services are regularly evaluated. Special Education Criteria Created or Revised in Response to IDEA-2004 Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented SE 3 √ Record review The district appropriately makes specific learning disability determinations. Observations are appropriately conducted, and the agreement of the Team is documented. Specific Learning Disabilities Interviews Document Review Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented The district is aware of the new forms for determining specific learning disabilities, which will Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 9 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic Criterion Implemented Method(s) of Verification SE 6 ##1 – 3 Partially Implemented Interviews Determination of Transition Services Document Review Record review Basis of Determination that Criterion was Implemented be required next year. Record review indicates that IEPs contain vision statements and students participate in Team meetings when they reach the appropriate age. Some records reviewed and documentation contained appropriate transition planning forms and transition planning. Criterion 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 Partially Implemented Some of the records reviewed lacked evidence of appropriate transition planning, specifically, transition planning forms and transition goals. Develop an internal oversight and tracking system to ensure that Teams appropriately address transition planning in IEPs, specifically through the use of transition goals and the transition planning form. Submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight. Submit this information to the Department by November 14, 2008. Interviews indicate that appropriate special education staff are familiar with the requirements of this criterion. Complete a review of student records age 15 and over and submit to the Department the following: Name and role of staff responsible for review; Number of records reviewed; Number of appropriately completed transition planning forms; Number of IEPs with transition goals or with documentation that the Team believed that transition goals were not Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 10 of 33 Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion 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 needed; Actions taken to schedule Team meetings immediately to address transition planning. Provide the report by March 16, 2009. SE 8 IEP Team composition and attendance SE 12 Frequency of re-evaluation √ Interviews Documentation Record review Interviews √ Record review SE 13 √ Progress Reports and content Record review Interviews Student record review indicates appropriate Team attendance. At times, Team attendance is exemplary with up to seven general education teachers present. Interviews and record review indicate that Team meetings always have a chair present that has the authority to commit the resources of the district, and is knowledgeable about the resources of the district. The district follows appropriate procedures for excusing Team members from meetings. Re-evaluations are conducted in a timely manner and when required, including before finding a student no longer eligible for special education. Record review indicates that progress reports are completed at appropriate times, consistent with the district’s report card cycle. Appropriate staff are Partially Implemented Progress reports do not always reflect actual progress on goals, and are written in terms of general progress in class without Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 11 of 33 Provide training to all staff responsible for completing progress reports on the content of progress reports, and on appropriate steps to take when Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented familiar with and have appropriate forms for completing summaries of academic achievement and functional performance, including recommendations on how to assist the student in meeting his or her postsecondary goals. Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting addressing specific goals in the IEP. In addition, record review indicates that when a progress report indicates a lack of student success, the district does not always reconvene the Team to discuss the lack of expected progress. a progress report indicates a lack of expected progress. Provide evidence of the training, including agenda, training materials and signed attendance sheets, indicating role, by November 14, 2008. Develop an internal oversight and tracking system to ensure that progress reports are appropriately completed, and that appropriate steps are taken when a progress report reflects a lack of student success. Submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight. Submit this information to the Department by November 14, 2008. Complete an internal review of progress reports at all levels created since the training. Provide a report of this review by March 16, 2009, including the following information: Number of records reviewed at each level; Number of records found in compliance with the Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 12 of 33 Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion 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 requirements of this criterion; Name and role of staff completing the review; Actions taken by the district to remedy any areas of noncompliance. SE 14 Review and revision of IEPs Record review √ Interviews Document Review SE 25B √ Interviews √ Interviews Resolution of disputes SE 33 Involvement in the General Curriculum Document Review Team meetings are held at least annually to review and revise the IEP. In addition, IEPs are revised appropriately through amendments, consistent with recent changes to IDEA 2004. Appropriate staff are aware that within 15 days of receiving notice that a parent has made an official hearing request to Special Education Appeals, the district is required to convene a meeting with the parent(s) and the relevant member(s) of the IEP Team, including a representative of the district with decisionmaking authority, to try to resolve the dispute. Interviews and documentation indicate that district personnel understand the rights of students with disabilities to be full participants in the general curriculum. The district Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 13 of 33 Criterion Number and Topic SE 39A Procedures for services to eligible private school students whose parents reside in the district Criterion Implemented Partially Implemented Method(s) of Verification Document Review Interviews Basis of Determination that Criterion was Implemented ensures that Teams document the student’s participation in the general curriculum in the IEP. Interviews indicate that the director is familiar with the procedures used to provide services to eligible students enrolled in private schools at private expense whose parents reside in the district. Criterion 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 Partially Implemented Interviews and documentation indicate that the district does not conduct child find activities--comparable to those for public school students--for all students enrolled at private expense in private schools in the district. See SE 15 below regarding Outreach. (SE 39A does not apply to charter schools or vocational schools) See SE 15 below regarding Outreach. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 14 of 33 Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state Partially Implemented Interviews Interviews indicate that the director is familiar with the procedures used to provide services to eligible students enrolled in private schools at private expense whose parents reside out of state. (SE 39B does not apply to charter schools or vocational schools) SE 46 Procedures for suspension of students with disabilities more than 10 days Document Review Record review Partially Implemented Document Review Interviews Interviews indicate that staff are familiar with appropriate procedures for the suspension of students with disabilities. Manifestation determination meetings are held. Criterion Partially Implemented or Not Implemented Partially Implemented Partially Implemented Handbooks submitted within this criterion will be reviewed under criterion CR 10A. Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Child find efforts are limited. See SE 15 below. See SE 15. Once the district’s child find efforts are appropriately implemented, the district will be able to appropriately ensure that it is providing services to eligible students who attend private schools in the district and whose parents reside out of state (if any such students are identified). Record review indicates that manifestation determination meetings are not always conducted in a timely manner. Forms used for conducting these meetings must be updated to be consistent with IDEA 2004. Record review indicates that Teams do not always consider, in a timely manner, functional behavioral assessments and behavioral intervention services and modifications to address Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 15 of 33 Provide training to all special education staff, principals and assistant principals concerning the IDEA 2004 requirements related to discipline. Provide evidence of the training, including agenda, training materials, and signed attendance sheets, indicating staff role. Provide all of the above by November 14, 2008. Develop an internal oversight and tracking system to ensure that all administrators appropriately implement IDEA 2004 procedures when special Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion 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 the behavior so that it does not recur. education students are subject to discipline. Submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight. Submit this information to the Department by November 14, 2008. Documentation indicates that handbooks lack appropriate procedures for discipline of students with disabilities. Please see CR 10A. Submit a report of an internal review of student records posttraining to determine compliance with ensuring that manifestation determination meetings are held when required, functional behavioral assessments are conducted and that notice is sent to parents. Submit the following information: Name and role of staff completing review; Number of records reviewed, Number of records found in compliance; Corrective action taken as required. Submit this report by March 16, 2009. SE 52 Appropriate certifications/ √ Document Review Interviews and documentation indicate that the district accesses interpretation services Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 16 of 33 Criterion Number and Topic licenses or other credentials – related service providers (to be reviewed only with respect to providers of interpreting services) Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Interviews through Department of Health and Human Services as needed. Interviews indicate that all other related services staff are appropriately certified. Criterion 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 Special Education Criteria Monitored because of Issues Identified since the CPR Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Criterion Method(s) of Basis of Determination that Criterion Basis of Determination Required Corrective Action, Number Implemented Verification Criterion was Implemented Partially that Criterion was Timelines for and Implemented Partially Implemented Implementation, and Topic or Not or Not Implemented Progress Reporting Implemented Interviews indicate that limited Interviews indicate that Revise the district’s child find Interviews Partially child find is conducted in the Partially the district does not have practices so that the district has SE 15 Implemented district. Staff in the Implemented sufficient outreach and annual or more frequent Outreach by superintendent’s office contacts continuous liaison with outreach with those groups the School private schools to determine if other groups or agencies from which promotion or District (Child students from the town are from which the promotion transfer of students in need of Find) enrolled there. or transfer of students special education may be with special needs may be expected, or which would expected. include students in need of special education, consistent with the requirements of this criterion. Provide evidence of Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 17 of 33 Criterion Number and Topic SE 18B Determination of placement; provision of IEP to parent Criterion Implemented Partially Implemented Method(s) of Verification Interviews Record review Basis of Determination that Criterion was Implemented Record review indicates that at the Team meeting, after the IEP has been fully developed, the Team determines the placement to deliver the services on the student’s IEP. The decision regarding placement is based on the IEP. Criterion Partially Implemented or Not Implemented Partially Implemented Interviews indicate that immediately following the development of the IEP, the district provides the parent with the proposed IEP and proposed placement along with the required notice. Basis of Determination that Criterion was Partially Implemented or Not Implemented Interviews indicate that at times at the elementary level, some students who are non-compliant in the general education classroom are removed from their full inclusion placements for extended periods of time in a regular and consistent manner to special education staff work spaces, inconsistent with service delivery grids and agreed upon placements. At times, these students are placed in these spaces during instructional periods, where the special educators are providing services to other special education students. Interviews indicate that this is used as an alternate means of discipline, without convening the Team and amending the IEP. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 18 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting the above by November 14, 2008. See SE 20. Provide training to all general and special education staff on the requirements of implementation of the IEP as written, including appropriate procedures to employ when students are non-compliant or have behaviors that interfere with their learning or that of other students. (See also SE 43). Provide evidence of the above trainings, including agenda, training materials and signed attendance sheets, indicating role of staff in attendance, by November 14, 2008. Criterion Number and Topic SE 43 Behavioral interventions Criterion Implemented Method(s) of Verification Partially Implemented Interviews Record review Basis of Determination that Criterion was Implemented Interviews indicate that the district intends to hire a board certified behavior analyst and an ABA therapist for the 20082009 school year. Criterion Partially Implemented or Not Implemented Partially Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting See 18A concerning the completion of page IEP3/PLEP B. Provide training for all Team chairpersons on requirements that Teams consider including positive behavioral interventions and the possible need for a functional behavioral assessment for students whose behaviors impede their learning or that of other students. Include in this training discussion by the Team of the student’s ability to follow the school’s discipline code, and completion of IEP 3/PLEP B. Provide evidence of the training, including agenda, training materials and attendance sheets by November 14, 2008. Interviews and record review indicate that for students whose behavior impedes their learning or the learning of other students, the Team does not always consider the student’s behavior including positive behavioral interventions and the possible need for a functional behavioral assessment. See also SE 46. Develop an internal oversight and tracking system to ensure that Teams appropriately consider positive behavioral interventions, including FBAs, supports, services and accommodations, for students whose behaviors interfere with learning. Submit a description of the internal oversight and tracking system, including person(s) responsible for the oversight. Submit this Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 19 of 33 Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion 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 information to the Department by November 14, 2008. Submit a report of an internal review of student records at the middle and high school levels for compliance with this criterion post-training, including developing behavioral interventions and conducting functional behavioral assessments. Include in the report the following: Name and role of staff completing review; Number of records reviewed, Number in compliance with this criterion, and Corrective action for any noncompliance found. Submit this report by March 16, 2009. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 20 of 33 Criteria from Other Regulated Programs Monitored During this Mid-cycle Review Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not 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 (formerly MOA) Cited in CPR Report and Monitored in Mid-cycle Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 21 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification CR 10A Partially Implemented Document Review Student handbooks and codes of conduct Basis of Determination that Corrective Action was Implemented and has been Effective Documentation indicates that the district has codes of conduct for students, and has some school committee policies concerning teacher conduct. Corrective Action Not Implemented or Not Effective Or New Issues Identified Partially Implemented 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 Requirements None of the district’s student handbooks contain the following: IDEA 2004 procedures for students not yet eligible for special education. Appropriate procedures for discipline of students with Section 504 plans. Reference to M.G.L. ch. 76, s. 5. The district’s procedures for accepting, investigating, and resolving complaints alleging discrimination or harassment. (The elementary and middle school handbooks contain contact information for allegations of race or gender harassment, but not other forms of Revise the student handbooks consistent with the column at left. The Department’s Civil Rights instrument, which lists these requirements, can be found at http://www.doe.mass.edu/pqa/r eview/cpr/instrument/civilright s.doc. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 22 of 33 Provide draft revisions by March 16, 2009, and a plan to include this in the next handbook revision. Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance harassment or discrimination.) The disciplinary measures that the school may impose if it determines that harassment or discrimination has occurred. In addition, while the handbooks contain procedures for discipline of students with disabilities, these must be updated to conform with IDEA 2004. Some of the handbooks reference outdated state regulations. The high school handbook is also missing: A non-discrimination policy that is consistent with M.G.L. ch. 76, s. 5 and affirms the district’s non-tolerance for harassment and discrimination based on race, color, national Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 23 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements Criterion Number/Topic CR 12A Annual and continuous notification concerning nondiscrimination and coordinators Approved Corrective Action Implemented and Effective Partially Implemented Method(s) of Verification Document Review Basis of Determination that Corrective Action was Implemented and has been Effective The district submitted job announcements and student handbooks. Job announcements contain appropriate notices of non-discrimination. While some of the handbooks submitted contain some required elements of this criterion, this is not consistent. Corrective Action Not Implemented or Not Effective Or New Issues Identified Partially Implemented The district also submitted a page from its website, which also contains an appropriate non-discrimination statement. The district’s homepage also Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance origin, sex, religion, or sexual orientation. The middle school handbook is also missing: A non-discrimination policy that is consistent with M.G.L. ch. 76, s. 5 and affirms the district’s nontolerance for harassment based on race, color, national origin, sex, religion, or sexual orientation. Documentation does not indicate that the district takes continuing steps to notify students, parents, and employees (including those with impaired vision or hearing), as well as unions or professional organizations holding collective bargaining or professional agreements with the district, that it does not discriminate on the basis of race, color, national origin, sex, or Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 24 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements Provide a description of the steps the district will take to notify students, parents, and employees (including those with impaired vision or hearing), as well as unions or professional organizations holding collective bargaining or professional agreements with the district, that it does not discriminate on the basis of race, color, national origin, sex, or disability. Describe how the district will ensure that notices and notification include the Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective Or New Issues Identified contains this statement. 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 Requirements disability. Handbooks do not consistently contain this information. (See CR 10A.) name(s), office address(es), and phone number(s) of the person(s) designated under CR 11A to coordinate compliance under Title IX and Section 504. In addition, the district’s notification and notices do not include the name(s), office address(es), and phone number(s) of the person(s) designated under CR 11A to coordinate compliance under Title IX and Section 504. CR 18 Responsibilities of the school principal Partially Implemented Interviews Document Review Record review The district submitted the District Curriculum Accommodation Plan, the “Pyramids of Support and Interventions” for all three schools, and the home hospital procedures. Partially Implemented Interviews indicate that staff are trained on and familiar with the DCAP and the pyramids of intervention. The district’s instructional supports currently do not include appropriate services for linguistic minority students that are consistent with ELL requirements, or the provision of services to address the needs of children whose behavior may interfere with learning. See SE 43 and ELE criteria. The principal with the Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 25 of 33 Provide this description by November 14, 2008. See SE 43 and ELE criteria. Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not 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 Requirements Partially implemented The district does not currently evaluate all aspects of its K-12 program annually to ensure that all students, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, disability, or housing status, have equal access to all programs, including athletics and other extracurricular activities and makes such changes as are indicated Provide a copy of the district’s self-evaluation by March 16, 2009. assistance of the administrator of special education coordinates the delivery and supervision of special education services within each school building. CR 25 Institutional SelfEvaluation Partially Implemented Document Review Interviews The principal ensures that documentation on the use of instructional support services for the student is provided as part of the evaluation information reviewed by the Team when determining eligibility. Interviews indicate that some aspects of the institutional selfevaluation are considered by administration. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 26 of 33 Criterion Number/Topic Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not 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 Requirements by the evaluation. ELE Criteria Current CPR criteria available by scrolling down to the monitoring instruments at http://www.doe.mass.edu/pqa/review/cpr/default.html ELE Criterion Number and Topic ELE 1 Annual Assessment ELE 2 MCAS Participation ELE 3 Initial Identification Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment √ √ Partially Implemented Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) The district’s self-assessment indicates that district annually assesses the English proficiency of all limited English proficient (LEP) students. The district’s self-assessment indicates that LEP students participate in the annual administration of the MCAS examination as required and in accordance with Department guidelines. While the district’s self-assessment indicates that some elements of this criterion are implemented, the home language survey is not translated and the district does not assess all students when second language is present on the home language survey responses, but only assesses students when the survey indicates that the student is a foreign language speaker. Once students are referred for assessment, however, the district reports that it uses qualified staff and appropriate procedures and assessments to identify students who are limited-English-proficient and to assess their level of English proficiency in reading, writing, Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 27 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting Provide copies of the home language survey that have been translated into the major languages spoken in the district. Submit copies by November 14, 2008. Revise the district’s procedures to ensure that initial identification assessments are conducted for all students whose home language survey indicates a home language other than English. Revise the district’s procedures to ensure that ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) speaking, and listening. parents are not permitted to decline testing for initial identification. The district allows parents to decline testing for identification as an English language learner. This is not appropriate. In addition, documentation indicates that a qualified person is not administering the home language survey. ELE 4 Waiver Procedures ELE 5 Program Placement and Structure √ Partially Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Provide the revised procedures by November 14, 2008. Provide a description of the district’s means for ensuring that qualified persons administer the home language survey by November 14, 2008. The self-assessment indicates that the district utilizes waiver forms provided on the Department’s website. Some professional development in teaching LEP students has been offered to teachers in an effort to provide a sheltered English immersion model. However, only some staff are trained in one or two categories, and ELL students are not assigned to these staff. The district provides ESL/ELD instruction through the use of paraprofessionals, instead of by appropriately licensed staff. The district did not indicate whether it uses assessment data to plan and implement educational programs for students at different instructional levels. Implement a professional development plan that provides teachers and administrators with high quality training, as prescribed by the Department, in (1) second language learning and teaching; (2) sheltering content instruction; (3) assessment of speaking and listening; and (4) teaching reading and writing to limited English proficient students. The district must provide training opportunities to teachers of LEP students that ensure the progress of LEP students in developing oral comprehension, speaking, reading, and writing of English, and in meeting academic standards. Provide the district’s professional development plan for SEI training and the licensure information (copy of license or waiver) of English language development instructors. Submit this information by November 14, 2008. Provide the district’s plan for ensuring that all ELL students receive ESL/ELD instruction provided by Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 28 of 33 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting appropriately licensed staff. Provide this plan by November 14, 2008. ELE 6 Program Exit and Readiness ELE 7 Parent Involvement Partially Implemented Partially Implemented Exit criteria submitted with the district’s self-assessment are inappropriate because they only permit a student to exit the ELL program in January or the end of the school year, and because they base the decision on LAS and MEPA -- stating that so long as students are competent literate (on the LAS) they can be exited. The district should ensure that it does not re-designate a student from limited English proficient (LEP) to formerly limited English proficient (FLEP) until he or she is deemed English proficient and can participate meaningfully in all aspects of the district’s general education program without the use of adapted or simplified English materials. See Department guidance at http://www.doe.mass.edu/ell/sei/MEPA_guidelines.doc. The district’s self–assessment states that parent involvement is a priority. The home language survey, though in English only, does contain a question asking what language parents would like notices in; sample home language surveys included several in which parents asked for translated documentation. However, the district did not submit any translated documents, and interviews indicate that nothing is currently translated. In addition, it is not clear what means have been developed to include parents or guardians of LEP students in matters pertaining to their children’s education, and to determine whether parents require translated documents or interpretation in order to participate in their children’s education. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 29 of 33 Indicate whether the district uses assessment data to plan and implement educational programs for students at different instructional levels, and, if not, provide a plan to remedy this by November 14, 2008. Revise the exit criteria consistent with Department guidance referenced in the previous column. Ensure that exit criteria include consideration of multiple measures, including but not limited to the following: MEPA results, grades, teacher observation, and local criteria for grade advancement. Also ensure that the district does not cap or limit the amount of time in which an LEP student can remain in a language support program. Submit the new procedures by November 14, 2008. Submit evidence of parent outreach at all levels, including a description of the means of including parents or guardians of LEP students in matters pertaining to their children’s education. Also include the means by which the district will ensure that translated documentation and interpreters are provided when needed. Provide this description, including evidence of the above, by November 14, 2008. ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 8 Declining Entry to a Program ELE 9 Instructional Grouping Partially Implemented ELE 10 Parental Notification Partially Implemented √ Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting The district submitted appropriate procedures for declining entry to a program, including providing supports to students whose parents have declined entry to an ELL program. While the district rates this criterion as implemented, due to other issues with the ELL program as identified in other criteria, in particular ELE 5 and 14, the district has not demonstrated that it ensures that LEP students receive effective content instruction at appropriate academic levels and that ESL/ELD instruction is at the appropriate proficiency level and based on the English Language Proficiency Benchmarks and Outcomes. The district’s parent notification form lacks appropriate content. Specifically, the form does not include information about the waiver, the level of English proficiency, and the program placement and method of instruction. In addition, the parent notification form is currently not translated, though the district is working on this concern. See ELE 5 and 14. The district must create a notice that meets all requirements of this criterion. Specifically, the following is required for parental notification: the reasons for identification of the student as LEP; the child’s level of English proficiency; program placement and/or the method of instruction used in the program; the parents’ right to apply for a waiver (see ELE 4), or to decline to enroll their child in the program (see ELE 8). Please note that the notice should be sent annually. Provide the new notice and evidence that it has been provided to appropriate district personnel by November 14, 2008. Provide evidence that the notice can be translated, if necessary, by November 14, 2008. Conduct a review of the records of all ELL Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 30 of 33 ELE Criterion Number and Topic ELE 11 Equal Access to Academic Programs and Services Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Partially Implemented Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) ELL students currently do not participate fully with peers because ESL/ELD instruction is being provided by non-certified personnel. In addition, because the district does not currently provide SEI instruction, the district does not ensure that LEP students are taught to the same academic standards and curriculum as all students, and does not provide them the same opportunities to master such standards as other students. See ELE 5. Required Corrective Action, Timelines for Implementation, and Progress Reporting students enrolled in the district during the 20082009 school year. Provide a report of the review including the following: Role of staff completing review; Number of records reviewed; Number of records which contained appropriate notices that meet the content requirements of this criterion; Number of records in which parents required translated documentation; Number of records in which translated notices were found; Actions taken by the district to remedy any non-compliance found as a result of this review. Provide a report of this review March 16, 2009. See ELE 5. Provide a description of the means by which the district ensures that ELL students have equal access to academic programs and services, including guidance and counseling, as required by this criterion. Provide this description, and evidence of its implementation by November 14, 2008. The district does not have a means of ensuring that LEP students have the opportunity to receive support services, such as guidance and counseling, in a language that the student understands. ELE 12 Equal Access Partially The district reported that ELL students participate in non-academic and extra-curricular activities such as athletics and clubs. However, Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 31 of 33 Provide a description of the means by which the district will ensure that LEP students have equal ELE Criterion Number and Topic to Nonacademic and Extracurricular Programs Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Implemented ELE 13 Follow-up Support √ ELE 14 Licensure Requirements Not implemented Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) given issues with translation, it is not clear how the district provides appropriate support, where necessary, to LEP students to ensure that they have equal access to the nonacademic programs and extracurricular activities available to their English-speaking peers. Information is not currently provided to LEP students or their parents about extracurricular activities and school events in a language they understand. The district reports that it monitors students who have exited the ELL program. The district actively monitors students who have exited the ELL program for two years and provides language support services to those students, if needed. The district does not currently employ an appropriately licensed ESL teacher. See ELE 5. Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 32 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting access to non-academic and extra-curricular programs and services. Provide this description, and evidence of its implementation by November 14, 2008. See ELE 5. ELE Criterion Number and Topic ELE 15 Professional Development Requirements Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) See ELE 5. Required Corrective Action, Timelines for Implementation, and Progress Reporting Submit the roster of staff taking part in SEI training, per ELE 5. On the roster include the names, grade levels and ELE/SEI training topics that staff have taken part in or are scheduled to participate in. Submit this information by March 16, 2009. Partially Implemented Provide a list of the district’s ELL students (by initials) and the teachers to whom they are assigned by March 16, 2009. ELE 16 Equitable Facilities ELE 17 Program Evaluation √ Partially Implemented ELL students are provided with facilities, materials and services comparable to those provided to the overall student population. The district has hired a consultant to conduct periodic evaluations of the effectiveness of its ELE program in developing students’ English language skills and increasing their ability to participate meaningfully in the educational program. ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) Millis Public Schools Coordinated Program Review Mid-cycle Report September 17, 2008 Page 33 of 33 Submit the report of the ELE program evaluation by March 16, 2009.