Massachusetts Department of
Elementary and Secondary Education
75 Pleasant Street, Malden, Massachusetts 02148-4096
Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
August 16, 2013
Thomas Charko, Superintendent
Palmer Public Schools
24 Converse Street
Palmer, MA 01069
Re: Mid-cycle Report
Dear Superintendent Charko:
Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Report based
on the onsite visit conducted in your district in April 2013. During the Mid-Cycle Review the
Department monitored selected special education criteria to determine your district’s compliance
with special education laws and regulations. The review consisted of information gathered from
one or more of the following activities: interviews, review of student records, examination of
documentation, and classroom observation(s).
The Department determined that one or more of the criteria monitored in your district was
“Partially Implemented” or “Not Implemented.” In all instances where noncompliance was
found, the Department has prescribed corrective action for the district. This corrective action
must be implemented as soon as possible, but in no case later than a year from the date of this
report. You will find these requirements for corrective action included in the enclosed report,
along with requirements for submitting progress reports using the enclosed form.
Please provide the Department with your written assurance that all of the required corrective
action will be implemented by your district within the timelines specified in the report. You
must submit your statement of assurance to Darlene Lynch, Director, Program Quality Assurance
Services, by September 3, 2013.
1
Your staff's cooperation throughout this Mid-cycle Review is appreciated. If you have questions
about this letter or the enclosed report, please do not hesitate to contact me at (413) 314-6708.
Sincerely,
Tom Hidalgo, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
cc:
Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education
Michelle Poulin, Supervisor, Program Quality Assurance Services
Maureen Gallagher, School Committee Chair
Susan Farrell, Local Program Review Coordinator
Encs: Mid-cycle Report
Mid-cycle Progress Report Form
2
MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION
MID-CYCLE REPORT
Palmer Public Schools
Dates of the Mid-cycle Review Onsite: April 17, 2013
Date of this Report: August 16, 2013
PLEASE NOTE THAT THIS REPORT IS IN TWO SECTIONS.
Required Special Education Criteria Monitored in this Mid-cycle Review
Current special education criteria available by scrolling down to the special education instrument at
http://www.doe.mass.edu/pqa/review/cpr/default.html
Criterion
SE 7
Transfer of
parental
rights and
student
participation
and consent
at age of
majority
Criterion
Implemented


Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Student
record review
Documents
Interview
Basis of Determination about
Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and
Timelines for
Implementation
Student record review, documents
and an interview indicated that
one year prior to the student
reaching age 18, the district
informs the student and the
parent/guardian of the rights that
will transfer from the
parent/guardian to the student
upon the student’s 18th birthday.
Upon reaching the age of 18, the
school district implements
procedures to obtain consent from
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 1 of 13
(b) Progress Report
Due Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination about
Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and
Timelines for
Implementation
(b) Progress Report
Due Date(s) and
Required
Elements
the student to continue the
student’s special education
program.
Student
record review
Interview
SE 8
IEP Team
composition
and
attendance

PI
SE 18A
IEP
Development
and content
Student
record review
Documents
Interview
Student record review and an
interview indicated that members
of the Team attend Team
meetings unless the parent and
district agree to use alternative
means, or the district and the
parent agree, in writing, that the
attendance of the Team member is
not necessary or the district and
the parent agree, in writing, to
excuse a required Team member’s
participation and the excused
member provides input in the
development of the IEP to the
parent and the IEP Team prior to
the meeting.
Student record review, documents
and an interview indicated that the
IEP Team considers and
specifically addresses the skills
and proficiencies needed to avoid
and respond to bullying,
harassment, or teasing when the
Review a sample of student
records across all grade levels
for IEP Teams convened
between January and April of
the 2012-2013 school year, to
determine why the IEP does
not address all required
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 2 of 13
Submit a description
of the root cause
analysis with the
results, as well as
specific proposal(s)
for remedying the
non-compliance and
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination about
Criterion
IEP Team evaluation indicates
that a student’s disability affects
social skills development, or when
the student’s disability makes him
or her vulnerable to bullying,
harassment or teasing, or when a
student is identified with a
disability on the autism spectrum.
Student record review and an
interview indicated that IEPs do
not consistently address all
elements of the most current IEP
format provided by the
Department, such as the student’s
educational strengths, interest
areas, significant personal
attributes, personal
accomplishments and type of
disability.
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and
Timelines for
Implementation
elements, specifically the
student’s educational strengths,
interest areas, significant
personal attributes, personal
accomplishments and type of
disability. Analyze the
information to establish the
root causes for the noncompliance. Based on this root
cause analysis, indicate the
specific corrective actions that
will be taken to remedy the
non-compliance.
associated timelines,
by November 1,
2013.
Develop an internal oversight
and tracking system to ensure
that all elements of the IEP are
addressed. The tracking system
should include supervisory
oversight and periodic reviews
by a designated person to
ensure ongoing compliance.
Submit a report of
the results of the
second review and
include the number
of IEPs reviewed;
the number in
compliance with this
criterion; for IEPs
not in compliance,
determine the root
cause and the
corrective actions the
district will take to
remedy any noncompliance, by
January 31, 2014.
Conduct a second review of a
sample of IEPs across all grade
levels, developed after all
corrective actions were
completed, to determine if all
elements of the IEP are
addressed.
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 3 of 13
(b) Progress Report
Due Date(s) and
Required
Elements
Submit a description
of the district’s
internal oversight
and tracking system
with periodic
reviews, along with
the name and role of
the designated
person, by
November 1, 2013.
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination about
Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and
Timelines for
Implementation
*Please note when
conducting internal
monitoring the district must
maintain the following
documentation and make it
available to the Department
upon request: a) List of
student names and grade
levels for the records
reviewed; b) Date of the
review; c) Name of person(s)
who conducted the review,
with their role(s) and
signature(s).
Student
record review
Interview
SE 25
Parental
consent

Student record review and an
interview indicated that if the
parent has given consent for
special education services and
then revokes his/her consent in
writing, the district discontinues
all special education services. The
district acts promptly to provide
written notice to the parent of the
district’s proposal to discontinue
services as well as information on
how the parent can obtain a copy
of his/her right to procedural
safeguards. The district provides
the notice in a reasonable time
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 4 of 13
(b) Progress Report
Due Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination about
Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and
Timelines for
Implementation
(b) Progress Report
Due Date(s) and
Required
Elements
before the district intends to
discontinue the services.
Additional Special Education Criteria Monitored in this Mid-cycle Review
Current special education criteria available by scrolling down to the special education instrument at
http://www.doe.mass.edu/pqa/review/cpr/default.html
Criterion
SE 4
Reports of
assessment
results
Criterion
Implemented


Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
Student
record review
Student record review and an
interview indicated that the
assessment reports
consistently summarized in
writing the procedures
employed and the results and
diagnostic impressions. The
reports defined in detail and in
educationally relevant and
common terms the students’
needs, and offered explicit
means of meeting the
Interview
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 5 of 13
(b) Progress Report
Due Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
(b) Progress Report
Due Date(s) and
Required
Elements
identified needs.
PI
SE 18B
Determination of
placement;
provision of IEP
to parent
Student
record review
Interview
Student record review and an
interview indicated that
although the district provided
the parent with two copies of
the proposed IEP and
proposed placement, along
with the required notice, it did
not always provide the
documents immediately
following the development of
the IEP.
Review a sample of student
records across all grade levels
for IEP Teams convened
between January and April of
the 2012-2013 school year, to
determine why two copies of
the proposed IEP and proposed
placement, along with the
required notice, are not always
provided immediately
following the development of
the IEP.
Develop an internal oversight
and tracking system to ensure
that the documents are sent
immediately following the
development of the IEP. The
tracking system should include
supervisory oversight and
periodic reviews by a
designated person, to ensure
ongoing compliance.
Conduct a second review of all
IEPs issued, after all corrective
actions were completed, to
determine if copies of the IEP
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 6 of 13
Submit a description
of the root cause
analysis with the
results, as well as
specific proposal(s)
for remedying the
non-compliance and
associated timelines,
by November 1,
2013
Submit a description
of the internal
oversight and
tracking system with
periodic reviews,
along with the name
and role of the
designated persons,
by November 1,
2013.
Submit the results of
a second record
review and include
the number of
records reviewed;
the number in
compliance with this
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
and placement were provided
to parents immediately
following development of the
IEP
*Please note when
conducting internal
monitoring the district must
maintain the following
documentation and make it
available to the Department
upon request: a) List of
student names and grade
levels for the records
reviewed; b) Date of the
review; c) Name of person(s)
who conducted the review,
with their role(s) and
signature(s)..
PI
SE 20
Least restrictive
program selected
Student
record review
Documents
Interview
Student record review,
documents and an interview
indicated that the IEP Team
did not consistently state why
the removal of a student from
the general classroom is
considered critical to the
student’s program, nor
provide the basis for its
conclusion that education of
the student in a less restrictive
Review a sample of student
records across all grade levels
for IEP Teams convened
between January and April of
the 2012-2013 school year, to
determine why the IEP Team
did not consistently state why
the removal of a student from
the general classroom is
considered critical to the
student’s program and did not
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 7 of 13
(b) Progress Report
Due Date(s) and
Required
Elements
criterion; the root
cause of any noncompliance; and the
corrective actions the
district will take to
remedy any noncompliance, by
January 31, 2014.
Submit a description
of the root cause
analysis with the
results, as well as
specific proposal(s)
for remedying the
non-compliance and
associated timelines,
by November 1,
2013
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
environment, with the use of
supplementary aids and
services, could not be
achieved satisfactorily.
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
provide the basis for its
conclusion that education of
the student in a less restrictive
environment, with the use of
supplementary aids and
services, could not be achieved
satisfactorily.
Develop an internal oversight
and tracking system to ensure
that the IEP consistently states
why a student is removed from
the general education
classroom. The tracking system
should include supervisory
oversight and periodic reviews
by a designated person, to
ensure ongoing compliance.
Conduct a second review of
student records across all grade
levels, for IEPs developed after
all corrective actions were
completed, to determine if
IEPs explain why students’
removal from the general
education classroom is
considered critical to the
students’ program.
*Please note when
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 8 of 13
(b) Progress Report
Due Date(s) and
Required
Elements
Submit a description
of the internal
oversight and
tracking system with
periodic reviews,
along with the name
and role of the
designated person,
by November 1,
2013.
Submit the results of
the second review
and include the
number of IEPs
reviewed; the
number in
compliance with this
criterion; the root
cause of any noncompliance; and the
corrective actions the
district will take to
remedy any noncompliance, by
January 31, 2014.
.
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
conducting internal
monitoring the district must
maintain the following
documentation and make it
available to the Department
upon request: a) List of
student names and grade
levels for the records
reviewed; b) Date of the
review; c) Name of person(s)
who conducted the review,
with their role(s) and
signature(s).
SE 22
IEP
Implementation
and availability
Student
record review

Documents
Interview
Student
record review
SE 24
Notice to parent
Interview

Student record review,
documents and an interview
indicated that the high school
is providing the mutually
agreed upon services stated in
the student’s IEP without
delay.
Student record review and an
interview indicated that the
district consistently addressed
the six questions, as required
by federal regulation, on the
Notice of School District
Action (N1). The questions
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 9 of 13
(b) Progress Report
Due Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
are:
1. What action is the school
district proposing to take?
2. Why is the school district
proposing to act?
3. What rejected options were
considered and why was each
option rejected?
4. What evaluation procedure,
test, record or report was used
as a basis for the proposed
action?
5. What other factors were
relevant to the school
district’s decision.
6. What next steps, if any, are
recommended?
SE 27
Content of Team
meeting notice to
parents
SE 29
Communications
are in English
and primary

Student
record review
Interview

Student
record review
Student record review and an
interview indicated that parent
notices of any Team meeting
included a list of the Team
members who would be in
attendance at the meeting.
Student record review and an
interview indicated that
communication with parents
is provided in both English
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 10 of 13
(b) Progress Report
Due Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
language of the
home
Interview
and the primary language of
the home, if such primary
language is other than
English.
SE 34
Continuum of
alternative
services and
placements
Student
record review
Student record review,
document review and an
interview indicated that the
district has developed
programs for students with
social emotional and
behavioral issues at the
elementary and high school
levels and will expand the
continuum to include two
elementary programs, one
middle school program, and
two high school programs for
school year 2013-14.

Documents
Interview
SE 36
IEP
implementation,
accountability,
and financial
responsibility
Student
record review

Documents
Interview
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
The district oversees the full
implementation of each IEP
which has been consented to
by a student’s parents.
See also SE 22.
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 11 of 13
(b) Progress Report
Due Date(s) and
Required
Elements
Criterion
SE 54
Professional
Development
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
Documents
Documents and an interview
indicated that the district did
not provide training to all
staff, including special
education and general
education staff, on state and
federal special education
requirements and related local
special education policies and
procedures; analyzing and
accommodating diverse
learning styles of all students
in order to achieve an
objective of inclusion in the
general classroom of students
with diverse learning styles;
methods of collaboration
among teachers,
paraprofessionals and teacher
assistants to accommodate
diverse learning styles of all
students in the general
classroom.
PI
Interview
According to a review of
documents, the district does
not provide in-service training
for all locally hired and
contracted transportation
providers, before they begin
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
Provide training to all staff
including special education and
general education staff on
state and federal special
education requirements and
related local special education
policies and procedures;
analyzing and accommodating
diverse learning styles of all
students in order to achieve an
objective of inclusion in the
regular classroom of students
with diverse learning styles;
methods of collaboration
among teachers,
paraprofessionals and teacher
assistants to accommodate
diverse learning styles of all
students in the regular
classroom.
Provide training to all locally
hired and contracted
transportation providers, before
they begin transporting any
special education student
receiving special
transportation, on his or her
needs and appropriate methods
of meeting those needs; and to
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 12 of 13
(b) Progress Report
Due Date(s) and
Required
Elements
Submit a plan with
topics and dates to
provide training to
all staff, including
special education
and general
education staff, by
November 1, 2013.
Submit evidence that
all locally hired and
contracted
transportation
providers receive
appropriate training
(agenda, attendance
list, and materials
used) by November
1, 2013.
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
transporting any special
education student receiving
special transportation, on his
or her needs and appropriate
methods of meeting those
needs; nor does it provide for
any such student, written
information on the nature of
any needs or problems that
may cause difficulties, along
with information on
appropriate emergency
measures.
provide for any such student,
written information on the
nature of any needs or
problems that may cause
difficulties, along with
information on appropriate
emergency measures.
Palmer Public Schools Coordinated Program Review Mid-cycle Report
August 16, 2013
Page 13 of 13
(b) Progress Report
Due Date(s) and
Required
Elements
MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION
MID-CYCLE REVIEW
School District: Palmer Public Schools
M I D – CY C L E P R O G R E S S R E P O R T
Date Prepared: ____________________________________
Prepared by: __________________________________________________________________
(name and title)
Criterion: _______________________
Topic: ________________________________________________________________________
For each criterion for which you prepare a progress report, please



make a copy of this cover page,
fill in the information requested above, and
attach a complete description of the corrective action taken and any accompanying documentation.
(Description of corrective action for each criterion and any accompanying documentation should include all of the
“Progress Report Required Elements” for that criterion in the Mid-cycle Report.)
Send the whole set of completed progress reports to:
Darlene Lynch, Director
Program Quality Assurance Services
Massachusetts Department of Elementary and Secondary Education
75 Pleasant Street
Malden, MA 02148-4906