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 December 17, 2007 Judith L. Klimkiewicz, Superintendent Nashoba Valley Technical High School 100 Littleton Road Westford, MA 01886 Re: ’07 Mid-cycle Coordinated Program Review Report Dear Superintendent Klimkiewicz: Enclosed is the Department of Education's ’07 Mid-cycle Coordinated Program Review Report (Mid-Cycle Report). This report contains findings based on onsite monitoring conducted to verify the implementation and effectiveness of corrective action approved or ordered by the Department to address findings of noncompliance included in the Nashoba Valley Technical High School ’04 Coordinated Program Review Report issued on August 25, 2004. The ’07 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 selfassessment 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 (documentation and any written analysis of compliance) and, based solely on that self-assessment, is providing you in this report with findings on your ELE program and the corresponding 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 781-3383534. ELE guidance documents are available on the Department’s website at http://www.doe.mass.edu/ell/ . The onsite team would like to commend the following programs and practices that were brought to its attention and that the team believes have a significant positive impact on the education of students enrolled in the Nashoba Valley Technical High School. These programs and practices are as follows: The district has made significant progress in addressing areas of previous non-compliance noted in the most recent Coordinated Program Review The district has a newly developed inclusion model for the provision of special education services that required the design of a new schedule to incorporate inclusion classes. The district has engaged in efforts to provide professional development opportunities for staff and has worked on bridging the gap between academic and technical teachers 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. 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 district within the timelines specified. You must submit your statement of assurance to me by January 11, 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 781-338-3747. Sincerely, Joel Krakow, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services cc: Jeffrey Nellhaus, Acting Commissioner of Education Kevin McKenzie, School Committee Chairperson Melissa LeRay, District Program Review Follow-up Coordinator Encl.: ’07 Mid-cycle Coordinated Program Review Report MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT Nashoba Valley Technical High School ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS Date of Coordinated Program Review (CPR): April 12-16, 2004 Date of Coordinated Program Review Corrective Action Plan Approval: December 13, 2004 Dates of Corrective Action Plan Progress Reports: October 7, 2004 Dates of this Mid-cycle Review Onsite Visit: March 12, 13, 2007 Date of this Report: December 17, 2007 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Special Ed. Criteria Cited in CPR Report and Monitored in Mid-cycle MOA 4 Disproportionality Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Review of data The district was not cited for noncompliance in this area in 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 Nashoba Valley Technical High School Coordinated Program Review ’07 Mid-cycle Report December 17, 2007 Page 1 of 14 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification the most recent CPR in 2004. (if Cited in the CPR Report) SE 9 IEP Timelines SE 15 Outreach SE 18A IEP development and content SE 18B Provision of Basis of Determination that Corrective Action was Implemented and has been Effective Review of student records, documentation and interviews. Review of student records and interviews demonstrated that regulatory IEP timelines are being met. Review of student records, and documentation Review of records and documentation showed that the district contacts a wide variety of agencies and settings Review of student records, and documentation Review of records and documentation showed that the district has changed its service delivery model to focus on more inclusion. Training has also been provided to staff for differentiated instruction, especially for vocational staff. Review of student records Review of records and interviews showed that 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 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective SE 22 IEP availability Basis of Determination that Corrective Action was Implemented and has been Effective IEP to parent SE 20 Least restrictive program Method(s) of Verification and staff interviews parents receive the IEP at the Team meeting. Review of student records, documentation and staff interviews The district has changed the basic structure of its special education delivery system, eliminating academic support classes and focusing on more inclusion. 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 Review of documentation and staff interviews showed that teachers are given a list of accommodations for students on IEPs but that they do not receive the actual IEP. Please submit a copy of the district’s policy statement demonstrating that teachers are provided with access to each student’s IEP. Due January 30, 2008. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) 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 SE 32 Parent advisory council SE 34 Continuum of alternative services Review of student records, documentation and staff interviews SE 40 Instructional grouping Review of student records, documentation and staff interviews SE 50 Administration Review of student records, documentation and staff interviews The district has changed its service delivery model to provide a broader array of services to students Review of documentation and staff interviews showed that special education classes sizes conform to regulations. Since the Department’s Coordinated Program review in 2004, the district has reorganized its special education administrative services, including the hiring 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 Review of documentation and staff interviews showed that parents are not involved in the planning, development and evaluation of the special education program. Please submit documentation to the Department that the PAC is involved in the review of special education policies and programs. Due January 30, 2008. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective of a full time director. An outside evaluation of the district’s special education services shows much improvement in the provision of support services. SE 54 Professional development Review of documentation Review of documentation demonstrated that the district is providing required training for staff. SE 56 Program evaluation Review of documentation Review of documentation demonstrated that the district has evaluated its special education programs and services. 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 Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Review of records Review of records demonstrated that the district appropriately plans for transition activities for students with disabilities 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 Review of records demonstrated that regular education teachers are not always in attendance at Team meetings. Please submit a sample of 4-6 student folders reflecting attendance by regular education teachers to the Department by January 30, 2008 Special Education Criteria created or revised in response to IDEA-2004 SE 6 ##1 - 3 Determination of Transition Services SE 8 IEP Team composition and attendance SE 12 Frequency of re-evaluation Record review Review of student records and interviews demonstrated that reevaluations are completed at least every three years SE 13 Progress Reports and content Record review Progress reports indicated whether the student’s progress is adequate to meet the annual goal as written in the progress report. Criterion Number and Topic SE 14 Review and revision of IEPs Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Record review Review of student records showed that the district is appropriately conducting annual reviews and amending IEPs as needed. SE 25B Resolution of disputes SE 33 Involvement in the General Curriculum SE 39A Procedures for services to eligible private school students whose parents reside in the district Criterion Determine d to be Partially Implement ed or Not Implement ed N/A (SE 39A does not apply to charter schools or vocational schools) Review of records and documentation Review of student records and student schedules demonstrated that students participate in the general curriculum. Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Review of records showed that the district did not always document that it notifies the BSEA regarding any rejected IEPs received by the district. The district will submit a sample of copies of notices to the BSEA to the Department by January 30, 2008. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Review of student records, documentation and staff interviews Review of documentation and staff interviews showed that although the district has not had the need to develop any behavioral plans, a process is in place if the need arises to conduct Functional Behavioral Assessments and Manifestation Determinations consistent with federal requirements. N/A (SE 39B does not apply to charter schools or vocational schools) SE 46 Procedures for suspension of students with disabilities more than 10 days Corrective Action Not Implement ed 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 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Civil Rights (MOA) and Other General Education Requirements Other Regulated Programs Monitored During this Mid-cycle Review 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 Nashoba Valley Technical Regional High School English Learner Education (ELE) Requirements Mid-Cycle Review Findings and Corrective Action Based on the Department’s Review Of Local Self-Assessments (Please refer to full text of 2006-2007 CPR requirements for ELE and related implementation guidance at http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc ) There are no Limited English Proficient (LEP) students currently enrolled in the vocational school. The school has established procedures for addressing the requirements for LEP students under Massachusetts General Laws, Chapter 71A, should they enroll. ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 1 Annual Assessment Implemented ELE 2 MCAS Participation Implemented ELE 3 Initial Identification Implemented ELE 4 Waiver Procedures Implemented ELE 5 Program 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 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Placement and Structure ELE 6 Program Exit and Readiness ELE 7 Parent Involvement ELE 8 Declining Entry to a Program Implemented Implemented Implemented ELE 9 Instructional Grouping Implemented ELE 10 Parental Notification Implemented ELE 11 Equal Access to Academic Programs and Services ELE 12 Equal Access to Implemented 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 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Nonacademic and Extracurricular Programs ELE 13 Follow-up Support Implemented ELE 14 Licensure Requirements 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 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 15 Professional Development Requirements Implemented ELE 16 Equitable Facilities Implemented ELE 17 Program Evaluation Implemented ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) 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