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 May 2, 2005 Michael L. Wood Superintendent Nashoba Regional School District 50 Mechanic Street Bolton, MA 01740 Re: Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action Plan Verification and Special Education Mid-cycle Review Dear Superintendent Wood: 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 August 7, 2002. We are pleased to note the progress your district has made in remedying the previously identified noncompliance issues. In some cases you may find that we have set additional Progress Reporting requirements where full implementation of your approved Corrective Action Plan has not yet been fully documented. Please note the due dates for any additional reports to the Department. If an onsite visit is required to verify implementation of Progress Report activities, we will notify you of the date for this visit and plan the schedule of activities with a person you designate. Your staff's cooperation throughout these Follow-up Monitoring activities is appreciated. Should you require additional clarification of information included in our report, please do not hesitate to contact the Onsite Team Chairperson at 781-338-3722. Sincerely, Susan D. Nichols, 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 Encl.: Follow-up Monitoring Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION COORDINATED PROGRAM REVIEW Nashoba Regional School District ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Onsite Visit Conducted on April 12-13, 2005 Date of this Report May 2, 2005 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Special Education Requirements SE 3 Special requirements for determination 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 Student Records Documentation The district has policies and procedures for the determination of specific learning disabilities. The 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 specific learning disabilities 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 district is implementing the special requirements for determination of specific learning disabilities. 2 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 6 Determination 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 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 Progress reports did not always include written information on the student’s progress toward the annual goal and some of the progress was not Provide training for special education providers on this requirement and provide the agenda and signed attendance sheet to the Department by November 15, 2005. Submit a Student Records Interviews IEP transition statements and activities were adequately reflected in the student record to determine needed transitional planning As appropriate, The IEP Teams consider the course of study in relation to future goals and interest for students and promote movement to post secondary programs. The district makes 688 referrals when needed. Partially Implemented Student Records Documentation Interviews Parents of special needs students are receiving progress reports as often as parents are informed of the progress of non-disabled students. 3 Partially Implemented 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 reported in measurable terms. 4 random sample of ten progress reports written for the first and second quarter of the 20052006 school year by March 1, 2006. 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 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 information required to be included on the district’s proposal (N1 form) is not always complete. Provide training for special education providers on this requirement and provide the agenda and signed attendance sheet to the Department by November 15, 2005. Submit a random sample of ten Documentation Interviews Documentation Interviews Partially Implemented Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Student Records Documentation Interviews The district conducts outreach within the school and throughout the community from which promotion or transfer of students in need of special education may be expected. The district adheres to the initiation of services at age three and coordinates with Early Intervention Programs to transition children into the schools. The IEP Teams, upon determining that the student is eligible for special education, use evaluation data to develop the IEP that contains all required elements. The IEP generally includes specifically designed instruction to meet 5 Partially Implemented 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 individual needs of students and related services. The district ensures that each IEP Team has at least one person with authority to commit the district resources. 6 completed N1 forms by March 1, 2006. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 18B Determination of placement; immediate provision of IEP to parent SE 20 Least restrictive program selected Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Partially Implemented Student Records Interviews Student Records Interviews 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 Documentation SE 22 IEP Comments Regarding Corrective Action Plan Implementation Student IEP Teams determine the appropriate placement to deliver the services on student IEPs. Placement selected by the Team is the least restrictive environment consistent with the needs of the student. The district is committed to inclusion practices and in providing the least restrictive environment for its students with special needs. The district offers several indistrict placement options and students are included throughout all grade levels, consistent with their needs. The district has an IEP in 7 Partially Implemented Student record reviews indicated that IEPs are not always provided to the parent immediately following its development and within 45 working days after a parent’s written consent to evaluations. Provide the district’s plan for tracking and ensuring that all IEPs are provided to the parent immediately (within 3-5 days) of the Team meeting by July 1, 2005. Provide a copy of the tracking system used from September 1-November 1, 2005 by November 15, 2005. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) implementation and 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 Records Documentation Interviews effect for eligible students at the beginning of each school year and begins IEP services without delay once the student’s parent has accepted an IEP. Staff are informed of their responsibilities and teachers have access to the IEP, and service providers document on worksheets what they are providing in classes to students. 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 SE 29 Communica- Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Documentation Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Student Records See SE 18 B See SE 18 B The district makes attempts to ensure parental participation in IEP Team meetings and parental attendance is high. See SE 18 B Partially Implemented Interviews Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Interviews Partially Implemented Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Student Communications with parents 9 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) tions are in English and primary language of home 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 Records are in English and the primary language of the home. Interviews 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) SE 32 Parent advisory council for special education SE 50 Responsibilities of the School Principal and Administrator of Special Education SE 54 Professional Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Documentation Documentation Interviews Partially 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation The district has established a parent advisory council (PAC) on special education, which meets the requirements of state law and regulation. The district has a Curriculum Accommodation Plan that is implemented by the building principals. The district ensures that all Administrators fulfill the responsibilities set forth in state and federal law and regulations. Principals in each of the district’s schools promote instructional practices that are responsive to student needs and ensure that adequate instructional support is available for students and their teachers. The district offers many of the required professional 11 Partially The district has not Provide the required training Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) development regarding special education SE 56 Special education programs and services are evaluated Other Requirements Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation 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 provided the annual required training on state and federal special education requirements and related local special education policies and procedures and confidentiality of student records. for special education regulations and confidentiality issues to all staff and provide the agenda and attendance sheets to the Department by November 15, 2005. Implemented Interviews Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation development opportunities In particular, training on analyzing and accommodating diverse learning needs and training on differentiated instruction Special education programs, services and administrative areas are regularly evaluated. Interviews 12 Implemented Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 34 Continuum of Alternative Services and Placements SE 45 Procedures for suspension up to 10 Days and after 10 days: General Requirements SE 46 Procedures for suspension of students with disabilities when suspensions exceed 10 consecutive Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Documentation Staff Interviews Documentation Staff Interviews Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Student Records Documentation Interviews The district offers a continuum of services and placements to meet the needs of students in special education. The district submitted a policy and procedures for suspensions up to and exceeding 10 days that meets the requirements of this criterion and included procedural safeguards. The district has appropriate procedures for suspending students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative school days. 13 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 school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district 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 7 Information to be Translated into languages other than English MOA 10A Handbooks and codes of conduct MOA 11A Designation of liaison/coordina tor(s); grievance 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 Documentation Interviews Interviews indicate the district has a mechanism for providing written information or documents into languages other than English and submitted a sample of translated material. Documentation The district submitted a copy of all of their school handbooks. All handbooks contain a policy on nondiscrimination, harassment, grievance procedures and district disciplinary policy and procedures. Documentation The district has designated the appropriate civil rights coordinators and adopted and published grievance Interviews 15 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 MOA 21 Staff training regarding civil rights responsibilities procedures. Documentation Interviews Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified procedures MOA 16 Notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion Comments Regarding Corrective Action Plan Implementation Documentation Interviews The district submitted its notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion that includes all required information. The district provides the required in-service training for all school personnel regarding civil rights responsibilities. 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