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 January 30, 2007 Richard Smith Superintendent of Schools North Attleborough Public Schools 6 Morse Street North Attleborough, MA 02760 Re: Mid-cycle Coordinated Program Review Report Dear Superintendent Smith: Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report (MidCycle Report). This report contains findings based on onsite monitoring conducted to verify the implementation and effectiveness of corrective action approved or ordered by the Department to address findings of noncompliance included in the North Attleborough Coordinated Program Review Report issued on June 15, 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 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 781338-3534. 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 North Attleborough Public Schools. These programs and practices are as follows: The district has made efforts to include all students into the life of their schools. They are aware of the benefits of locating special education classes in locations that promote integration and minimize separation and stigmatization of eligible students. Project 1 Teammates was initiated at the high school to promote inclusive practices. Through this program regular education students have become involved in a collaborative class of student thus providing increased opportunities for disabled students to interact with their peers. All students benefit from the services of a vocational counselor who can attend Team meetings and help students explore vocational opportunities. Summer job experiences are supported as the counselor works with interested students and employers willing to give students the opportunity to explore their interests. 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 that this CPR will occur sometime during the 2010 unless the Department determines that there is some reason to schedule this visit earlier. 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 24, 2007. 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 781-338-3714. Sincerely, Nancy Hicks, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education David Manoogian, School Committee Chairperson Margo Brissette, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT North Attleborough Public Schools ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS Date of Coordinated Program Review (CPR): February 26, 2004-March 5, 2004 Date of Coordinated Program Review Corrective Action Plan Approval: October 7, 2004 Dates of Corrective Action Plan Progress Reports: October 18, 2004, February 25, 2005, May 16, 2005 and October 15, 2005 Dates of this Mid-cycle Review Onsite Visit: January 4 and 5, 2007 Date of this Report: January 30, 2007 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 1 of 13 Criterion Number/Topic Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Student records SE 18 A IEP Content Partial Student records If a student is removed from the general education classroom at any time, the IEP included a statement indicating why the removal was considered critical and the basis for the conclusion. Some IEPs clearly indicated what the student would need to do to achieve the IEP goal and how it would be measured. SE 24 Notice Student records SE 48 FAPE (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and 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 Some IEPs, however, contained goals that were not measurable and they did not always include information on how progress would be measured. By April 1, 2007, provide a schedule of proposed training on writing measurable goals and a list of those who will be included in the training. Special Ed. Criteria Cited in CPR Report and Monitored in Mid-cycle SE 20 #2 Least Restrictive Program Interviews Partial Notice, provided when the district proposed an IEP or informed the parent of a finding of no eligibility, contained all required questions and the questions were consistently addressed. The district has made efforts to include Bi-County Collaborative students into the life of the school. Schedules were changed so that collaborative students at the Community School have lunch North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 2 of 13 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 54 Professional Development SE 55 Special Education Classrooms Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Documentation and interviews Interviews Community School Tour 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 with age appropriate students. Students are encouraged at the high school to take part in school activities and Project Teammates has supported reverse integration in a collaborative class. Professional development has been provided in the required areas. Teachers have all been trained in analyzing and accommodating diverse learning styles of all students and methods of collaboration among teachers, paraprofessionals and teacher assistants. The location of special education facilities and classrooms are accessible and minimize the separation or stigmatization of eligible students. North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 3 of 13 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic 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 Criterion Implemented Partial Method(s) of Verification Student records and interviews and documentation Student records and interviews Basis of Determination that Criterion was Implemented Age appropriate students are consistently invited to and attend Team meetings. Students’ interests and long team goals are included in the IEP. The district utilizes the Transitional Planning Chart when considering the need for transitional goals and transition services at the Team meeting. Note that consistent with the recently enacted IDEA-2004 regulations, the transition planning chart will become a mandated form, which should be maintained with the student’s IEP. Refer to Administrative Advisory SPED 2007-1 for guidance. The Department is currently revising this form, please check the Department’s Special Education website for updates and review the new requirements for transition planning and services with appropriate staff. No additional progress report is required. The district has a vocational counselor who often attends Team meetings when one purpose of the Criterion Partially Implemented or Not Implemented Partial Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Team meetings at the high school and middle school do not always have a regular By April 1, 2007, the district must develop and provide a procedure to ensure that regular education North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 4 of 13 Team meeting is to discuss vocational education needs. attendance SE 12 Frequency of reevaluation SE 13 Progress Reports and content Student records and interviews and documentation Student records and interviews and documentation education teacher in attendance when the student is involved or may be involved in a regular education program. The district conducts reevaluations as required every three years except when the parent and district agree that it is unnecessary. The district has not coordinated the dates of the evaluation with the annual review. Often there are two Team meetings scheduled within a short period of time, which may challenge the district’s ability to ensure that all required Team members are in attendance. Progress reports contain the required information and are issued with required frequency. When a student’s eligibility terminates because the student has graduated or exceeded the age of eligibility, a summary of academic achievement and functional performance is provided. Please note that recently enacted IDEA-2004 regulations have now changed the content requirements for IEP progress reports. Refer to Administrative Advisory SPED 2007-1 for guidance. The Department has changed the progress report form and it is now available on the Department’s Special Education website at http://www.doe.mass.edu/sped/iep/ eng_toc.html. North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 5 of 13 teachers attend Team meetings at the high school and middle school. Copies of a sample of five Team meeting attendance sheets from meetings scheduled in February or March 2007 at both the middle school and high school must be provided. Criterion Number and Topic SE 14 Review and revision of IEPs 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 Implemented Method(s) of Verification Student records, interviews and documentation Interviews and documentation Interviews and documentation Interviews and documentation Basis of Determination that Criterion was Implemented Criterion Determined to be Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented The district reviews the IEP annually on or before the anniversary date of the IEP. When the district and parent agrees to make changes to the student’s IEP without convening a meeting of the Team, it is not clear how the changes are being documented. An amendment to the IEP could be used to document the agreed to changes. The district is aware of their responsibility regarding the resolution of disputes when a parent requests an official hearing. They have not, however had the occasion to schedule such a meeting. The district documents the student’s participation in the general curriculum in the IEP. See SE 8 regarding the requirement to have in attendance at the Team meeting one member who is familiar with the general curriculum. The district provides services to five eligible students enrolled at private expense in private schools. They have completed the Proportionate Share Worksheet. Please note that consistent with recently enacted IDEA-2004 North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 6 of 13 Required Corrective Action, Timelines for Implementation, and Progress Reporting regulations, the public school district’s procedures for consultation with private schools requires the public school to obtain written affirmation of the private school representative’s participation. Refer to Administrative Advisory SPED 2007-1 for guidance. (SE 39A does not apply to charter schools or vocational schools) SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state Interviews and documentation The district was aware of their obligation regarding eligible students in private schools whose parents reside out of state. They do not have any students at this time. Student records and interviews The district has procedures in place to track student suspensions. Student records contained a detailed summary of a Manifestation Determination meeting. In response to a finding in a Problem Resolution investigation with the Department, the district is in the process of including in the high school handbook the procedures for suspension of students with disabilities. (SE 39B does not apply to charter schools or vocational schools) SE 46 Procedures for suspension of students with disabilities more than 10 days North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 7 of 13 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Civil Rights (MOA) and Other General Education Requirements MOA 17A Physical Restraints MOA 21 Civil Rights Training Approved Corrective Action Implemented and Effective Method(s) of Verification Documentation and interviews Documentation and interviews 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 Consistent with regulatory requirements, the district has implemented staff training on the use of restraint within the first month of school. The district has provided training for all school personnel at least annually regarding civil rights responsibilities. North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 8 of 13 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements Other Regulated Programs Monitored During this Mid-cycle Review 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 7 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 Interviews indicate that students were being asked to make the age of majority decision at age 17. In one student record a 17-year-old signed the IEP. Regulations require that one year prior to the student reaching age 18, the district informs the student of the transfer of rights at the age of majority. This discussion takes place at the Team meeting and is documented in the IEP under Additional Information. Upon reaching 18, the student’s decision regarding the age of majority must be documented. By April 1, 2007, the district must submit an agenda and sign-in sheet of training on the Age of Majority Decision documentation within the IEP. Provide a copy of an IEP of a 17 year-old and 18 year old whose Team meeting took place following the training. North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 9 of 13 North Attleborough Public Schools 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 ) ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE SelfAssessment ELE 1 Annual Assessment ELE 2 MCAS Participation ELE 3 Initial Identification ELE 4 Waiver Procedures Not all teachers providing content instruction to limited English proficient students have received training in sheltered English instruction. ELE 5 Program Placement and Structure ELE 6 Program Exit and Readiness Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 10 of 13 Required Corrective Action, Timelines for Implementation, and Progress Reporting By April 1, 2007 provide a list of teachers who are providing instruction to LEP students along with the date that training in SEI was or will be completed. ELE Criterion Number and Topic ELE 7 Parent Involvement ELE 8 Declining Entry to a Program Criterion Determined to be Implemented Based on Review of Local ELE SelfAssessment ELE 9 Instructional Grouping ELE 10 Parental Notification ELE 11 Equal Access to Academic Programs and Services ELE 12 Equal Access to Nonacademic and Extracurricular Programs ELE 13 Follow-up Support Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 11 of 13 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 SelfAssessment 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 14 Licensure Requirements LEP students are not all receiving English as a second language instruction by a licensed ESL teacher. By April 1, 2007, provide an explanation of how the district will ensure that all LEP students receive English as a second language instruction by a qualified teacher. ELE 15 Professional Development Requirements Not all teachers of LEP students have had training in sheltered English instruction. Please see ELE 5. ELE 16 Equitable Facilities ELE 17 Program Evaluation ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) Mid-cycle Report Format 2007.doc Rev. 1/3/07 North Attleborough Coordinated Program Review Mid-cycle Report January 30, 2007 Page 12 of 13