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 25, 2007 Dr. Gerald Fournier, Superintendent Converse Middle School 24 Converse Street Palmer, MA 01069-1770 Re: Mid-cycle Coordinated Program Review Report Dear Dr. Fournier: Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report (MidCycle Report). This report contains findings based on onsite monitoring conducted to verify the implementation and effectiveness of corrective action approved or ordered by the Department to address findings of noncompliance included in the Palmer School District Coordinated Program Review Report issued on September 24, 2004. The Mid-cycle Report also contains findings based on onsite monitoring of special education compliance criteria that have been created or substantially changed in response to IDEA 2004. Another component of the Department’s Mid-cycle Review is the review of your school district or charter school's self-assessment in the area of English learner education (ELE). (In the remainder of this letter, please read “district” as meaning “school district or charter school.”) The purpose of this review is to determine whether your district is implementing the significant changes in M.G.L. Chapter 71A, governing the education of limited English proficient students, that were adopted by voters by means of Question 2 in 2002. The Department has reviewed your district’s ELE self-assessment (documentation and any written analysis of compliance) and, based solely on that self-assessment, is providing you in this report with findings on your ELE program and the corresponding corrective action to be implemented. Your district is urged to request technical assistance in relation to any of these findings or this prescribed corrective action from me or from staff in the Department’s Office of Language Acquisition and Achievement at 781338-3534. ELE guidance documents are available on the Department’s website at http://www.doe.mass.edu/ell/. 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 1 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 3, 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 413-858-4591. Sincerely, Nicole E. Heroux, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Mary A. Salzmann, Chairperson of School Committee Neil Metcalf, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report Mid-cycle Cover Letter 2007.doc Rev. 11/14/06 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT Palmer Public Schools ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS Date of Coordinated Program Review (CPR): September 24, 2004 Date of Coordinated Program Review Corrective Action Plan Approval: March 30, 2005 Dates of Corrective Action Plan Progress Reports: 6/05, 1/06, 6/06, 12/06 Dates of this Mid-cycle Review Onsite Visit: April 23, 26, 27, 2007 Date of this Report: July 25, 2007 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 1 of 22 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Special Ed. Criteria Cited in CPR Report and Monitored in Mid-cycle MOA 4 Disproportionality (if Cited in the CPR Report) SE1 Student record review, documentation and interviews The district has provided evidence of communications and the professional development plan for regular and special education teachers, along with names of service providers on this topic. SE2 Student record review, documentation and interviews The district provided a sample of educational assessments conducted by the classroom teacher and Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 2 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance samples of educational assessments and observations of interactions in the student’s natural environment or early intervention program. SE3 Statutory requirements for the determination of specific learning disabilities have been revised under the recently reauthorized IDEA 2004. Therefore, 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 and will consider resolution following the issuance by MA DOE of guidance regarding the implementation of related federal regulations. Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 3 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified SE4 Student record review, documentation and interviews The district submitted information on what type of assessments were provided for these students, along with the dates that these assessments were administered to the selected students. SE8 Student record review, documentation and interviews The district submitted the names and titles of the personnel in the district that are able to commit district resources at Team meetings. The district also submitted signed attendance sheets from Team meetings to demonstrate that required persons are in attendance at the Team meetings. SE9 Student record review, documentation and interviews The district submitted tracking forms and/or copies of parent consent forms and dated IEPs to demonstrate compliance with this criterion. Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 4 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified SE15 Student record review, documentation and interviews The district submitted copies of its fliers and announcements informing the community of its outreach. The district also provided copies of its distribution list and schedule of when it conducts outreach within the community. SE17 Student record review, documentation and interviews The district provided evidence of communications that it has had with local area providers to encourage referrals of students for Early Childhood services at the age of 2 and 2 1/2. SE18A Student record review, documentation and interviews The district submitted signed attendance sheets from Team meetings to demonstrate that required persons are in attendance at the Team meetings. Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 5 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance The district submitted copies of the letters that it has sent to the independent contractors informing them of the eight -week timeline limitation, which was the issue previously identified as creating the timeline delay. SE19 SE20 Student record review, documentation and interviews The district provided documentation to establish that there are child study teams in every school in the district with a formalized process for assessing situations within the general education classroom. SE22 Student record review, documentation and interviews The district submitted copies of student summary sheets that have been provided to all the students’ teachers informing them of their specific responsibility as it relates to the implementation of the students’ IEPs. Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 6 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified SE23 Student record review, documentation and interviews The district currently uses E SPED for student records, along with student records in which anyone looking for access must sign a log of access. SE24 Student record review, documentation and interviews The district submitted signed consent (N1A) forms, along with the N3 and N3a forms, demonstrating that the referrals made directly to the Special Education office are being processed, and the evaluation procedures are being initiated within the required timelines. SE26 Student record review and documentation The district submitted notification that is sent to the parents regarding parent participation in Team meetings. SE28 Student record review, The district submitted signed N3A forms, along with the Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 7 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified documentation and interviews dates that the parents of these students were provided the IEPs. The district also provided copies of N1forms and copies of N2 forms for students that were determined not to be or no longer eligible for special education services or programs. SE29 Student record review, documentation and interviews The district submitted copies of the notices that it sends home in English, along with copies of the same notices that it sends home in other languages. SE30 Student record review, documentation and interviews The district recently purchased a program that translates all notices to parents. SE34 Student record review, documentation and interviews The district provided a list and program descriptions for its continuum of services from the least restrictive to Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 8 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance most restrictive educational setting. SE36 SE40 SE41 Student record review, documentation and interviews The district provided a copy of its written policy and procedure that it has developed in order to notify all service providers and teachers of the receipt of an accepted or partially accepted IEP and to implement the services without delay. Student record review, documentation and interviews The district submitted class rosters for all special education classes with the names of the students, teachers, aides, or copies of requested waivers to demonstrate compliance with this criterion. Student record review, documentation and interviews The district submitted class rosters for all its high school special education classes and programs with names of the Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 9 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance students and their dates of birth to demonstrate compliance with this criterion. SE42 Student record review, documentation and interviews The district submitted class rosters with the names of the students, teachers, aides, and the designation of which students in its kindergarten classes are on IEPs to demonstrate compliance with this criterion. SE43 Student record review, documentation and interviews The district submitted copies of its developed Functional Behavioral Assessment procedures and practices. The district also submitted copies of Functional Behavioral Assessments. SE47 Student record review, documentation and interviews The district provided evidence that training is continuing to occur on this topic and specific evidence of future trainings, including Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 10 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance topics covered, dates selected, and attendees. SE48 Student record review, documentation and interviews The district submitted evidence that all students receive an equal opportunity to participate in the general education program as well as the non-academic and extracurricular programs of school. SE49 Student record review, documentation and interviews The district provided copies of its written policy and procedure that it has developed in order to notify all service providers and teachers of the receipt of an accepted or partially accepted IEP and to implement the services without delay. SE50 Student record review, documentation and interviews The district provided copies of its developed procedures and forms used to document child study team activities Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 11 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance and the implementation of its DCAP. SE51 Student record review, documentation and interviews The district provided copies of the certification/licensure for all its special education teachers, and all staff are fully licensed or on an approved waiver. SE52 Student record review, documentation and interviews The district provided copies of the certifications/licensure for all its related service providers. SE53 Student record review, documentation and interviews The district provided copies of the receipt signature sheet for the Special Education Summary sheets that have been distributed to paraprofessional staff that provide services to special education students. The district also provided evidence of the professional development trainings that it Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 12 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance has offered to its paraprofessional staff members, along with a copy of the agendas, training materials used, and signed attendance sheets. SE54 Documentation review and interviews The district submitted a copy of their professional development plan for both paraprofessionals and professional staff. SE56 Documentation review and Interviews The district provided documentation of its developed comprehensive program for evaluating the effectiveness of programs in assisting students with disabilities to achieve the goals set forth in their IEPs in the least restrictive environment. Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 13 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic 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 Special Education Criteria created or revised in response to IDEA-2004 SE 6 #1 - 3 Determination of Transition Services Student record review, documentation and interviews The district submitted a record of transition plans to demonstrate compliance with this criterion. SE 8 IEP Team composition and attendance Student record review and documentation The district submitted the names and titles of the personnel in the district that are able to commit district resources at Team meetings, along with signed attendance sheets from Team meetings to demonstrate that regular education teachers and other required persons are in attendance at the Team meetings. Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 14 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented SE 12 Frequency of re-evaluation Student record review and documentation The district provided records and copies of the students’ initial IEPs and their IEPs after being reevaluated. SE 13 Progress Reports and content Student record review and documentation The school district submitted current copies of all progress reports. SE 14 Review and revision of IEPs Student record review and documentation Student records and documentation provided indicated that the school district conducts annual reviews in a timely manner. SE 25B Resolution of disputes Documentation review The district submitted evidence that they contact the BSEA in order to try to resolve a dispute regarding IEPs. SE 33 Involvement in the General Curriculum Student record review and documentation The district submitted the names and titles of the personnel in the district that are able to commit district resources at Team meetings. Basis of Determination that Criterion was Partially Implemented or Not Implemented Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 15 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic 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 The district also submitted signed attendance sheets from Team meetings to demonstrate that required persons are in attendance at the Team meetings. SE 39A Procedures for services to eligible private school students whose parents reside in the district Documentation Review The district provided a copy of its written policy and procedure that it has developed to provide services to eligible students in private schools at a private expense. Documentation Review The district provided a copy of its written policy and procedure that it has developed to provide services to eligible students in private schools at a private expense whose parents (SE 39A does not apply to charter schools or vocational schools) SE 39B Procedures for services to eligible students in private schools Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 16 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic 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 reside out of state. in the district whose parents reside out of state (SE 39B does not apply to charter schools or vocational schools) SE 46 Procedures for suspension of students with disabilities more than 10 days Documentation Review The district submitted written copies of its revised exit criteria for its alternative education programs. The district also provided evidence that appropriate training has occurred on this topic. Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 17 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting Palmer 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 Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) ELE 1 Annual Assessment ELE 2 MCAS Participation ELE 3 Initial Identification ELE 4 Waiver Procedures Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 18 of 22 Required Corrective Action, Timelines for Implementation, and Progress Reporting ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting ELE 5 Program Placement and Structure Documentation indicates the district’s program placement and structure do not meet all requirements under this criterion. The district needs to have additional staff trained in Sheltered English Immersion. The district must provide its plan to have all staff trained in SEI to the Department on or before September 10, 2007. ELE 6 Program Exit and Readiness Documentation indicates the district does not have well-established procedures to appropriately determine an LEP student’s program readiness and exit level. The district will develop a program placement and structure plan for LEP students that meet all requirements under this criterion. A copy of the program placement and structure plan will be provided to the Department on or before September 10, 2007. ELE 7 Parent Involvement Documentation indicates the district does not have well established mechanisms in place that consistently include parents/guardians of LEP students in matters pertaining to their children’s education. The district will develop well-established mechanisms that consistently include parents/guardians of LEP students in matters pertaining to their children’s education. A copy of this plan will be provided to the Department on or before September 10, 2007. ELE 8 Declining Entry to a Program Documentation indicates the district does not have well-established procedures for parents/guardians of LEP students who choose to decline entry to a district program. To date only one parent of an LEP student, designated for an advanced ELL class, declined entry to a district program. The district will develop procedures for parents/guardians of LEP students who choose to decline entry to a district program. A copy of the plan will be provided to the Department on or before September 10, 2007. Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 19 of 22 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting ELE 9 Instructional Grouping ELE 10 Parental Notification Documentation indicates the district’s grouping of students does not ensure that LEP students receive effective content instruction at appropriate academic levels and that ESL/ELD instruction is at the appropriate proficiency level and based on the English Language Proficiency Benchmarks and Outcomes. Documentation indicates the district does not have a parental notification letter. The notification letter must include the following elements: a. reasons for identification of the student as LEP; b. child’s level of English proficiency; c. program placement and/or method of instruction used in the program; d. parent’s right to apply for a waiver or to decline to enroll their child in the program. Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 20 of 22 The district must provide its plan to ensure that this criterion is fully implemented by September 10, 2007. The district will develop a parental notification letter to the Department on or before September 10, 2007. This notice must be mailed upon placement of any student in the district’s ELE program and annually thereafter in both English and the student’s primary/home language. The notification letter must incorporate the following elements: a. reasons for identification of the student as LEP; b. child’s level of English proficiency; c. program placement and/or method of instruction used in the program; d. parent’s right to apply for a waiver or to decline to enroll their child in the program. The district will also provide a letter of assurance that it will provide parents of LEP students with report cards and progress report in a language understandable to the parent to the maximum extent possible. A copy of the memo and letter of assurance will be provided to the Department on or before September 10, 2007. ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting ELE 11 Equal Access to Academic Programs and Services ELE 12 Equal Access to Nonacademic and Extracurricular Programs ELE 13 Follow-up Support Documentation indicates the district does not actively monitor students who have exited an English learner education program for two years and does not provide language support services to those students, if needed. The district must provide its plan to ensure that this criterion is fully implemented by September 10, 2007. ELE 14 Licensure Requirements Documentation indicates the district does not have a certified ELL teacher in the school system. The district must have staff that holds the appropriate licenses issued by the Department of Education and provide evidence to the Department on or before September 10, 2007. Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 21 of 22 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment 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 indicates the district has not met all required professional development requirements under this criterion. ELE 15 Professional Development Requirements ELE 16 Equitable Facilities ELE 17 Program Evaluation The district must provide its plan to have all staff trained in SEI to the Department on or before September 10, 2007. ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) Mid-cycle Report Format 2007.doc Rev. 1/3/07 Palmer Public Schools Coordinated Program Review Mid-cycle Report July 25, 2007 Page 22 of 22