The Commonwealth of Massachusetts Department of Education 350 Main Street, Malden, Massachusetts 02148-5023 Telephone: (781) 338- 3000 November 8, 2005 James J. Brosnan Superintendent of Schools Northern Berkshire Vocational Regional School District 70 Hodges Cross Road North Adams, MA 01247 Re: Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action Plan Verification and Special Education Mid-cycle Review Dear Superintendent Brosnan: 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 July 24, 2002. . We are pleased to indicate that the Department of Education has found your district's approved Corrective Action Plan to be substantially implemented and effective in remedying previously identified noncompliance issues in the area of special education. The findings of the Department are included in the attached Follow-up Monitoring Report. You and your entire staff are to be congratulated for your efforts in implementing all necessary improvements. While the Department of Education found all special education noncompliance issues to be resolved, noncompliance issues in the area of Title I were partially corrected, not addressed at all and/or new issues were identified by the Department’s onsite team. As the Department previously informed you, in cases where a district fails to fully and effectively implement a Corrective Action Plan, which was proposed by your district and approved by the Department, the Department must then prepare a Corrective Action Plan for the district, which must be implemented without further delay. You will find these requirements for corrective action and further progress reporting included in the attached report together with any steps that must be taken by the district to fully implement new special education requirements. Please provide the Department with your written assurance that 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 Department's Onsite Chairperson by November 21, 2005. 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 2008-2009 academic year, unless the Department determines that there is some reason to schedule this visit earlier. 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 413-284-0382. Sincerely, Sandra K. Hanig, 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 Daniel Maloney, School Committee Chairperson Mary Lou Accetta, District Program Review Follow-up Coordinator Encl.: Follow-up Monitoring Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION COORDINATED PROGRAM REVIEW Northern Berkshire Vocational Regional School District / McCann Technical School ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Action Plan Submitted on October 9, 2002 Progress Reports Submitted on December 2, 2002, February 8, 2003 and October 31, 2003 Onsite Visits Conducted on March 18, 2003, December 9, 2003, October 31, 2004, March 21, 2005, and October 14, 2005 Date of this Report: November 8, 2005 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation OSEP Focus Areas - Special Education Requirements SE 3 Special requirements for √ Documentation Statutory requirements for the determination of specific learning disabilities have been 3 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) determination of specific learning disabilities Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation revised under the recently reauthorized IDEA 2004. Therefore, until final implementing regulations have been adopted, the Department is not making findings related to school district practices under Coordinated Program Review Criterion SE 3. For districts seeking to resolve a previous finding in this area, the Department will extend the date required for final actions on the part of the school district to June 2006 and will consider resolution at any time following promulgation of final federal regulations. The district submitted evidence that it has provided training on the topic of specific learning disabilities. The district submitted evidence 4 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation of its internal investigation of student records to monitor compliance with this criterion. 5 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) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation √ Documentation, interview, student record The district submitted a copy of guidelines for determining transition services. The district also submitted a list of participating co-op students and placements and evidence that it is meeting on an on-going basis with Mass Rehab to identify students who will need services after graduation. Review of student records and interviews indicate that transition considerations are a big focus of this vocational technical school. The need for a 688 referral is documented under “Additional Information” on each IEP. SE 13 Progress Reports and content √ Documentation, interview, student record On March 21, 2005, the district submitted a sign-in sheet and a follow-up summary memo, along with copies of actual student 6 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation progress reports that were critiqued with staff members as part of staff training on writing quality progress reports. The concern at the time of the 2002 Coordinated Program Review is that progress reports were written by the Director of Special Education instead of the teachers who provide direct services. Student record review in October 2005 indicates that progress reports are typed without the author’s signature. Interviews indicate that special education teachers write progress reports. 7 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 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation √ Student record review and interviews Northern Berkshire Vocational Regional School District serves students in grades 9-12 exclusively. Not applicable √ This criterion was implemented at the time of the program review. Student record review and interviews indicate that this criterion continues to be implemented. Documentation, interview, student record Concern at the time of the Coordinated Program Review in March 2002 was that IEPs were “boilerplate” and not written to meet the individual needs of each special education student. In March 2005, the district 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) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation submitted evidence that it has held staff trainings on the development on content of IEPs. Review of student records in October 2005 indicate that IEPs are now written to address the individual needs of each student. 9 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 18B Determination of placement; immediate provision of IEP to parent Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation √ Interview, Student record, documentation The concern at the time of the Coordinated Program Review in 2002 was that the IEP was poorly written and appropriate placement could not be determined. Documentation submitted in March 2005 and student record review in October 2005 indicate that the district has developed a continuum of services and delivery models that allows for appropriate student placement to meet IEP goals. The district piloted a program of collaborative teaching in an English and math class. The special education department works with general education teachers to ensure that classroom modifications and accommodations are implemented for inclusive 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) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation placements. A special education teacher supports students in vocational classes. Some students receive services in a resource room placement. The district’s report on the number of students who now receive special education services in a less restrictive environment indicates the success of these additional placement options. 11 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 20 Least restrictive program selected Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation √ Student record, documentation, interview The concern at the time of the 2002 Coordinated Program Review was that special education students had only one placement option, removal from the classroom and placement in a study skills class. See comment under SE 18B regarding the district’s efforts to establish less restrictive special education programs and practices. Student record review in October 2005 indicates that the justification for removal from general education is documented on student IEPs. SE 22 IEP implementation and √ Documentation, interview The concern at the time of the 2002 Coordinated Program Review was that general 12 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) 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation education teachers were not implementing IEP accommodations and modifications. In March 2005, the district submitted evidence that it has held professional development for all staff on the requirement to fully implement IEPs, with an emphasis on the requirement for general educators to carry out accommodations and modifications. Staff members have been given summaries of IEP information for every student who has an IEP. The district reports that the principal/director, assistant director and director of student services observe classrooms to ensure accommodations and modifications are being carried out. Services delivery grids and 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation progress reports are reviewed biyearly. 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) SE 26 Parent participation in meetings (Emphasis on district’s attempts to ensure parent participation at IEP Team meetings) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation √ Documentation, interview, student record The concern at the time of the 2002 Coordinated Program Review was that, if the parent did not attend the IEP Team meeting, the district had not documented multiple attempts to ensure that the parent attend the meeting or have input into the development of the IEP. In March 2005, the district submitted a copy of the parent/guardian communication log it has developed. The district reviews data each quarter about the number of parents/guardians attending IEP Team meetings. For the quarter preceding this Midcycle review, the district had 100% parent participation at IEP Team meetings. A sample of student records was reviewed in October 2005. Each 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation had a parent in attendance at the IEP Team meeting. 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 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 28 Parent provided the IEP or notice of no eligibility together with notification of procedural safeguards and parents' rights Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation √ Student record, interview The concern at the time of the 2002 Coordinated Program Review was that parents were not handed a summary of agreed upon IEP services at the conclusion of the IEP Team meeting. Student record review in October 2005 indicates that parents are provided either a cover letter with the IEP explaining why the district was proposing the IEP or a letter notifying parents that the student is not eligible for special education and a copy of the parents’ rights brochure. Interview indicates that the district gives parents a handwritten copy of the proposed IEP at the conclusion of the IEP Team meeting. 17 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 29 Communications 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation √ Documentation, interview The concern at the time of the 2002 Coordinated Program Review was that, although the district did not have any enrolled students or their parents who required translations, the district had no policy to provide these services if a student or parent should require them. In October 2005 the district submitted a copy of its policy on providing translations, if required. SE 32 Parent advisory council for special education √ Documentation The concern at the time of the 2002 Coordinated Program Review was that the district had hosted only one Special Education Parent Advisory Council meeting. On March 21, 2005, the district submitted copies of invitations to 18 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation several PAC meetings held from September 2003 – May 2005 along with agendas and sign-in sheets for these PAC meetings. 19 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 50 Responsibilities of the School Principal and Administrator of Special Education Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation √ Documentation, interviews The concern at the time of the 2002 Coordinated Program Review was that the district had no Curriculum Accommodation Plan and interviews indicated there was no coordination of services between the Principal and the Director of Special Education. In March 2005, the district submitted a copy of its Curriculum Accommodation Plan, which includes a description of services available to limited English proficient students and job descriptions of Principals and Administrator of Special Education. The district also submitted a description of local implementation practices for the provision of home or hospital 20 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation services and “Home Hospital Guidance.” 21 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 54 Professional development regarding special education Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation √ Documentation, interview The concern at the time of the 2002 Coordinated Program Review was that the district did not provide its staff with required trainings. In March 2005, the district submitted a staff training calendar that gives evidence of on-going staff training in the area of special education for the 2003 – 2004 and 2004 – 2005 academic years. SE 56 Special education programs and services are evaluated √ Documentation, interview The concern at the time of the 2002 Coordinated Program Review was that there was no evidence that the district evaluates its special education programs. In October 2005, the district submitted a description of what 22 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance data is used to evaluate its special education programs, who is involved in analyzing data and examples of changes that have been made to the special education program as a result of the district’s evaluation of its programs. Additional criteria not fully implemented at time of 2001 – 2002 Coordinated Program Review – Special Education Requirements SE 1 Assessments appropriately selected and interpreted √ Documentation, student record, interview The concern at the time of the 2002 Coordinated Program Review was that the district relied too heavily on one assessment to determine special education eligibility. In March 2005 the district submitted evidence of ongoing professional development in the area of appropriate assessment selection and interpretation. 23 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation The district submitted evidence of its internal investigation of student records to monitor compliance with this criterion. Review of student records in October 2005 indicated that the district is now using a variety of instruments to assess students in all areas of suspected disability. SE 2 Required and optional assessments √ Documentation, student record, interview The concern at the time of the 2002 Coordinated Program Review was that the district did not appropriately select or conduct assessments. In March 2005 the district submitted evidence that it has researched and evaluated assessment options, purchased assessment tools and attended professional development in the area of assessment. 24 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation Review of student records in October 2005 indicated that the district is now using a variety of instruments to assess students in all areas of suspected disability. SE 4 Assessment results √ Documentation, student record The concern at the time of the 2002 Coordinated Program review was that assessment results did not provide a detailed, educationally relevant definition of the student’s needs and explicit means to meet those needs. In March 2005, the district submitted copies of sample assessment summaries and its revised handbook, “Team Evaluation Process.” The district submitted evidence of its internal investigation of student records to monitor 25 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation compliance with this criterion. Review of student records in October 2005 indicated that assessment summaries are now conducted by a number of qualified consultants who provide a range of expertise to better address the individual needs of students. Interviews indicate that the specialist conducting tests meets with general education, special education and vocational teachers to ensure that assessment results information is understood by all staff members. SE 8 IEP Team composition √ Documentation, student records The concern at the time of the 2002 Coordinated Program Review was that general education teachers did not attend 26 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation IEP Team meetings. In March 2005 the district submitted evidence that it has hired a substitute teacher to ensure that general education and shop teachers attend IEP Team meetings. The district submitted evidence of its internal investigation of student records to monitor compliance with this criterion. Student records indicate that all required members are in attendance at IEP meetings. SE 9 Eligibility √ Documentation, interview, student record The concern at the time of the 2002 Coordinated Program Review was that the district did not use required DOE forms and because of this the DOE was not 27 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation able to determine whether the district met required timelines to evaluate students and hold IEP Team meetings. Student record review in October 2005 indicates that the district is meeting timelines for conducting evaluations and holding IEP Team meetings. The district reports that staff members have been trained in a new process for re-evaluations. Ongoing training on this topic consists of feedback sessions after three-year re-evaluation Team meetings. SE 12 Re-evaluations √ Student record The concern at the time of the 2005 Coordinated Program Review was that the district was not conducting 3-yr reevaluations. 28 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation Student record review in October 2005 indicates that three year reevaluations are conducted within required timelines. SE 24 Notice to parent √ Documentation, student record The concern at the time of the 2002 Coordinated Program Review was that the district was not sending out any required notices to parents. In March 2005, the district submitted copies of handouts and memos to staff members regarding staff training on FAPE and parental consent regarding functional behavioral assessment and manifestation determinations. Student record review in October 2005 indicates that the district is now sending out required notices to parents. 29 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 25 Parental consent Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation √ Documentation, student record The concern at the time of the 2002 Coordinated Program Review was that the district was not sending out required consent forms. Student record review in October 2005 indicates that the district is not obtaining required parental consent using DOE recommended forms. In March 2005, the district submitted copies of handouts and memos to staff members regarding staff training on FAPE and parental consent. SE 33 Involvement in general curriculum √ Documentation, interview, student record The concern at the time of the 2002 Coordinated Program Review was that there was no thoughtful discussion at IEP 30 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation Team meetings of how students will participate in the general curriculum with the necessary accommodations and modifications. In March 2005, the district submitted copies of textbooks, technology and equipment it has purchased to accommodate special education students in the classroom. The district also reports that it increased opportunities for mutual planning time and cooperative teaching between general and special education staff members. Student record review indicates that the district is recording necessary accommodations and modifications in IEPs. 31 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 34 Continuum of alternate services and placements Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation √ Documentation, interview, student records See comment under SE 20 regarding continuum of alternate services and placements. In March 2005, the district submitted evidence that it has increased its provision of related services and reports that it is creating an expanded list of resources to provide services. The district has hired a Spanish teacher who is qualified to provide LEP services if needed, under the supervision of a contracted LEP coordinator, a highly qualified speech and language assistant who is supervised by a consulting Speech and Language Pathologist, a consultant from the Willie Ross School for the Deaf. The district has also expanded its 32 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation contracts for psychological testing, counseling and consultation. SE 35 Materials and Technology √ Documentation The concern at the time of the 2002 Coordinated Program Review was that assistive technology needs are not discussed at IEP Team meetings. The district submitted evidence that it has purchased materials and technology and has trained staff on its use. Review of student records indicate that the need for assistive technology is documented on the IEP. SE 36 IEP √ Documentation review, The concern at the time of the 2002 Coordinated Program Review was that the district did 33 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation implementation interview not have a process to monitor whether staff members are carrying out required IEP services. See comment under SE 22. The district has also developed a notebook of IEP summaries that teachers are required to sign and date to indicate that they have read the IEPs of students assigned to their classes. SE 43 Behavioral interventions √ Documentation, interview The concern at the time of the 2002 Coordinated Program Review was that the district did not have policies or procedures to consider a student’s behavior, positive behavior reinforcements or the ability to follow the discipline code. In March 2005, the district submitted a copy of its 34 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation suspension log and indicated students with a disability who have been suspended. The district also submitted a copy of a student behavior plan with positive behavior supports. The district reports that its review of data shows that the use of in-school suspension had little long-term positive effect on student behavior or benefit for student. In response to this data, the district has trained all staff on positive behavior interventions. These workshops by a school psychologist and ongoing use of preventive discipline by staff members have reduced behavioral incidents. SE 44 Recording suspensions √ Documentation The concern at the time of the Coordinated Program Review in 2002 was that the district had no 35 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation procedures for recording suspensions. In March 2005 the district submitted a copy of its suspension log and indicated students with a disability who have been suspended to give evidence that it is following its procedure to record suspensions of students with disabilities. SE 45 Suspensions of 10 days – general procedures √ Documentation, interviews The concern at the time of the 2002 Coordinated Program Review was that the district had no policy describing the district’s process when students are suspended more than 10 days. In March 2005 the district submitted a copy of its policies on suspension that were reviewed and finalized for the Special Education Handbook. Interviews indicate that these policies are 36 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Comments Regarding Corrective Action Plan Implementation being consistently implemented. SE 46 Suspension of 10 days – district responsibilities √ SE 52 Credentials of related services staff √ Documents, interview See comment under SE 46. In October 2005 the district submitted a copy of receipts for a certified special education tutor it provided to special education students who reached more than 10 days of suspension. One student was tutored at home. The other student was tutored at the school building after regular school hours. Documentation, student record, interview The concern at the time of the 2002 Coordinated Program Review was that the district provided virtually no related services to students; only one student received physical therapy. 37 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 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 district submitted a copy of the DOE license for its school psychologist. Student record review indicated that the district is recording the need for related services on IEPs. Additional criteria not fully implemented at time of 2001 – 2002 Coordinated Program Review – Title I Requirements TI 5 Criteria to identify eligible students √ The district submitted student selection criteria but no evidence of rank ordering. Submit rank-order lists of participating students by subject and grade level. Please assign points to the objective academic criteria (teacher recommendation list). Submit this documentation to the Department of Education by January 15, 2006. TI 7 √ 38 The district submitted a Submit documentation of policies 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 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 Developing criteria in consultation corrective action plan with no evidence of implementation. and procedures that show an implementation of the Corrective Action Plan. Submit rank-order lists of participating students by subject and grade level. Please assign points to the objective academic criteria (teacher recommendation list). Submit this documentation to the Department of Education by January 15, 2006. TI 9 Identifying eligible special education students √ 39 The Corrective Action Plan ordered has not been implemented. Submit student selection criteria sheets and policy for selection processes that ensures equal opportunity for participation in the Title 1 program and in accordance with supplement not supplant provisions. 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 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 Submit rank-order lists of participating students by subject and grade level. Please assign points to the objective academic criteria (teacher recommendation list). Submit this documentation to the Department of Education by January 15, 2006. TI 10 Parent involvement in planning and review √ The Corrective Action Plan ordered has not been implemented. Submit a plan and process for developing parent involvement policies and procedures with parental input into program planning, implementation, and review. Submit this documentation to the Department of Education by January 15, 2006. 40 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 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 √ TI 11A Training for parents The Corrective Action Plan ordered has not been implemented. Submit a plan that specifies parent involvement training activities, a means to verify their occurrence. Submit this documentation to the Department of Education by January 15, 2006. TI 12 Curriculum frameworks √ The Corrective Action Plan ordered has not been implemented. Submit a corrective action plan that shows the development of a procedure to assess Title 1 student progress and a means to report progress to parents. Submit this documentation to the Department of Education by January 15, 2006. 41