Mitchell D. Chester, Ed.D.
Commissioner of Elementary and Secondary Education

SE Criterion # 7 - Transfer of parental rights at age of majority and student participation and consent at the age of majority
Rating:
Partially Implemented
Basis for Findings:
Student record review demonstrated that the district does not notify parents and students of the transfer of educational decision-making rights one year prior to students reaching the age of 18. Additionally, student records indicated that the district does not consistently obtain the student’s consent to continue his or her special education program once the student has reached the age of majority.
Department Order of Corrective Action:
Using the district’s database, develop a sample of approximately 10-15 special education students who turned 17 between January 2013 and April 2013. Cross-reference this sample with the students’ special education records for evidence of notification to students and their parents of the transfer of educational decision-making rights to the student upon attainment of the age of majority. Based on the results of this 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.
Conduct a second review of student records. Please select a sample of 8-10 high school student records drawn from those students who turned 18 after implementation of all corrective actions for evidence that 1) families and students are notified one year prior to the student turning 18 and 2) consent is obtained from the educational-decision maker to continue the then current special education program.
*Please note that 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 level 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).
Required Elements of Progress Reports:
Submit the results of the analysis conducted of records for students who turned age 17 between January 2013 to April 2013. Include a description of the root cause analysis, the steps taken to correct the noncompliance, and the associated timelines. This progress report is due October 28, 2013.
Submit the results of the second review of student records. Indicate the number of student records reviewed, the number of student records in compliance, for all records not in compliance with this criterion, determine the root cause(s) of the noncompliance and provide the school ’s plan to remedy the non-compliance. This progress report is due March 3, 2014.
Progress Report Due Date(s):
10/28/2013 03/03/2014
Massachusetts Department of Elementary & Secondary Education – Program Quality Assurance Services
Peabody Mid-Cycle Report – September 10, 2013 02:27:43 PM
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SE Criterion # 8 - IEP Team composition and attendance
Rating:
Implemented
Basis for Findings:
A review of student records and staff interviews indicated that the district ’s IEP Teams are consistently convened with all required members in attendance. When a required Team member cannot participate in an IEP Team meeting, the district secures written parent permission prior to the meeting to excuse the Team member. In addition, the excused required Team member provides a written report in advance for the IEP Team to use in developing or reviewing the IEP. If the parent does not wish to convene the IEP Team meeting without the required member, the district reschedules the meeting. Staff interviews indicated that the district and parent agree in writing when excusing Team members who are not necessary because their area of the curriculum or services is not being modified or discussed.
SE Criterion # 18A - IEP development and content
Rating:
Implemented
Basis for Findings:
Document and student record review demonstrated that when a student's evaluation data indicates that his/her disability affects social skills development or makes them susceptible to bullying, harassment, or teasing, the district’s IEP Teams address the skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing in the student’s IEP.
Document and student record review also demonstrated that for students identified with a disability on the autism spectrum, the district’s IEP Teams specifically address the students’ social skills and communication challenges with peers and staff in the student’s IEP.
SE Criterion # 18B - Determination of placement; provision of IEP to parent
Rating:
Implemented
Basis for Findings:
Student records indicate that the district routinely provides parents with two (2) copies of the proposed IEP and proposed placement along with the required notice immediately following the development of the IEP.
Massachusetts Department of Elementary & Secondary Education – Program Quality Assurance Services
Peabody Mid-Cycle Report – September 10, 2013 02:27:43 PM
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SE Criterion # 22 - IEP implementation and availability
Rating:
Implemented
Basis for Findings:
Document review verified that counseling on IEPs is consistently provided in the amount indicated by the service delivery grids. Interviews confirmed that the district has increased staffing to deliver counseling services as prescribed by IEP Teams. Interviews also confirmed that in the event that there is a delay in services due to a lack of personnel, the district immediately informs the parent in writing of the delay, the actions that the school district is taking, and offers alternative methods to meet the goals on the accepted IEP.
SE Criterion # 24 - Notice to parent regarding proposal or refusal to initiate or change the identification, evaluation, or educational placement of the child or the provision of FAPE
Rating:
Implemented
Basis for Findings:
Student record review verified that the district consistently documents the evaluation procedures, tests, records or reports used as a basis for its proposed actions in the district’s
Notices of Proposed School District Action (N1) to parents.
SE Criterion # 25 - Parental consent
Rating:
Implemented
Basis for Findings:
Document review demonstrated that the district ’s procedures require that the parent revoke consent for special education services in writing. Upon receiving the parent ’s written request, the district will immediately send a notice indicating that the student ’s special education services will be discontinued within a reasonable period of time and where parents can obtain a copy of procedural safeguards.
Document review and staff interviews indicate that these procedures also state that the district will not use mediation or request a due process hearing to obtain agreement or a ruling requiring the continuation of services.
At the time of the onsite review, the district did not have any current records for revocation of consent.
SE Criterion # 26 - Parent participation in meetings
Rating:
Implemented
Basis for Findings:
The district submitted a copy of its special education roster as required by the MCR.
Massachusetts Department of Elementary & Secondary Education – Program Quality Assurance Services
Peabody Mid-Cycle Report – September 10, 2013 02:27:43 PM
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SE Criterion # 29 - Communications are in English and primary language of home
Rating:
Partially Implemented
Basis for Findings:
Student record review found that translated documents for parents whose primary language is not English are not consistently found in student records.
Department Order of Corrective Action:
Please ensure the parents of the students identified by the Department in the Student Record
Issues Worksheet receive special education documents and notices in their primary language.
Using the district’s database, develop a sample of approximately 10-15 students whose families are identified as needing translations and who were engaged in special education activities between January 2013 and April 2013. Cross-reference this sample with the students’ special education records for evidence of consistent provision of information in the families’ primary language. 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.
Conduct a second review of 10 records of students from a crosssection of the district’s schools whose parents’ primary language is not English for evidence that documents are translated. This sample must be drawn from those records with IEP meetings convened after all corrective actions have been implemented.
Required Elements of Progress Reports:
Submit the evidence of completion for those students identified by the Department in the
Student Record Issues Worksheet. This progress report is due October 28, 2013.
Submit the results of the root cause analysis. Include the number of 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 October 28, 2013.
Submit the results of the second review of student records following implementation of all corrective actions. Indicate the number of student records reviewed, the number of student records in compliance, for all records not in compliance with this criterion, determine the root cause(s) of the noncompliance and provide the school’s plan to remedy the non-compliance.
This progress report is due March 3, 2014.
*Please note that 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 level 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).
Progress Report Due Date(s):
10/28/2013 03/03/2014
Massachusetts Department of Elementary & Secondary Education – Program Quality Assurance Services
Peabody Mid-Cycle Report – September 10, 2013 02:27:43 PM
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SE Criterion # 37 - Procedures for approved and unapproved out-ofdistrict placements
Rating:
Implemented
Basis for Findings:
A review of student records found that the district provides contracts for students placed in special education day programs, including students attending the North Shore Collaborative.
SE Criterion # 43 - Behavioral interventions
Rating:
Implemented
Basis for Findings:
Staff interviews and student record review confirmed that the IEP Team routinely considers the student's behavioral needs, including positive behavioral interventions, in the development of the IEP.
Massachusetts Department of Elementary & Secondary Education – Program Quality Assurance Services
Peabody Mid-Cycle Report – September 10, 2013 02:27:43 PM
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SE Criterion # 46 - Procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district
Rating:
Partially Implemented
Basis for Findings:
Student record review demonstrated that the district conducts manifestation determinations for students with disabilities after in-house suspensions are considerably beyond 10 consecutive or cumulative days and/or several weeks after the 10 th day of suspension is accrued.
Document review demonstrated that although the district submitted procedures for in-house and external suspension of students with disabilities when suspensions exceed 10 days, the district’s currently posted high school handbook contains a process that is not consistent with federal requirements and that is different from the submitted policy. In addition, record review demonstrated that the district is not following either set of procedures when suspending students with disabilities beyond 10 days.
Department Order of Corrective Action:
Using the district’s suspension database, develop a sample of approximately 10-15 high school students with disabilities who have received in-house suspensions beyond 10 days between January 2013 and May 2013. Crossreference this sample with the students’ special education records for evidence that the district has conducted manifestation determinations prior to the suspension that constitutes a change in placement for a student with disabilities.
Based on the results of the analysis, provide the district’s determination of the root cause(s) of the non-compliance, the steps the district proposes to take to correct the root causes, and a timeline for the implementation of those corrections.
Provide a detailed plan to revise the district’s suspension policy for students with disabilities beyond 10 days; this plan must include a review of the high school handbook discipline policy for students with disabilities as well as training for high school administration and special education staff on the revised policy.
Conduct a second review of student records. Please select a sample of five to six student records drawn from students who have received 10 consecutive or cumulative in-house suspensions for evidence that the district has conducted a manifestation determination prior to the suspension that constitutes a change in placement. This sample of records must be drawn from those students who have received in-house suspensions after all corrective actions have been implemented.
Upon completion of the district’s corrective action activities, the Department will conduct an onsite review of student records. This onsite visit will be scheduled during the 2013- 2014 school year.
Required Elements of Progress Reports:
Submit the results of the root cause analysis. Include the number of 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 October 28, 2013.
Massachusetts Department of Elementary & Secondary Education – Program Quality Assurance Services
Peabody Mid-Cycle Report – September 10, 2013 02:27:43 PM
Page 7 of 8

SE Criterion # 46 - Procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district
Submit the revised suspension policy and evidence of staff training, including signed attendance sheets with the name and role of the staff member, agendas, and the training materials by October 28, 2013.
Submit the results of the second review of student records. Indicate the number of student records reviewed, the number of student records in compliance, for all records not in compliance with this criterion, determine the root cause(s) of the noncompliance and provide the school’s plan to remedy the non-compliance. This progress report is due March 3, 2014.
*Please note that 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 level 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).
Progress Report Due Date(s):
10/28/2013 03/03/2014
SE Criterion # 48 - FAPE (Free, appropriate, public education): Equal opportunity to participate in educational, nonacademic, extracurricular and ancillary programs, as well as participation in regular education
Rating:
Implemented
Basis for Findings:
Staff interviews and review of student schedules verified that students with disabilities who are also identified as English language learners have access to an English Language
Education program consistent with the requirements of M.G.L. c. 71A.
SE Criterion # 55 - Special education facilities and classrooms
Rating:
Implemented
Basis for Findings:
A review of documents verified that the district has been granted public day school approval for the Community High School program located at the Higgins Middle School. A review of student schedules and interviews with the superintendent verified that students enrolled in the
Eagles Middle School therapeutic classroom are integrated into the life of the school with regular education peers. A facility review of the Brown and Center Elementary Schools confirmed that signs identifying special education classrooms have been removed.
Massachusetts Department of Elementary & Secondary Education – Program Quality Assurance Services
Peabody Mid-Cycle Report – September 10, 2013 02:27:43 PM
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