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 19, 2006 Dr. Chris Augusta-Scott Superintendent of Schools Norfolk Public Schools 70 Boardman St. Norfolk, MA 02056 Re: Mid-cycle Coordinated Program Review Report Dear Dr. Augusta-Scott: Enclosed is the Department of Education's 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 by the Department to address findings of noncompliance included in the Norfolk Public Schools Coordinated Program Review Report issued on August 26, 2003. The Mid-cycle Report also contains findings based on onsite monitoring of special education compliance criteria that have been newly created or substantially changed in response to IDEA 2004. As you know, another component of the Department’s Mid-cycle Review is the review of your school district or charter school's self-assessment in the area of English learner education (ELE). (In the remainder of this letter, please read “district” as meaning “school district or charter school.”) The purpose of this review is to determine whether your district is implementing the significant changes in M.G.L. Chapter 71A, governing the education of limited English proficient students, that were adopted by voters by means of Question 2 in 2002. The Department has reviewed your district’s ELE self-assessment documents and, based solely on that self-assessment, is providing you in this report with comments on your ELE program and, where necessary, corrective action to be implemented. Your district is urged to request technical assistance in relation to any of these comments or prescribed corrective action. To secure assistance, you may consult with your Mid-cycle Review Chairperson or call Robyn Dowling-Grant in Program Quality Assurance Services at 781-338-3732. You may also consult with staff in the Department’s Office of Language Acquisition and Achievement at 781-338-3534 and obtain additional ELE guidance documents through the Department’s web site at http://www.doe.mass.edu/ell/ . The onsite team would like to commend the following areas that were brought to its attention and that the team believes have a significant and positive impact on the delivery of educational services for students enrolled in the Norfolk Public Schools. These areas are as follows: The Team process is run in a way that facilitates positive collaboration between the district and parents. The quality of the goals and objectives on the IEPs is commendable. Assessments completed for initial evaluations and reevaluations are thoroughly done and easily readable. Specific programs, in particular the math, reading, and pre-K programs, are of high quality. The district’s commitment to providing numerous opportunities for staff members to access professional development is commendable. Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 1 of 15 The Department will notify you of your district's next regularly scheduled Coordinated Program Review several months before it is to occur. At this time we anticipate the Department's next routine monitoring visit to occur sometime during the 2009 school year, unless the Department determines that there is some reason to schedule this visit earlier. 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 school district within the timelines specified. Your statement of assurance must be submitted to the Mid-cycle Review Chairperson by June 2, 2006. Your staff's cooperation throughout these follow-up monitoring activities is appreciated. Should you like clarification of any part of our report, please do not hesitate to contact the Mid-cycle Review Chairperson at 781-338-3704. Sincerely, Matthew Deninger, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Kim Williams, School Committee Chairperson Encl.: Mid-cycle Coordinated Program Review Report Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 2 of 15 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT NORFOLK PUBLIC SCHOOLS ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION Date of Coordinated Program Review (CPR): August 26, 2003 Date of Coordinated Program Review Corrective Action Plan Approval: December 4, 2003 Dates of Corrective Action Plan Progress Reports: January 16, 2004, October 28, 2004, November 16, 2004, April 11, 2005, August 26, 2005, and January 23, 2006 Dates of this Mid-cycle Review Onsite Visit: March 13-14, 2006 Date of this Report: May 19, 2006 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 3 of 15 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Determined to be Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Determined Not to have been Implemented or Not to have been Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting (previously SE 18B) According to the district’s own tracking sheet, during the 2005-2006 school year IEPs are being provided to parents within three school days 64% of the time. While this is an improvement from previous years, this criterion is not significantly implemented. The district will continue monitoring the provision of IEPs using the same tracking sheet through the end of the ’05-’06 school year and into the ’06-’07 school year. Implementation will be verified by review of the tracking sheet to be submitted no later than July 15, 2006, and an onsite record review to occur no later than October 1, 2006. The district will continue to monitor the timely provision of IEPs using its aforementioned tracking sheet. Implementation will be verified by review of the tracking sheet to be submitted Special Education Criteria Originally Cited in CPR Report and Monitored in Mid-cycle SE 9: Eligibility determination: Timelines for evaluation, provision of IEP and/or identification of other needed instructional programs. SE 10: End of school year evaluations. Record review indicated that IEPs developed at the end of the school year were not consistently being provided within 14 days after the end Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 4 of 15 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) SE 18B: Determination of placement; provision of IEP to parent. SE 23: Confidentiality of personally identifiable information SE 24: Notice to parent Approved Corrective Action Determined to be Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Record Review and Interviews Corrective Action Determined Not to have been Implemented or Not to have been Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting of the school year. no later than July 15, 2006, and an onsite record review no later than October 1, 2006. Record review indicated that most special education records did not contain a log of access. (This criterion was not previously cited in the 2003 CPR.) The district will include logs of access in every special education record. Implementation will be verified by review of a sample log of access to be submitted no later than July 15, 2006, and an onsite record review no later than October 1, 2006. The district should provide training for the staff members whose responsibility it is for completing notice forms. Evidence of training (agenda, sign-in sheet) will be submitted to the Department no later than This criterion is fully implemented, except for the immediate provision of the IEP to parents, which has been addressed under SE 9. Record review indicated that notice forms (N1 and N2) were not consistently completed. On some forms, page 2 did not include the required guiding questions that must be answered. On Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 5 of 15 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) SE 28: Parent provided the IEP or notice of no eligibility together with notification of procedural safeguards and parents' rights. SE 50: Responsibilities of the School Principal and Administrator of Special Education. SE 56: Special Approved Corrective Action Determined to be Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Record review and interviews When appropriate, the district provides notice forms along with the Interim Notice of Procedural Safeguards to parents. This was verified by looking at the enclosures listed on the notice form, as well as through interviews. Record review and interviews Due to a change in criterion, this will be addressed under MOA 18. Documentation The district hired a consultant to Corrective Action Determined Not to have been Implemented or Not to have been Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting other forms, the answers to these guiding questions were not thorough, depriving parents of their right to receive adequate notice. July 15, 2006. Implementation will be verified during an onsite record review no later than October 1, 2006. Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 6 of 15 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Determined to be Implemented and Effective Basis of Determination that Corrective Action was Implemented and has been Effective education programs and services are evaluated. Criterion Number and Topic Criterion Implemented (Refer to full text of 20052006 CPR requirements) Special Education Criteria created or Method(s) of Verification review conduct a study of the special education department and its various programs and services. The study details the current status of the department, as well as considerations for the future. Method(s) of Verification Basis of Determination that Criterion was Implemented Corrective Action Determined Not to have been Implemented or Not to have been Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Determined to be Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 7 of 15 revised in response to IDEA-2004 Interviews The district only runs PK-6, so none of the secondary transition criteria apply. The district does provide some transition services from PK to K, and from grade 6 to the King Philip Middle School. Record review and interviews The IEP Team composition is strong in this district. All members are in attendance and participate in meetings. Record review and interviews Record review and interviews Reevaluations are done every three years in this district. In addition, when a student is suspected to be no longer in need of special education services, reevaluations are always completed. Progress reports are complete, thorough, address all goals in the IEP, and are always sent out to parents in a timely manner. SE 6 Determination of Transition Services SE 8 IEP Team composition and attendance SE 12 Frequency of re-evaluation SE 13 Progress Reports and content SE 14 Review and revision of IEPs SE 25B Resolution of disputes SE 30 Notice of Record review and interviews Documentation and record review Documentation review, record IEPs are reviewed at least on an annual basis. The district has also adjusted to the new IDEA 2004 provisions, allowing amendments to be made without convening the Team. When receiving notice of a request for a hearing with the BSEA, the district convenes a resolution meeting within 15 days. The Interim Notice of Procedural Safeguards was mailed to parents Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 8 of 15 procedural safeguards SE 46 Procedures for suspension of students with disabilities more than 10 days review and interviews of special education students in the fall of 2005. Documentation review The district’s procedures for suspension of students with disabilities are consistent with federal law. Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 9 of 15 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Determined to be Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Determined Not to have been Implemented or Not to have been Effective Or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective Or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements Civil Rights (MOA) and Other General Education Requirements MOA 18: Responsibilities of the school principal MOA 21: Staff training regarding civil rights responsibilities. (previously SE 50) The district, although it has a Curriculum Accommodation Plan, has not updated the plan since the 2002-2003 school year, and has not made its staff members aware of the document’s several uses. Documentation review and interviews The district submitted evidence in its documentation that civil rights training had occurred on 8/31/05. The specific topic was sexual harassment. Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 10 of 15 The district will submit a plan for the revision of the DCAP. The plan should be submitted to the Department no later than July 15, 2006. The DCAP will be revised before the start of the 2006-2007 school year, and each staff member will be given a copy and instructed on its purpose and uses. Verification will be made during an onsite visit to occur no later than October 1, 2006. MOA 22: Accessibility of district programs and services for students with limited physical mobility. The district has spent $23,595 on repairs to rectify accessibility issues from June 2003 through June 2004. The FreemanCentennial School is the facility in most need of renovations. The district ensures that students with disabilities have access to classrooms and to all of the same activities as other students. The H. Olive Day School is free from accessibility issues. However, sink fixtures in the PK classrooms are large and not easily accessible for any student, let alone for students with limited physical mobility. Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 11 of 15 The district will submit an update of accessibility improvements made during the 2005-2006 school year no later than July 15, 2006. The district will also submit any plans for the refurbishment of the Freeman-Centennial School no later than July 15, 2006. NORFOLK PUBLIC SCHOOLS English Learner Education (ELE) Requirements Mid-Cycle Review Comments and Corrective Action Based on the Department’s Review Of Local Self-Assessments (Please refer to full text of 2005-2006 CPR-ELE legal requirements and related implementation guidance at http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc ) ELE Criterion Number and Topic Comments Based on the Department’s Review of Local ELE Self-Assessment Required Corrective Action, Timelines for Implementation, and Progress Reporting The district maintains that “tests are being ordered,” however there is no indication of which specific tests are being ordered and for whom they are being ordered. The district must develop policies and procedures for the annual assessment of limited English proficient students. Policies and procedures will be submitted to the Department no later than July 15, 2006. ELE 2 MCAS Participation The district does not have policies and procedures regarding the MCAS participation of LEP students. The district must develop policies and procedures for limited English proficient students’ MCAS participation. Policies and procedures will be submitted to the Department no later than July 15, 2006. ELE 3 Initial Identification A home language survey was completed, and is now part of new student registration packets. However, there is no indication of a translated version of the home language survey. The district does not have waiver forms or policies and procedures for waivers. The district must have a translated home language survey in a common language spoken in the immediate area. Copies of the translated home language survey will be submitted to the Department no later than July 15, 2006. ELE 1 Annual Assessment ELE 4 Waiver Procedures ELE 5 Program Placement and Structure The district does not currently have an ELE program of any kind. The district must develop policies and procedures for the parent’s right to waive ELE services. The district must also develop the waiver forms. Policies and procedures, along with waiver forms, will be submitted to the Department no later than July 15, 2006. The district must develop a program and placement structure for LEP students and submit the program’s description to the Department no later than July 15, 2006. Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 12 of 15 ELE Criterion Number and Topic Comments Based on the Department’s Review of Local ELE Self-Assessment Required Corrective Action, Timelines for Implementation, and Progress Reporting ELE 6 Program Exit and Readiness The district does not have policies and procedures regarding program exit and readiness. The district must develop policies and procedures for limited English proficient students’ program exit. A description of the program will be submitted to the Department no later than July 15, 2006. ELE 7 Parent Involvement The district does not have a description of how they plan to involve parents of students who are LEP. The district must develop policies and procedures for involvement of parents of limited English proficient students. Policies and procedures will be submitted to the Department no later than July 15, 2006. ELE 8 Declining Entry to a Program The district does not have policies and procedures regarding students whose parents have declined entry to an ELL program. The district must develop policies and procedures for systems that support LEP students whose parent have declined entry in the ELL program. Policies and procedures will be submitted to the Department no later than July 15, 2006. ELE 9 Instructional Grouping The district does not have policies and procedures regarding the instructional grouping of LEP students. The district must develop policies and procedures regarding the instructional grouping of LEP students. Policies and procedures will be submitted to the Department no later than July 15, 2006. ELE 10 Parental Notification The district does not have policies, procedures, or supporting documentation regarding the required elements of parent notices. ELE 11 Equal Access to Academic Programs and Services The district does not address the requirements of equal access to academic programs and services for LEP students. The district must develop policies and procedures regarding notices sent to parents of LEP students. In addition, the district must develop notice forms that include all required elements. Policies and procedures, as well as a sample notice form, will be submitted to the Department no later than July 15, 2006. The district must develop policies and procedures regarding equal access to academic programs and services for LEP students. Policies and procedures will be submitted to the Department no later than July 15, 2006. ELE 12 Equal Access to Nonacademic and Extracurricular The district does not address the requirements of equal access to nonacademic and extracurricular programs for LEP students. The district must develop policies and procedures regarding equal access to nonacademic and extracurricular programs for LEP students. Policies and procedures will be submitted to the Department no later than July 15, 2006. Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 13 of 15 ELE Criterion Number and Topic Programs Comments Based on the Department’s Review of Local ELE Self-Assessment Required Corrective Action, Timelines for Implementation, and Progress Reporting ELE 13 Follow-up Support The district does not have policies or procedures regarding the monitoring activities provided for students who have exited the ELL program. The district must develop policies and procedures regarding the monitoring activities provided for students who have exited the ELL program. Policies and procedures will be submitted to the Department no later than July 15, 2006. ELE 14 Licensure and Fluency Requirements Though the district maintains that one teacher in the district is ELL licensed, the district did not provide the teacher’s name, position, or licensure information. The district must have an ESL certified teacher in place, as well as teachers at each grade level who are trained in Sheltered English Immersion. The district should submit a professional development plan for providing teachers with the Sheltered English Immersion training that is required. The district should also submit evidence of an ESL-certified teacher. This plan will be submitted to the Department no later than July 15, 2006. Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 14 of 15 ELE Criterion Number and Topic ELE 15 Professional Development Requirements Comments Based on the Department’s Review of Local ELE Self-Assessment Required Corrective Action, Timelines for Implementation, and Progress Reporting The district must have ongoing professional development regarding the provision of high quality instruction for LEP students. The district should submit a professional development plan for providing teachers with ongoing training regarding the instruction of LEP students. This plan will be submitted to the Department no later than July 15, 2006. ELE 16 Equitable Facilities (To be reviewed during next CPR visit) The district does not have policies or procedures regarding the provision of equitable facilities for LEP students. The district must develop policies and procedures regarding the provision of equitable facilities for LEP students. Policies and procedures will be submitted to the Department no later than July 15, 2006. ELE 17 DOE Data Submission Requirements and Program Evaluation While the district has reported its SIMS data, the district does not conduct periodic evaluations of its ELL program. The district must develop policies and procedures regarding the periodic evaluation of its ELL program. Policies and procedures will be submitted to the Department no later than July 15, 2006. ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) The district does not have any students who have been identified as being LEP. Therefore the district does have records of LEP students. Norfolk Public Schools Coordinated Program Review Mid-cycle Report May 19, 2006 Page 15 of 15