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 May 14, 2012 Dr. Gerald Paist, Superintendent Pathfinder Regional Vocational Technical High School 240 Sykes Street Palmer, Massachusetts 01069-1129 Re: Mid-cycle Report Dear Dr. Paist: Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Report based on the onsite visit conducted in your district in January of 2012. 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 Mid-Cycle Report for your district describes continued serious noncompliance with state and federal law in special education. 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. The Department is concerned regarding the number of issues identified and subsequently corrected from the previous CPR, which have reoccurred. Beth Lopez will contact you shortly to arrange a meeting regarding the identified non-compliance and to provide technical assistance. 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 May 30, 2012. If you have questions about this letter or the enclosed report, please do not hesitate to contact Beth Lopez at 781-338-6703 or 413-314-6703. Sincerely, D. Beth Lopez, 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 Jean Jonker, Supervisor, Program Quality Assurance Services Michael J. Cavanaugh, School Committee Chairperson Nicole Heroux, Local Program Review Coordinator Encs: Mid-cycle Report Mid-cycle Progress Report form MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REPORT Pathfinder Regional Vocational Technical High School Dates of the Mid-cycle Review Onsite: January 4 & 5, 2012 Date of this Report: May 14, 2012 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 PI Student Records Interviews Document Review Basis of Determination about Criterion The district has newly developed written procedures delineating when and how the district informs the student and parent about the rights that will transfer to the student at the age of majority and the process the district employs to procure consent from the student upon reaching 18. However, student record review, interviews and documents reveal that the district does not yet routinely, one year prior to the student If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation For those students whose records were identified by the Department, who were not informed about the rights that transfer to the student at the age of majority one year prior to turning 18, the district must inform the students and their parents of the rights that transfer to the student at the age of majority. Conduct an analysis of student records of students turning 17 Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 1 of 29 (b) Progress Report Due Date(s) and Required Elements For student records identified by the Department, submit evidence that those identified students who have not yet reached the age of majority, and their parents, have been informed about the rights that transfer to the student at the age of majority by September 28, 2012. Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion turning 18, inform the student and the parent of the rights that will transfer to the student upon reaching the age of 18. If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation between September 2011 and April 2012, to determine why the district is not, one year prior to the student’s 18th birthday, routinely informing students and their parents of the rights that will transfer to the student upon reaching the age of majority. Based on the results of the analysis, provide the district’s determination of the root cause(s) of the noncompliance, the steps the district proposes to take to correct the root causes and a timeline for the implementation of those corrections. Develop an internal tracking and oversight system with periodic review by designated person(s) responsible, to ensure that one year prior to the student turning 18, the district informs the student and the parent of the rights that will transfer to the student upon reaching the age of 18. Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 2 of 29 (b) Progress Report Due Date(s) and Required Elements Submit the results of the analysis conducted of the records of students turning 17 between September 2011 and April 2012. Include the number of student records reviewed and the number of records in compliance. Include a description of the root cause(s); of any noncompliance, a description of the steps the district will take to correct the root cause(s); and the district’s proposed timeline for implementation of corrective actions by September 28, 2012. Submit a description of the district’s internal oversight and tracking system with periodic review along with the name/role of the designated person(s) responsible by January 4, 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 The district must conduct an internal review of student records after all other corrective actions have been implemented: 1. the records of all those students who attained the age of 17 subsequent to the district’s implementation of corrective actions to ensure that each of these students (and their parent or guardian) was appropriately informed of the transfer of rights to the student at the age of 18. 2. the records of all those students who attained the age of majority subsequent to the district’s implementation of corrective actions to ensure that the district obtained consent to continue the student’s special education program. *Please note when conducting Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 3 of 29 (b) Progress Report Due Date(s) and Required Elements Submit a report of the results of the two internal reviews and include the following information for each sample: number of student records reviewed; number of records in compliance; for records not in compliance, determine the root cause(s); and the specific action(s) taken by the district to remedy the non-compliance by January 4, 2013. The Department will also conduct an onsite review to verify correction of noncompliance. 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 internal monitoring that district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s. SE 8 IEP Team composition and attendance Student Records Interviews Document Review Student record review, interviews and review of documents indicate that members of the IEP Team consistently attend meetings unless the parent and the district agree to alternative means, or the district and the parent agree in writing that the attendance of the Team member is not necessary. When a Team member’s participation is required, the excused member provides Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 4 of 29 (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 written input for the development of the IEP prior to the scheduled meeting. SE 18A IEP development and content Student Records Interviews Document Review Student record review, interviews and review of documents indicate that the district addresses all elements of the most current IEP format, including the Team’s designation of how each student will participate in the Massachusetts Comprehensive Assessment System (MCAS). The district considers and specifically addresses the skills needed to avoid and respond to bullying for students identified with a disability on the autism spectrum. Whenever the Team evaluation indicates that the student’s disability makes him or her vulnerable to bullying, harassment or teasing, the IEP addresses the skills and proficiencies needed to avoid and respond Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 5 of 29 (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 to bullying, harassment, or teasing. SE 25 Parental consent PI Student Records Interviews Student record review and interviews reveal that the district does not consistently secure and document written parental consent before conducting an evaluation or re-evaluation, and before providing the services proposed on a student’s IEP. For those student records identified by the Department as having a Team meeting but with no subsequent parental consent for proposed IEP services, secure parent/guardian consent or that of the 18 year old student for all unexpired IEPs that are missing consent. For those identified student records, please submit evidence that consent was secured for IEP services provided by the district [i.e. IEP Response Section (IEP 8)] by September 28, 2012. Conduct an analysis of a cross section of student records for Team activities that took place between September 2011 and April 2012, to determine: 1. why parental consent is not being routinely secured before conducting an evaluation, and 2. why proposed services are initiated prior to obtaining parental consent. Submit the results of the analysis conducted of student records for activities taking place between September 2011 and April 2012. Include the number of student records reviewed and the number of records in compliance. Include a description of the root cause(s) of any noncompliance, a description of the steps the district will take to Based on the results of the analysis, provide the district’s Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 6 of 29 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 determination of the root cause(s) of the noncompliance, the steps the district proposes to take to correct the root causes and a timeline for the implementation of those corrections. correct the root cause(s); and the district’s proposed timeline for implementation of corrective actions. by September 28, 2012. Develop an internal tracking and oversight system with periodic review by designated person(s) responsible, to ensure that the district secures and documents written parental consent before conducting an evaluation or re-evaluation, and before providing the services proposed on a student’s IEP. . Conduct an internal review of a sampling of student records for Team meetings conducted after the implementation of all corrective actions to ensure that in all cases parental consent is secured before conducting an evaluation and before providing services proposed on a student’s IEP. Submit a description of the district’s internal oversight and tracking system with periodic review along with the name/role of the designated person(s) responsible by January 4, 2013. Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 7 of 29 (b) Progress Report Due Date(s) and Required Elements Submit a report of the results of the internal record review. Include the number of student records reviewed; number of records in compliance; for records not in compliance, determine the root cause(s); and the specific action(s) taken by the district to remedy the non-compliance by 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 that district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 8 of 29 (b) Progress Report Due Date(s) and Required Elements January 4, 2013. The Department will also conduct an onsite review to verify the correction of non-compliance. 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 1 Assessments are appropriately selected and interpreted SE 3 Special requirements for determination of specific Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion Student Records Student record review, interviews and review of documents indicate that assessments and other evaluation materials are validated and administered by trained individuals. The district uses information from a variety of sources to gather relevant functional and developmental information and ensures that information obtained from these sources is considered. Interviews Document Review NI Student Records Interviews Document Student record review, interviews and review of documents indicate that the district does not have procedures in place for determining Specific If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation (b) Progress Report Due Date(s) and Required Elements Develop district procedures for the determination of Specific Learning Disability (SLD) and provide IEP Team chairpersons with training on those procedures. Please submit a copy of the district’s procedures for the determination of SLD, and evidence of staff training (agendas, signed attendance sheets Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 9 of 29 Criterion learning disability Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion Review Learning Disability (SLD) when students suspected of having a specific learning disability are evaluated. If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation See http://www.doe.mass.edu/sped/ iep/sld/ for a description of appropriate procedures and forms for the identification and documentation of SLD. Develop an internal tracking and oversight system with periodic review by designated person(s) responsible, to ensure that Team chairpersons are consistently using appropriate procedures and forms. Conduct an internal review of those records of students who were evaluated for SLD subsequent to the district’s implementation of all corrective actions to ensure that the district has consistently completed and maintained all the required SLD components . *Please note when conducting internal monitoring that district must maintain the following documentation and Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 10 of 29 (b) Progress Report Due Date(s) and Required Elements indicating title/role of staff, name and title of the presenter, training materials, etc.) by September 28, 2012. Submit a description of the district’s internal oversight and tracking system with periodic review along with the name/role of the designated person(s) responsible by January 4, 2013. Submit a report of the results of the internal record review. Include the number of student records reviewed; the number of records in compliance; for records not in compliance, determine the root cause(s); and the specific action(s) taken by the district to remedy any identified non-compliance by January 4, 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 (b) Progress Report Due Date(s) and Required Elements make it available to the Department upon request: a) List of the student names and grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). SE 4 Reports of Assessment results PI Student Records Interviews Student record review and interviews reveal that summaries of assessments were not consistently completed prior to discussion by the Team and did not consistently contain recommendations for meeting the student’s needs. Conduct an analysis of a cross section of initial evaluations and re-evaluations conducted between September 2011 and April 2012, to determine why summaries of assessments are not consistently completed prior to the Team meeting and why summaries do not consistently contain the required recommendations for meeting student needs. Based on the results of the analysis, provide the district’s determination of the root cause(s) of the noncompliance, the steps the district proposes to take to correct the root causes and a timeline for the implementation of those corrections. Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 11 of 29 Please submit the results of the district’s analysis. Include a description of the root cause(s); of the noncompliance, a description of the steps the district will take to correct the root cause(s); the district’s proposed timeline for implementation of corrective actions. Submit a description of the district’s internal oversight and tracking system with periodic review along with the name/role of the designated person(s) responsible by January 4, 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 Develop an internal tracking and oversight system with periodic review by designated person(s) responsible, to ensure that summaries of assessments are completed prior to discussion by the Team and contain recommendations for meeting the student’s needs. Conduct an internal review of a sampling of student records for evaluations conducted after the implementation of all corrective actions to ensure that summaries of all assessments are completed prior to discussion by the Team and contain recommendations for meeting the student’s needs. *Please note when conducting internal monitoring that district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 12 of 29 (b) Progress Report Due Date(s) and Required Elements 2013. Submit a report of the results of the internal record review conducted after implementation of all corrective actions. Include the number of student records reviewed; number of records in compliance; for records not in compliance, determine the root cause(s); and the specific action(s) taken by the district to remedy the noncompliance by January 4, 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 (b) Progress Report Due Date(s) and Required Elements grade level for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). SE 5 Participation in general state and district-wide assessments SE 9 Timelines for the determination of eligibility Student Records Interviews Document Review PI Student Records Interviews Student record review, interviews and review of documents indicate that Team members designate how each student will participate in the MCAS and other district-wide assessment programs. Student record review and interviews demonstrate that the district does not, in every case, provide the parent with a proposed IEP, proposed placement, or a written explanation of the finding of no eligibility within 45 working days after receipt of the parent’s consent to evaluate. Conduct an analysis of a cross section of evaluations conducted between September 2011 and April 2012, to determine why parents are not provided with a proposed IEP, proposed placement or written explanation of the finding of no eligibility within 45 working days after receipt of parental consent. Based on the results of the analysis, provide the district’s determination of the root cause(s) of the noncompliance, the steps the Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 13 of 29 Please submit the results of the district’s analysis. Include a description of the root cause(s); of the noncompliance, a description of the steps the district will take to correct the root causes, the district’s proposed timeline for implementation of corrective actions by September 28, 2012. 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 district proposes to take to correct the root causes, and a timeline for the implementation of those corrections. Develop an internal tracking and oversight system with periodic review by designated person(s) responsible, to ensure that parents are provided with a proposed IEP, proposed placement or written explanation of the finding of no eligibility within 45 working days after receipt of parental consent. Conduct an internal review of a sampling student records for both initial and reevaluations conducted after the implementation of all corrective actions to ensure that evaluations were conducted in compliance with timelines. *Please note that when monitoring the district must maintain the following Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 14 of 29 (b) Progress Report Due Date(s) and Required Elements Submit a description of the district’s internal oversight and tracking system with periodic review along with the name/role of the designated person(s) responsible by January 4, 2013. Submit a report of the results of the internal record review. Include the following: number of student records reviewed; number of records in compliance; for records not in compliance, determine the root cause(s); and the specific action(s) taken by the district to remedy the noncompliance by January 4, 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 documentation and make it available to the Department upon request: a) List of student names and grade levels for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). SE 9A Elements of the eligibility determination Student Records Interviews Student record review and interviews indicate that the district has appropriate procedures in place to determine whether a student is eligible for special education, or requires related services to make effective progress or access the general education curriculum. If the Team determines that the student is not eligible, but may be eligible for accommodations for disabilities under Section 504, the student is referred for consideration under that general Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 15 of 29 (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 education program. If the Team makes a finding of no eligibility, appropriate services are provided under the general education program. SE 12 Frequency of evaluation PI Student Records Interviews Document Review Student record review, interviews and review of documents indicates that timelines for completion of re-evaluations were not, in all instances, being met. Conduct an analysis of a cross section of evaluations conducted between September 2011 and April 2012, to determine why the timelines are not being met. Based on the results of the analysis, provide the district’s determination of the root cause(s) of the noncompliance, the steps the district proposes to take to correct the root cause(s) and a timeline for the implementation of those corrections. Develop an internal tracking and oversight system with periodic review by designated person(s) responsible, to ensure that timelines for all reevaluations are being met. Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 16 of 29 Please submit the results of the district’s analysis. Include a description of the root cause(s) of the noncompliance, a description of the steps the district will take to correct the root cause(s), and the district’s proposed timeline for implementation of corrective actions. September 28, 2012. Submit a description of the district’s internal oversight and tracking system with periodic review along with the name/role of the designated person(s) responsible by January 4, 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 2013. Conduct an internal review of re-evaluation Team meetings conducted subsequent to implementation of the district’s corrective actions to ensure that re-evaluations are being completed on time. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). SE 13 Progress reports and content PI Student Records Interviews Student record review, interviews and review of documents reveal that progress reports are not consistently completed Conduct an analysis of a cross section of student records from all grade levels from September 2011 to April 2012 to determine why progress Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 17 of 29 Submit a report of the results of the internal record review. Include the following: number of student records reviewed; number of records in compliance; for records not in compliance, determine the root cause(s); and the specific action(s) taken by the district to remedy the noncompliance by January 4, 2013. The Department will also conduct an onsite review to verify the correction of non-compliance. Please submit the results of the district’s analysis. Include a description of the root cause(s) of the noncompliance, a Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Document Review Basis of Determination about Criterion and issued with the same frequency as they’re issued to non-disabled peers. If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation reports are not consistently completed and issued with the same frequency as progress reports are issued to nondisabled peers. Based on the results of the analysis, provide the district’s determination of the root cause(s) of the noncompliance and a timeline for the implementation of those corrections. Develop an internal tracking and oversight system with periodic review by designated person(s) responsible, to ensure progress reports are consistently completed and issued with the same frequency as they’re issued to non-disabled peers. Following implementation of all corrective actions, conduct an internal review of a sample of student records from all grade levels to ensure that students are issued progress reports for all their IEP goals with the same frequency as progress reports are issued to Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 18 of 29 (b) Progress Report Due Date(s) and Required Elements description of the steps the district will take to correct the root cause(s), and the district’s proposed timeline for implementation of corrective actions by September 28, 2012. Submit a description of the district’s internal oversight and tracking system with periodic review along with the name/role of the designated person(s) responsible by January 4, 2013. Submit a report of the results of the internal record review. Include the following: number of student records reviewed; number of records in compliance; for records not in compliance, determine the root cause(s); and the specific 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 non-disabled peers. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). SE 14 Review and revision of IEPs PI Student Records Interviews Student record review and interviews indicate that the district does not consistently conduct a Team meeting at least annually on or before the anniversary date of the IEP to consider the student’s progress, and to review, revise or develop a new IEP or refer the student for a re-evaluation as appropriate. Conduct an analysis of a cross section of annual reviews from September 2011 to April 2012 to determine why annual reviews are not routinely being held on, or before, the anniversary date of the last accepted IEP. Based on the results of the analysis, provide the district’s determination of the root cause(s) of the noncompliance, along with the steps the district proposes to take to correct the root causes and a timeline for the implementation of those Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 19 of 29 (b) Progress Report Due Date(s) and Required Elements action(s) taken by the district to remedy the noncompliance by January 4, 2013. Please submit the results of the district’s analysis. Include a description of the root cause(s) of the noncompliance, a description of the steps the district will take to correct the root cause(s), and the district’s proposed timeline for implementation of corrective actions by September 28, 2012. Submit a description of the district’s internal 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 corrections. Develop an internal tracking and oversight system with periodic review by designated person(s) responsible, to ensure That annual reviews are consistently held on or before the anniversary date of the IEP. Select a sample of student records for annual reviews conducted after the implementation of all corrective actions, and conduct an internal review for compliance with timelines. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 20 of 29 (b) Progress Report Due Date(s) and Required Elements oversight and tracking system with periodic review along with the name/role of the designated person(s) responsible by January 4, 2013. Submit a report of the results of the internal record review. Include the number of student records reviewed; number of records in compliance; for records not in compliance, determine the root cause(s); and the specific action(s) taken by the district to remedy the noncompliance by January 4, 2013. The Department will conduct an onsite review to verify correction of non-compliance. Criterion SE 18B Determination of placement Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion PI Student Records Student record review and interviews demonstrate that the district does not in all cases, immediately following the development of the IEP, provide the parent with two (2) copies of the proposed IEP, or a summary, which must, at a minimum, contain (a) a completed service delivery grid describing the types and amounts of special education or related services proposed by the district, and (b) a statement of the major goal areas associated with these services, followed within two calendar weeks by the two (2) copies of the proposed IEP. Interviews If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation Conduct an analysis of a cross section of IEPs from all grade levels from September 2011 to April 2012 to determine why parents are not routinely being provided with two copies of the proposed IEP and placement within the required timelines. Based on the results of the analysis, provide the district’s determination of the root cause(s) of the noncompliance, along with the steps the district proposes to take to correct the root cause(s) and a timeline for the implementation of those corrections. Develop an internal tracking and oversight system with periodic review by designated person(s) responsible, to ensure that parents are routinely being provided with two copies of the proposed IEP and placement within the required timelines. Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 21 of 29 (b) Progress Report Due Date(s) and Required Elements Please submit the results of the district’s analysis. Include a description of the root cause(s) of the noncompliance, a description of the steps the district will take to correct the root cause(s), and the district’s proposed timeline for implementation of corrective actions by September 28, 2012. Submit a description of the district’s internal oversight and tracking system with periodic review along with the name/role of the designated person(s) responsible by January 4, 2013. Submit a report of the results of the internal record review. Include the following: number of 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 Select a sample of student records from all grade levels whose activity (initial evaluation, annual review, reevaluation) was conducted after implementation of all corrective actions to review for compliance with timelines for the provision of two copies of the proposed IEP to parents. *Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). SE 19 Extended evaluation Student Records Interviews Student record review and interviews demonstrate that district staff understand the extended evaluation process and are Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 22 of 29 (b) Progress Report Due Date(s) and Required Elements student records reviewed; number of records in compliance; for records not in compliance, determine the root cause(s); and the specific action(s) taken by the district to remedy the noncompliance by January 4, 2013. The Department will conduct an onsite review to verify correction of non-compliance. 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 able to use it appropriately. SE 20 Least restrictive program selected Student Records Interviews Document Review Student record review, interviews and review of documents confirm that the district is no longer relying exclusively on an inclusion model and the former substantially separate program, Modified Vocational Instruction at Pathfinder (MVIP). The district has expanded its continuum of alternative services and placement options. Record review, interview, and review of documents indicate that the program selected for the student is the least restrictive environment for that student with consideration given to any potential harmful effects on the student. If the student is removed from the general education classroom, the Team states why the removal is critical to the Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 23 of 29 (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 student’s program and the basis for the conclusion that the education of the student in a less restrictive environment with supplementary aids and services could not be achieved satisfactorily. SE 22 IEP implementation and availability Student Records Interviews Document Review Student record review, interviews and review of documents reveal that the district now has a process in place to actively inform teachers and service providers of their specific responsibilities related to the implementation of the student’s IEP and the specific accommodations, modifications and supports that must be provided under it. However, the district does not consistently have an IEP in effect for each eligible student at the beginning of the school year. For those students whose records were identified by the Department because they did not have a current IEP consented to and in place at the time of the onsite review, secure the consent of the parent and/or student. Conduct an analysis of a cross section of student records from September 2011 to April 2012 to determine why the district does not in all cases have an IEP in effect for each eligible student at the beginning of the school year. Based on the results of the analysis, provide the district’s determination of the root cause(s) of the Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 24 of 29 For those identified student records, submit evidence that consent was secured and documented in student records and/or evidence of ongoing attempts to obtain consent with evidence of the district’s subsequent actions (i.e., copy of the Notice of School District Action (N1), Meeting Invitation (N3), and Attendance Sheet (N 3A) for the IEP Team meetings) by September 28, 2012. Please submit the results of the district’s analysis. 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 noncompliance, along with the steps the district proposes to take to correct the root causes and a timeline for the implementation of those corrections. Develop an internal tracking and oversight system with periodic review by designated person(s) responsible, to ensure that the district has an IEP in effect for each eligible student at the beginning of the school year. Select a sampling of student records across all grade levels for annual reviews and reevaluations conducted after the implementation of all corrective actions, and conduct an internal review to ensure that all eligible students have an IEP in place for the 20122013 school year. *Please note that when monitoring the district must maintain the following Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 25 of 29 (b) Progress Report Due Date(s) and Required Elements Include a description of the root cause(s) of the noncompliance, a description of the steps the district will take to correct the root cause(s), the district’s proposed timeline for implementation of corrective actions, and September 28, 2012. Submit a description of the district’s internal oversight and tracking system with periodic review along with the name/role of the designated person(s) responsible by January 4, 2013. Submit a report of the results of the internal record review. Include the following: number of student records reviewed; number of records in compliance; for records not in compliance, determine the root Criterion SE 24 Notice to parent regarding proposal or refusal to initiate or change the identification, evaluation, or educational placement for the child or the provision of FAPE Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) PI Method(s) of Investigation Student Records Interviews Document Review Basis of Determination about Criterion Student record review, interviews and review of documents indicate that the district does not consistently provide written notice to parents and document written parental consent before conducting an evaluation or re-evaluation. If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation documentation and make it available to the Department upon request: a) List of student names and grade levels for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). cause(s); and the specific action(s) taken by the district to remedy the noncompliance by January 4, 2013. See SE 25. See SE 25. Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 26 of 29 (b) Progress Report Due Date(s) and Required Elements The Department will conduct an onsite review to verify correction of non-compliance. Criterion Criterion Implemented SE 33 Involvement in the general curriculum SE 34 Continuum of alternative services and placements Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion Student Records Student record review and interviews demonstrate that the district ensures that at least one member of the Team familiar with the general curriculum is present and able to discuss the student’s appropriate access to the general education curriculum. Interviews Student Records Interviews Document Review If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation According to student record review, interviews and review of documents, the district disbanded the substantially separate program, MVIP. Student record review and interviews indicate that decisions concerning each student’s placement and services are Team decisions based on the individual needs of the student. The school provides a continuum of services to meet the needs of all student with disabilities and takes the Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 27 of 29 (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 necessary steps to ensure compliance with all elements of the IEP. The continuum of services now includes a variety of placement and service options including; full inclusion with and without consult, tutorials and strategy classes for both special education and general education students, individual and small group support in the shop areas and related classes, as well as self contained small group pull out classes. Vocational exploratories are available to all students. SE 43 Behavioral interventions Student Records Interviews Student record reviews and interviews indicate that when a student’s behavior impedes their learning or the learning of others, the Team considers the student’s behavior including the use of positive behavioral Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 28 of 29 (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 interventions and the possible need for a functional behavioral analysis. SE 48 Equal opportunity to participate in educational, nonacademic, extracurricular and ancillary programs as well as regular education Interviews Document Review Interviews and a review of documents indicate that all students receiving special education have an equal opportunity to participate in and, if appropriate, receive credit for the vocational, supportive, or remedial services that may be available as part of the general education program as well as the non-academic and extracurricular programs of the school. Pathfinder Regional Vocational School Coordinated Program Review Mid-cycle Report May 14, 2012 Page 29 of 29 (b) Progress Report Due Date(s) and Required Elements MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REVIEW School District: Pathfinder Regional Vocational School District 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