350 Main Street, Malden, Massachusetts 02148-5023 Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
August 6, 2007
William Cooper, Superintendent
Old Rochester Regional School District
135 Marion Road
Mattapoisett, MA 02739
Re: Mid-cycle Coordinated Program Review Report
Dear Superintendent Cooper:
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 or ordered by the Department to address findings of noncompliance included in the Old Rochester Regional School District
Coordinated Program Review Report issued on June 8, 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 781-
338-3534. 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 Old Rochester Regional School District. These programs and practices are as follows:
Documentation, staff interviews, and student records indicated that the district supports a strong commitment to educating students in the least restrictive environment – i.e., the full inclusion model with supports in the classroom and the team teaching approach at the
1
high school and junior high school.
Documentation and student records indicated that the district consistently develops highly individualized Individual Education Plans (“IEPs”) for the students eligible for special education services.
Documentation and staff interviews indicated that the district’s use of weekly Resource
Study Team meetings enables the district to monitor and discuss the special education programs for the students.
Staff interviews indicated that the district practice of common planning time for staff opens the opportunity for the staff members to communicate and work cooperatively for the benefit of the students.
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 2009-2010 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 district within the timelines specified. You must submit your statement of assurance to me by August 23, 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 781-338-3739.
Sincerely,
John Coleman Swanson, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education
Robert Nectow, School Committee Chair, 135 Marion Rd., Mattapoisett, MA 02739
Theresa Hamm, District Program Review Follow-up Coordinator
Encl.: Mid-cycle Coordinated Program Review Report
2
Old Rochester Regional School District
ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS
Date of Coordinated Program Review (CPR): February 23-27, 2004
Date of Coordinated Program Review Corrective Action Plan Approval: July 26, 2004
Dates of Corrective Action Plan Progress Reports: January 5, 2005, March 2, 2005, December 12, 2005, and June 15, 2006
Dates of this Mid-cycle Review Onsite Visit: May 14-15, 2007
Date of this Report: August 6, 2007
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
Criterion
Number/Topic
(Refer to full text of 2006-
2007 CPR requirements)
Approved
Corrective
Action
Implemented and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Special Ed.
Criteria Cited in CPR Report and Monitored in Mid-cycle
SE 9
Timeline for determination of eligibility and provision of documentation to parent
SE 13
Progress
Reports and content
Partial
Documentation
Review, Student
Record Review, and Staff
Interviews
Based on the documentation review, staff interviews, and record review, the 45day timelines for the determination of eligibility were consistently adhered to.
Student Record
Review and Staff
Interviews
Student records and interviews indicated that the district does issue progress reports on the frequency as required by state and federal regulations, however, not all of the progress reports were filed in the student records. The content of the progress reports contained written information on the student’s progress toward the annual goals of the IEP. The progress reports were also consistently signed and dated by the individuals providing the
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
Partial Based on the student records, not all of the student files contained all of the progress reports.
Furthermore, not all of the
IEP goals were addressed in the progress reports that were filed in the student records.
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
By November 1, 2007 , please provide as evidence of training on progress reporting the following: signed attendance sheets, a copy of the materials distributed, the date(s) of the training, and the name of the presenter.
The district must develop a plan for local monitoring of progress reports. By March 1, 2008, identify by role, the person(s) responsible for conducting the internal monitoring at each
Criterion
Number/Topic
(Refer to full text of 2006-
2007 CPR requirements)
SE 18B
Determination of placement; provision of
IEP to parent
Approved
Corrective
Action
Implemented and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action Not
Implemented or Not
Effective or
New Issues
Identified
Basis of Determination that Implementation of
Corrective Action was
Incomplete or
Ineffective or
Basis of Finding of New
Noncompliance
Documentation
Review, Student
Record Review, and Staff
Interviews mandated special education services.
*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
.
Documentation, student records, and staff interviews indicated that the district places a strong emphasis on educating students with disabilities in the least restrict environment. The district offers a variety of service delivery models, including but not limited to, full inclusion with supports in the classroom and a team teaching approach in both the junior high school and high school.
*Please note that the Department has recently changed the implementation requirements for providing an IEP “immediately”
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
Required Corrective Action,
Timelines for
Implementation, and Progress Reporting building in the district.
Provide the Department with the results of monitoring activities, including: the number of records reviewed and the rate of compliance, along with a description of any additional steps taken by the district if noncompliance was identified by local personnel.
Criterion
Number/Topic
(Refer to full text of 2006-
2007 CPR requirements)
Approved
Corrective
Action
Implemented and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective following its development in a
Team meeting. Refer to the “best practice guidance” memo on the
Department’s Special Education website at http://www.doe.mass.edu/news/ne ws.asp?id=3182
Please review the new guidance for the “immediately” standard with appropriate staff. No additional progress report required.
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
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
Criterion
Number and
Topic
Special
Education
Criteria created or revised in response to
IDEA-2004
SE 6 ##1 - 3
Determination of Transition
Services
Criterion
Implemented
Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Criterion
Partially
Implemented or Not
Implemented
Basis of Determination that Criterion was
Partially Implemented or Not Implemented
Documentation
Review,
Student Record
Review, and
Staff Interviews
Documentation, student records, and staff interviews indicated that the district consistently discussed transition services at Team meetings, the district consistently invited the student to attend the
Team meetings, and the district consistently incorporated the student’s preferences and interests into the student’s IEP. The district was also active involving outside agencies, such as DMR and DMH, with IEP Team meetings.
* Please note that consistent with the recently enacted IDEA-2004 regulations, the transition planning chart has become a mandated form, which should be maintained with the student’s IEP. Refer to
Administrative Advisory SPED
2007-1 for guidance. The
Department has revised this form; please check the Department’s
Special Education website at http://www.doe.mass.edu/news/ne ws.asp?id=3295..
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
SE 8
IEP Team composition and attendance
SE 12
Frequency of re-evaluation
SE 13
Progress
Reports and content
Partial
Documentation
Review,
Student Record
Review, and
Staff Interviews
Documentation
Review,
Student Record
Review, and
Staff Interviews
Student Record
Review and
Staff Interviews
Please review the new requirements for transition planning and services with appropriate staff. No additional progress report is required.
Documentation, student records, and staff interviews indicated the following: (1) the district consistently held meetings with all the required members attending; (2) the district’s Team chairs have the authority to commit district resources; (3) the district used multiple methods to ensure parental participation (i.e., teleconferences or rescheduling); and (4) the district used the proper procedures to excuse Team members.
Documentation and student records indicated that the re-evaluations are conducted every three years. Also, the district’s IEP Teams consistently conduct re-evaluations before removing special education services for eligible students.
See above.
Partial
See above. See above.
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
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
Criterion
Implemented
Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Documentation
Review,
Student Record
Review, and
Staff Interviews
Documentation
Review,
Student Record
Review, and
Staff Interviews
Documentation
Review,
Student Record
Review, and
Staff Interviews
Documentation
Review,
Student Record
Review, and
Staff Interviews
Documentation, student records, and staff interviews indicated that the district’s IEP Teams were consistently reviewing and revising student IEPs within the specified one-year timeline.
The district has procedures established to enable the district to reach a settlement with a parent or guardian prior to it reaching the level of going to the BSEA for a hearing. The district also submitted evidence of recent settlement agreements.
Based on the documentation review, interviews, and record review, a student’s involvement and progress in the general curriculum is measured, discussed among the IEP Team members, and noted on each IEP.
Based on the documentation review, interviews, and record review, students in private schools whose parents reside in district are given evaluations and, if found eligible, they may access a full range of special education and related services. The district has
Criterion
Determined to be
Partially
Implemented or Not
Implemented
Basis of Determination that Criterion was
Partially Implemented or Not Implemented
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
district
SE 39B
Procedures for services to eligible students in private schools in the district whose parents reside out of state
SE 46
Procedures for suspension of students with disabilities more than 10 days
Documentation
Review and
Staff Interviews
Documentation
Review and
Staff Interviews documented the proportionate share, and has budgeted that amount of money for the private school students.
Please note that consistent with recently enacted IDEA-2004 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.
Documentation review and staff interviews indicated that students in private schools whose parents reside out of state have the opportunity to access special education services. However, despite extensive outreach efforts by the district, no out-of-state students have contacted the district for any evaluations or services.
The district will continue its outreach efforts, as required by law.
Based on the documentation review and staff interviews, the district’s codes of conduct contain all required elements for the discipline of special education students.
Also, the district does an excellent job in tracking the numbers of suspensions for special education students and conducting risk assessments in a timely manner to ensure that students are not out of school longer than necessary.
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
Old Rochester Regional School District
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
ELE 1
Annual
Assessment
ELE 2
MCAS
Participation
ELE 3
Initial
Identification
Criterion
Determined to be
Implemented
Based on Review of Local ELE
Self-Assessment
Partial
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
Documentation and staff interviews indicate that the district does not utilize an assessment instrument beyond the MEPA, MELA-O, and
MCAS to assess the level of English proficiency for identifying LEP students.
The district does not have a formal assessment tool to measure the level of English proficiency – the district utilizes informal methods by teachers and speech and language service
By November 1, 2007 , please provide a copy of the district’s home language survey (English and other major languages of the community), a description of the assessments used to determine
English language proficiency in all four modalities of reading, writing, speaking, and listening, and a list of qualified staff (name, title, and role) to implement identification procedures.
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
ELE
Criterion
Number and
Topic
ELE 4
Waiver
Procedures
ELE 5
Program
Placement and Structure
Criterion
Determined to be
Implemented
Based on Review of Local ELE
Self-Assessment
Partial
Partial
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 providers. Also, the district’s home language survey was provided only in English.
Documentation and staff interviews indicated that the district has not developed or implemented a waiver procedure.
Documentation and staff interviews indicated that the district does not have classroom teachers trained in Sheltered English Instruction
(“SEI”) – although, plans are in place to have teachers enrolled in SEI training over the summer. Students are not receiving English as a
Second Language (“ESL”) instruction from ESL-certified teachers but are receiving ESL instruction from reading teachers and/or from the
Rosetta Stone program.
By November 1, 2007 , please provide a copy of a notice that informs parent(s) of their right to apply for a waiver that includes all of the required elements.
By November 1, 2007 , please 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. Provide the name of the teacher who is providing English as a second language instruction to LEP students as well as a copy of the teacher’s license or waiver.
ELE 6
Program Exit and
Readiness
ELE 7
Parent
Involvement
Partial Documentation indicated that the district did not develop procedures to communicate with parents whose primary language is not English.
By November 1, 2007 , please provide a copy of procedures in place to provide notices or interpreters for parents who do not speak English in a language they can understand. Provide a copy of those procedures as well as a sample of a translated school documents from each school where there are LEP students or parents in each language that the document has been translated.
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
ELE
Criterion
Number and
Topic
ELE 8
Declining
Entry to a
Program
ELE 9
Instructional
Grouping
ELE 10
Parental
Notification
Criterion
Determined to be
Implemented
Based on Review of Local ELE
Self-Assessment
Partial
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
Documentation and staff interviews indicated that the district did not develop policies and procedures for LEP students whose parents have declined entry to a program based upon the requirements of this criterion.
By November 1, 2007 , please provide a copy of policies, procedures, and an implementation plan for providing supports to LEP students whose parents decline entry into an ELE program.
Partial Documentation and staff interviews indicated that the district did not develop procedures to translate materials for parents who do not speak
English at home. Also, the parent notification letter did not contain the following components of this criterion: (a) the reasons for identification of the student as LEP; (b) the child’s level of English proficiency; (c) program placement and/or the method of instruction used in the program; and (g) the parents’ right to apply for a waiver, or to decline to enroll their child in the program.
By November 1, 2007, please provide a copy of procedures to translate materials for parents who do not speak English and a revised copy of its parental notification letter that contains all of the required components of this criterion.
ELE 11
Equal Access to Academic
Programs and Services
ELE 12
Equal Access to
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
ELE
Criterion
Number and
Topic
Nonacademic and
Extracurricular
Programs
ELE 13
Follow-up
Support
ELE 14
Licensure
Requirements
Criterion
Determined to be
Implemented
Based on Review of Local ELE
Self-Assessment
Partial
Partial
Findings of Noncompliance Based on Department’s
Review of Local ELE Self-Assessment
(Criterion Determined to be Partially Implemented or Not
Implemented)
Documentation and staff interviews indicated that the district did not develop a monitoring instrument for Formerly Limited English
Proficient (“FLEP”) students who have exited the ELE program.
Also, the district did not describe who would be conducting the monitoring of FLEP students who have exited the ELE program.
See ELE 5
Required Corrective Action,
Timelines for Implementation, and Progress Reporting
By November 1, 2007 , please provide a copy of the district’s monitoring and follow-up procedures to provide support for students who have exited the
ELE program.
See ELE 5
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007
ELE
Criterion
Number and
Topic
ELE 15
Professional
Development
Requirements
ELE 16
Equitable
Facilities
ELE 17
Program
Evaluation
ELE 18
Records of
LEP
Students-
(To be reviewed during next
CPR visit.)
Criterion
Determined to be
Implemented
Based on Review of Local ELE
Self-Assessment
Partial See ELE 5
Findings of Noncompliance Based on Department’s
Review of Local ELE Self-Assessment
(Criterion Determined to be Partially Implemented or Not
Implemented)
Partial
See ELE 5
Required Corrective Action,
Timelines for Implementation, and Progress Reporting
Documentation and staff interviews indicated that the district does not have a formal procedure to periodically evaluate the effectiveness of its ELE program.
By November 1, 2007, please provide a copy of the district’s proposal for evaluating the effectiveness of its ELE program.
Old Rochester Regional School District Coordinated Program Review Mid-cycle Report
August 6, 2007