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
July 14, 2005
Paul Burnim, Superintendent
Orange Public Schools
131 West Main Street
Orange, MA 01364-
Re: Onsite Follow-up Monitoring Report: Coordinated
Program Review Corrective Action Plan Verification and
Special Education Mid-cycle Review
Dear Superintendent Burnim:
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 June 19, 2001.
While the Department of Education found certain noncompliance issues to be resolved, others
were partially corrected, not addressed at all and/or new issues were identified by the
Department’s onsite team. In areas where the district has failed to implement fully its approved
Corrective Action Plan, the Department views these findings to be serious.
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 July
29, 2005 The district’s continuing failure to implement the required Corrective Action Plan
described in this report will result in recommendation to the Commissioner of Education the
withholding of state or federal funds and/or other enforcement action by the Department.
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 781-338-3760.
Sincerely,
Robin Haunton, 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
Richard Herk, School Committee Chairperson
Jay Conway, District Program Review Follow-up Coordinator
Encl.: Follow-up Monitoring Report
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
COORDINATED PROGRAM REVIEW
Orange Public Schools
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION
Action Plan Submitted on 8/31/01
Progress Reports Submitted on 12/24/01, 12/24/02
Onsite Visit Conducted on June 1-2, 2005
Date of this Report July 14, 2005
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
or
Fully
Implemen-ted
or Additional
Issues
Identified


Special
Education
Requirements
SE 3
Special
requirements
for
determination
of specific

Corrective
Action Plan
Determined
to be Not
Documentatio
n review and
interviews
Review of documentation and
interviews indicated that this
criterion is implemented.
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
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
or
Fully
Implemen-ted
or Additional
Issues
Identified


learning
disabilities
2
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
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
or
Fully
Implemen-ted
or Additional
Issues
Identified
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


NA (Orange serves elementary
school age students only)
SE 6
Determination
of transition
services
SE 8
Evaluation
Team
Composition
Interviews

Interviews indicated that
Team Chairpersons do not
feel that they have the
ability to commit district
resources during Team
meetings.
SE 13
Progress
Reports and
content
Record review
and interviews

Record review indicated
that progress reports do
not consistently address
whether the student will
achieve their goals by the
end of the IEP period.
Additionally, parents were
not informed of student
progress as often as
3
Submit to the Department,
by January 9, 2006, the list of
persons in the district who
have the authority to commit
district resources and the
ability to attend all Team
meetings. Submit
documentation that this
authority has been
communicated to those
involved.
The district must provide
training to all related staff on
writing special education
progress reports.
Submit a copy of the training
agenda and attendance list by
January 9, 2006.
Submit by June 5, 2006,
copies of 10 progress reports
selected from student records
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
or
Fully
Implemen-ted
or Additional
Issues
Identified
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


nondisabled students.
4
across all grade levels that
have been written since the
start of the 2005-2006 school
year.
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
or
Fully
Implemen-ted
or Additional
Issues
Identified
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting


SE 14
Annual review
team meeting
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

Record review
and interviews
SE 15
Outreach by the
School District
(Child Find)

Documentatio
n review and
interviews
Review of documentation and
interviews indicated that this
criterion is implemented.
SE 17
Initiation of
services at age
three and Early
Intervention
transition
procedures

Documentatio
n review and
interviews
Review of documentation and
interviews indicated that this
criterion is implemented.
Records indicated that the
district is not consistently
convening student Team
meetings in a timely
fashion. The meetings are
scheduled in advance, but
not far enough so as to
take into account
unplanned issues that may
arise, thus causing the
time lapse between IEP
anniversary dates.
Review of records
5
Submit to the Department,
by January 9, 2006, the
schedule for IEP Team
meetings including when the
meetings were actually held.
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
or
Fully
Implemen-ted
or Additional
Issues
Identified
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


SE 18A
IEP
development
and content
Record review
and interviews.

indicated several issues in
regards to student IEP’s:
IEP goals were not
consistently measurable.
Certain nonparticipation
justification sections were
vague, stating only that
the student was being
removed, but not
explaining why this was
occurring.
Not all accommodations
that were reflected in the
MCAS section of a
student’s IEP were
consistently reflected in
the IEP accommodation
section that addresses
effective student progress.
Certain IEP’s seemed not
to be clear regarding the
difference between
accommodations and
specially designed
instruction.
The district must provide
training to all related staff on
writing student IEP goals,
nonparticipation justification
statements, reflecting
accommodations throughout a
student’s IEP and clarifying the
differences between
accommodations and specially
designed instruction.
Submit a copy of the training
agenda and attendance list by
January 9, 2006.
Additionally, submit by June
5, 2006, copies of 10 IEP’s
selected from student records
across all grade levels that
have been written since the
start of the 2005-2006 school
year.
SE 18B
Record review

Record review indicated
Develop an internal data
6
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Determination
of placement;
immediate
provision of
IEP to parent
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
or
Fully
Implemen-ted
or Additional
Issues
Identified
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
that parents are not
consistently provided
student IEP’s immediately
following the Team
meetings. Additionally,
parents receive meeting
notes following Team
meetings, but these notes
do not specifically include
student goals or the types
and duration of the
services to be provided
(which is documented on
the service delivery grid).
tracking system that
monitors IEP Team meetings
and the provision of the
related IEP to the parent.
Submit by June 5, 2006, a
sample of the data for the
2005-2006 school year.
Additionally, submit 6
examples of Team meeting
notes given to parents at the
conclusion of the meeting.


and interviews
7
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
or
Fully
Implemen-ted
or Additional
Issues
Identified

Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting


Documentatio
n review and
interviews
Review of documentation and
interviews indicated that this
criterion is implemented.
SE 22
IEP
implementation
and availability
Record review
and interviews
Review of documentation
indicated that this criterion is
implemented.
SE 25
Parental
consent
Record review
and interviews
SE 20
Least restrictive
program
selected
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance


8
Record review and
interviews indicated that
the district makes a
concerted effort to obtain
parental signatures on
evaluation consent forms.
In some cases, they are
not able to obtain the
written consent or get a
verbal consent or do get a
consent way in advance of
when it is needed because
the parent is available at
the school at the time.
The district must continue
to use alternative methods
to obtain the actual
Submit to the department by
January 9 2005, a log that
documents the date and types
of attempts used to obtain
parental consents. Document
any referrals to BSEA.
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
or
Fully
Implemen-ted
or Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance


written parental consent
and document these
attempts. If the district
determines that the
parent’ failure or refusal
to provide consent will
result in a denial of FAPE
for a student, the district
must seek resolution
through BSEA.
9
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
or
Fully
Implemen-ted
or Additional
Issues
Identified
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


SE 26
Parent
participation in
meetings

Record review
and interviews
Review of documentation
indicated that this criterion is
implemented.
SE 28
Parent provided
the IEP or
notice of no
eligibility
together with
notification of
procedural
safeguards and
parents' rights

Record review
and interviews
Review of documentation
indicated that this criterion is
implemented.
SE 29
Communications are in
English and
primary
language of
home
Corrective
Action Plan
Determined
to be Not

Documentatio
n review and
interviews
10
At the time of the review,
the district did not have
any families requiring this
service. It is unclear if the
district would be able to
provide for a family who
may require verbal or
written translation.
Submit to the Department,
by January 9, 2006, a written
description of resources
available to the district that
are able to provide both
written and verbal
translation if needed. This
includes language translation
as well as Braille and sign
language interpretation.
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
SE 32
Parent Advisory
Council for
special
education
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
or
Fully
Implemen-ted
or Additional
Issues
Identified
Record review
and interviews
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Documentation review
and interviews indicated
that the district does not
consistently have
contracts or monitoring
plans with out-of-district
placements.
Submit to the Department,
by January 9, 2005,
6 contracts, monitoring
plans and monitoring reports
developed for out-of-district
placements during the 20052006 school year.
Review of documentation
indicated that this criterion is
implemented.

Record review
and interviews
SE 37
Procedures for
approved and
unapproved
out-of-district
placements
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance



Corrective
Action Plan
Determined
to be Not
SE 50
Responsibilities
of the School
Principal and
Administrator
of Special
Education

Record review
and interviews
Review of documentation
indicated that this criterion is
implemented.
SE 54
Professional
development
regarding
special

Record review
and interviews
Review of documentation
indicated that this criterion is
implemented.
11
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
or
Fully
Implemen-ted
or Additional
Issues
Identified


education
SE 56
Special
education
programs and
services are
evaluated

Corrective
Action Plan
Determined
to be Not
Record review
and interviews
Review of documentation
indicated that this criterion is
implemented.
Other
Requirements
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
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
or
Corrective
Action Plan
Determined
to be Not
Fully
Implemen-ted
or Additional
Issues
Identified
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
Currently, the district has
no limited-EnglishProficient Students. The
district did not provide
any examples of home
language surveys nor did
they document the
instruments to be used to
identify students.
Submit to the Department,
by January 9, 2006, examples
of home language surveys in
multiple languages.
Additionally, document how
staff will determine a
student’s level of English
proficiency and identify
appropriately trained staff
who may conduct
assessments.


MOA 1
Identification of
limitedEnglishProficient
Students
Documentatio
n review

MOA 2
Program
modifications
and support for
limitedEnglishProficient
Students
Documentatio
n review

13
Currently, the district has
no limited-EnglishProficient Students. It is
unclear if the district
would be able to provide
the necessary program
modifications and support
if a student requiring
these services enrolled in
the school.
Submit to the Department,
by January 9, 2006, a written
description of how the
district would modify
programming and provide
support for limited-EnglishProficient Students who may
enter the district in the
future. This description
should include how the
district will provide:
1. Assessment-using
MELA-O, MEPA
2. Provision of ContentSheltered English
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
or
Corrective
Action Plan
Determined
to be Not
Fully
Implemen-ted
or Additional
Issues
Identified
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


Immersion Instruction
3. Provision of English
Language InstructionESL
4. Instructional SupportsTitle 1, Tutoring,
Special Education
14
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
MOA 25
Institutional self
evaluation
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
or
Fully
Implemen-ted
or Additional
Issues
Identified
Record review
and interviews
TI 22
Materials and
training to
On site visit
and
documentation

Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Review of documentation
indicated that this criterion is
implemented.
TI 12
Time and Effort
reporting
TI 21
Evaluation of
the Parent
Involvement
Policy
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance



Corrective
Action Plan
Determined
to be Not
On site visit
and
documentation
Evidence of scheduled
meetings, workshops, 2nd step
programs, anger control
15

The Title 1 director needs
to provide an account of
time spent on Title 1
activities

The district has not
conducted an annual
evaluation of the parent
involvement policy with
input from parents.
Submit to the Department by
January 9, 2005, an account
of time spent on Title 1
activities by the director. Use
appropriate forms and refer
to the Mass. D.O.E website
www.mass.doe.edu, Title I
section.
Submit to the Department by
January 9 2005, a copy of the
annual evaluation of the
content and effectiveness of
the parental involvement
policy. Evidence should be
provided that parents had
the opportunity to be actively
involved in this process
Criterion
Number
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
improve student
achievement.
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
or
Corrective
Action Plan
Determined
to be Not
Fully
Implemen-ted
or Additional
Issues
Identified


workshops and behavioral
management sessions.
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
Implementation Status of
And Topic
Requirements
(Refer to full
text of
requirements in
2004-2005
Special
Education
Information
Package)
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation
or
Fully
Implemen-ted
or Additional
Issues
Identified
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 does not have
a formal evaluation but is
working on this for the
04-05 school year.
Submit to the Department by
January 9, 2005, a copy of
the formal evaluation.


TI 23
Parent
involvement
policy is
provided in the
home language

On site visit
District does not have ELL
children. The policies they
have are suitably written for
the school population.
TI 24
Minimizing the
removal of
students from
the classroom

On site visit
Every effort is made to
minimize pullout models but in
some cases this is the best
model to promote and enhance
student achievement.
TI 31
Professional
development

On site visit
Professional development
funds come from the regular
educational budget; the Title 1
PD budget is put into tutoring.
All paraprofessionals are now
highly qualified.
TI 32
Needs
assessment and
data analysis
Corrective
Action Plan
Determined
to be Not

On site visit
17
18