Massachusetts Department of
Elementary and Secondary Education
350 Main Street, Malden, Massachusetts 02148-5023
Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
September 6, 2007
Milton C. Burnett, Superintendent
Peabody Public Schools
21 Johnson Street
Peabody, MA 01960
Re: 2007 Mid-cycle Coordinated Program Review Report
Dear Superintendent Burnett:
Enclosed is the Department of Elementary and Secondary Education's 2007 Mid-cycle
Coordinated Program Review Report (Mid-Cycle Report). Please accept our apologies for our
delay in providing you with this 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 Peabody Public
Schools Coordinated Program Review Report issued on April 30, 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/ .
We are pleased to indicate that the Department of Elementary and Secondary Education has
found your district's approved Corrective Action Plan to have been implemented and to have been
effective in remedying previously identified noncompliance in Special Education. The
Department has also found your district to implement special education compliance criteria that
were created or substantially changed in response to IDEA 2004, as well as SE 33, on the access
of students with disabilities to the district’s general curriculum (the curriculum expected to be
taught to all students). The findings of the Department are included in the attached report. You
1
and your entire staff are to be congratulated for your success in implementing not only all
required corrective action, but also all new special education requirements.
The Department will notify you of your district's next regularly scheduled Coordinated Program
Review several months before it is to occur. At this time we anticipate that this CPR will occur
sometime during the 2009 School Year unless the Department determines that there is some
reason to schedule this visit earlier.
While the Department of Elementary and Secondary Education found your district to have
resolved its special education noncompliance issues, the Department’s onsite staff member
identified issues of noncompliance with ELE criteria.
In all instances where noncompliance has been found, the Department has prescribed corrective
action for the district that must be implemented without delay. You will find these requirements
for corrective action included in the attached report, along with requirements for progress
reporting. Please provide the Department with your written assurance that all of the Department's
requirements for corrective action will be implemented by your district within the timelines
specified. You must submit your statement of assurance to me by September 21, 2007.
Your staff's cooperation throughout this Mid-cycle Review is appreciated. Should you like
clarification of any part of our report, please do not hesitate to contact me at 781-338-3703.
Sincerely,
Dean Paolillo, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c:
Jeffrey Nellhaus, Acting Commissioner of Elementary and Secondary Education
Michael Bonfati, Chairperson
Jean Shea, 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 ELEMENTARY AND SECONDARY
EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
Peabody Public Schools
ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS
Date of Coordinated Program Review (CPR): November 17, 2003
Date of Coordinated Program Review Corrective Action Plan Approval: August 25, 2004
Dates of Corrective Action Plan Progress Reports: January 14, 2005 & January 14, 2006
Dates of this Mid-cycle Review Onsite Visit: March 14, 2007 through March 16, 2007
Date of this Report: September 7, 2007
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 1 of 19
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
Approved
Corrective
Action
Implemente
d and
Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Student Record
Review &
Documentation
Review
A review of student records
indicated that the district is
meeting the 45 timeline. In only
one instance of the records
reviewed was district noted to
be egregiously beyond the 45day timeline in 2005. However,
the subsequent IEP met the
timelines. The Department has
determined that the incident of
noncompliance does not
constitute systemic
noncompliance with this
standard as further
documentation provided by the
district demonstrated. The
district tracks timeline
compliance using the computer
program EasyIEP® and a review

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)
SE 9
Timelines
Yes
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 2 of 19
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
Approved
Corrective
Action
Implemente
d 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
of the district’s timeline
compliance report indicated that
39 out of 39 meetings between
December 2006 and March
2007 were completed within the
timelines.
SE 18 A
IEP Development
Yes
SE 18 B
Placement
Yes
SE 29
Communications
Yes
Student Record
Review &
Documentation
The goals of the IEPs reviewed
were measurable. District
documentation indicated staff
members have been trained in
IEP development. The district
submitted training agendas and
attendance sheets for
verification. All chairpersons
have the authority to commit
district resources.
The district was cited for its
timeline compliance in the CPR
of 2003 under SE 9 and SE
18B. Please see SE 9 for
comment.
Documentation
The districted has contracted
translators in Albanian, Spanish,
and Portuguese. The district
also contracted language service
for low incidence needs. An IEP
translated into Portuguese was
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 3 of 19
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
Approved
Corrective
Action
Implemente
d 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
reviewed. Samples of translated
notices announcing parenttraining workshops were
provided to the Department as
well.
Documentation
& Interviews
The district provided a copy of
its 2006-2007 District
Curriculum Accommodation
Plan. The DCAP was
disseminated and reviewed with
staff at each building,
SE 54
Professional
Development
Documentation
& Staff
Interviews
The district has developed a
DCAP and has conducted
extensive staff training on
inclusion strategies with a more
recent focus on inclusion
strategies for children within the
Autistic Spectrum.
SE 55
Facilities
Documentation
& Staff
Interviews
The district’s documentation
indicated that special education
facilities and classrooms are
located within the district’s
schools. Substantially separate
classrooms for LD populations
and students with Autism
Spectrum Disorders are located
in the district’s newest schools
SE 50
DCAP
Yes
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 4 of 19
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
Approved
Corrective
Action
Implemente
d 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 facilitate inclusion into the
general education milieu. Staff
interviews indicated that
substantially separate programs
are housed among the regular
education classrooms.
SE 6 ##1 - 3
Determination
of Transition
Services
Yes
Student Record
Review &
Documentation
Documentation indicates that the
district has instituted the use of the
transition-planning chart to assist
in planning the transition services
for students. Student records,
district documentation and
individual IEPs documented
Chapter 688 referrals.
For young children, the district
transitions children from Early
Intervention and develops IEPs.
The district has actively engaged
in professional development
activities to improve transition
planning, activities and goal
development. A component of the
district’s training included
reviewing current state and federal
standards.
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 5 of 19
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
SE 8
IEP Team
composition
and attendance
Yes
Student Record
Review,
Documentation
and Staff
Interviews
The student records reviewed by
the Department indicated that the
required Team members attend
initial, re-evaluation and annual
review meetings. The district has
actively trained chairpersons on
the requirements of Team member
attendance and the circumstances
and process that must be used to
excuse a member from
participation.
SE 12
Frequency of
re-evaluation
Yes
Student Record
Review &
Documentation
The student record review
indicated that students are
evaluated every three years.
Exceptional circumstances were
noted in some of the records
reviewed that indicated some
evaluations were conducted prior
to the three-year mark to address
concerns articulated by the parents
or other Team members.
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
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 6 of 19
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
Yes
Student Record
Review,
Documentation
and Staff
Interviews.
A review of the student records
indicates that progress reports are
issued consistent with the
district’s report card. Gaps in the
sequence of progress reporting
were noted prior to 2005;
however, subsequent progress
reports were issued consistent
with state and federal
requirements. In some instances
past IEP periods indicated that
progress reports were not issued
for all the goals identified on the
student’s IEP. This issue,
however, was not found in the
most recent progress reporting
cycles. Staff interviews indicate
that new monitoring systems were
developed to ensure that service
providers provide the progress
reports to the Team chairpersons
for review.
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 13
Progress
Reports and
content
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 7 of 19
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
SE 14
Review and
revision of
IEPs
Yes
Student Record
Review &
District
Documentation
The student record review
indicated that annual reviews are
conducted and the IEPs are
revised to meet the needs of the
individual students. The district
tracks the completion of annual
reviews through the EasyIEP
monitoring system that alerts staff
of pending annual reviews.
SE 25B
Resolution of
disputes
Yes
Documentation
The district’s documentation
indicated only one instance of a
need to conduct a resolution
meeting since the regulatory
change of requirements was
instituted. The district indicates a
meeting was scheduled but not
held because the matter was
resolved prior to conducting the
resolution meeting.
Criterion
Determined
to be
Partially
Implemented
or Not
Implemented

Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 8 of 19
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
Yes
Student Record
Review &
District
Documentation
IEPs document the student’s
ability to make effective progress
in the non-participation
justification section. District
documentation indicates a
significant number of
paraprofessionals are employed to
assist students and obtain
educational services within the
general education setting. The
district has a Curriculum
Integration Specialist to assist
school personnel in involving
students in the general curriculum.
Student
Record,
Documentation
& Staff
Interviews
The district’s documentation
indicated that school personnel
have communicated with the local
administrators of private schools
within the district. The district has
evaluated students with private
schools and is currently serving
students within four private
schools. The district provides
Massachusetts students with an
individual entitlement and has also
calculated its federal proportional
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 33
Involvement in
the General
Curriculum
SE 39A
Procedures for
services to
eligible private
school students
whose parents
reside in the
district
(SE 39A does
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 9 of 19
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
expenditures to ensure
compliance. The student record
review verified the district’s
implementation practices.
not apply to
charter schools
or vocational
schools)
Criterion
Number
and
Topic
Special
Education
Criteria
created or
revised in
response to
IDEA-2004
SE 39B
Procedures for
services to
eligible
students in
private schools
in the district
whose parents
reside out of
state
Criterion
Implemented

Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Documentation
The district is aware of the
requirements for the provision of
services for students whose
parents reside out of state. At this
time, the district does not have
any students with parents living
out of state that are intended indistrict private schools.
Student
Records, Staff
District documentation indicated
that staff members are trained in
Criterion
Partially
Implemented
or Not
Implemented

Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
(SE 39B does
not apply to
charter schools
or vocational
schools)
SE 46
Procedures for
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 10 of 19
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
suspension of
students with
disabilities
more than 10
days
Interviews &
Documentation
the procedures for the suspension
of students with disabilities. Each
school within the district tracks
individual student suspensions.
Documentation of manifestation
determinations conducted by
school personnel demonstrated
understanding of the procedures
for suspension and the procedures
for conducting a manifestation
determination. District principals,
housemasters, chairpersons and
psychologists have attended
updated training of student
discipline procedures under IDEA
2004.
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 11 of 19
Peabody Public Schools
English Learner Education (ELE) Requirements
Mid-Cycle Review Findings and Corrective Action Based on the Department’s Review Of Local Self-Assessments
(Please refer to full text of 2006-2007 CPR requirements for ELE and related implementation guidance at
http://www.doe.mass.edu/pqa/review/cpr/instrument/chapter71A.doc)
ELE
Criterion
Number
and
Topic
ELE 1
Annual
Assessment
Criterion Determined
to be Implemented
Based on Review of
Local ELE SelfAssessment

Implemented
ELE 2
MCAS
Participation
Implemented
ELE 3
Initial
Identification
Implemented
ELE 4
Waiver
Procedures
Findings of Noncompliance Based on Department’s
Review of Local ELE Self-Assessment
(Criterion Determined to be Partially Implemented or Not
Implemented)
Implemented
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 12 of 19
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 SelfAssessment

ELE 5
Program
Placement
and Structure
Partially Implemented
ELE 6
Program Exit
and
Readiness
Implemented
ELE 7
Parent
Involvement
Implemented
ELE 8
Declining
Entry to a
Program
ELE 9
Instructional
Grouping
Findings of Noncompliance Based on Department’s
Review of Local ELE Self-Assessment
(Criterion Determined to be Partially Implemented or Not
Implemented)
The district is in process of developing a complete SEI program
structure. Students are provided English Language
Development (ELD) instruction. Professional development is
being provided to staff in the Department’s four categories of
training; however, the district has not completed sufficient
professional development to ensure SEI at all school levels.
Existing ESL staff levels are insufficient to meet the needs of
the district’s LEP populations English Language Development.
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
The district will identify teachers at each school
that have received professional development in
order to implement Sheltered English Immersion.
The district must identify the teachers at each
building, their current licensure status and the
amount of training by category for each teacher.
The district will provide the progress report by
November 30, 2007.
Implemented
Implemented
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 13 of 19
ELE
Criterion
Number
and
Topic
Criterion Determined
to be Implemented
Based on Review of
Local ELE SelfAssessment

ELE 10
Parental
Notification
Implemented
ELE 11
Equal Access
to Academic
Programs
and Services
Implemented
ELE 12
Equal Access
to
Nonacademic
and
Extracurricular
Programs
Implemented
ELE 13
Follow-up
Support
Partially Implemented
ELE 14
Licensure
Partially Implemented
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
The district’s follow-up monitoring is consistent with the
practices identified in ELE 6. What is not clear with regards to
students who need follow-up support is what kinds of English
Language Development support is made available. It is unclear
if these students receive pullout or tutorial support from ELL
personnel.
The district will identify the type and frequency of
follow-up support for students identified as FLEP.
The district will provide its progress report to the
Department by November 30, 2007.
Currently, the district has an ELL coordinator credentialed as an
ESL teacher and administration. The coordinator is a certified
trainer of category one and two training and has received
Please see ELE 5 for the required corrective action.
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 14 of 19
ELE
Criterion
Number
and
Topic
Requirements
Criterion Determined
to be Implemented
Based on Review of
Local ELE SelfAssessment

Findings of Noncompliance Based on Department’s
Review of Local ELE Self-Assessment
(Criterion Determined to be Partially Implemented or Not
Implemented)
category four professional development. The district indicated it
intends to increase its capacity of qualified trainers.
Three ESL certified teachers are located at the high school and
one licensed ESL teacher is located at the middle school Two
certified ESL teachers and a licensed tutor are employed at the
elementary level. The district is actively engaging general
educators and its non-certified tutors and providers in the
Department’s four categories of training. However, current
licensed staffing levels are inadequate to meet the needs of the
320 Limited English Proficient students identified by the
district.
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 15 of 19
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 SelfAssessment

ELE 15
Professional
Development
Requirements
The district is actively
training staff in the four
categories of training
identified by the
Department of
Elementary and
Secondary Education.
The district has trained
over 30 staff members as
Qualified MELA-O
administrators. The
district provided its
training roster and
attendance sheets for
teacher that participated
in the category 1 training.
The district continues to
offer and encourage
professional development
in the four categories of
training. Samples of
course and professional
development offerings
were provided to the
Department for review.
ELE 16
Equitable
Facilities
Findings of Noncompliance Based on Department’s
Review of Local ELE Self-Assessment
(Criterion Determined to be Partially Implemented or Not
Implemented)
Implemented
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 16 of 19
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
ELE
Criterion
Number
and
Topic
ELE 17
Program
Evaluation
Criterion Determined
to be Implemented
Based on Review of
Local ELE SelfAssessment

Implemented
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 18
Records of
LEP
Students(To be
reviewed
during next
CPR visit.)
Mid-cycle Report Format 2007.doc
Rev. 1/3/07
Peabody Public Schools Coordinated Program Review 2007 Mid-cycle Report
September 7, 2007
Page 17 of 19