The Commonwealth of Massachusetts
Department of Education
350 Main Street, Malden, Massachusetts 02148-5023
Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
August 15, 2006
Jessica G. Waugh
Superintendent
Provincetown Public Schools
2 Mayflower Lane
Provincetown, MA 02657
Re: Mid-cycle Coordinated Program Review Report
Dear Superintendent Waugh:
Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report (MidCycle Report). This report contains findings based on onsite monitoring conducted to verify the
implementation and effectiveness of corrective action approved by the Department to address
findings of noncompliance included in the Provincetown Public Schools Coordinated Program
Review Report issued on August 25, 2003. The Mid-cycle Report also contains findings based
on onsite monitoring of special education compliance criteria that have been newly created or
substantially changed in response to IDEA 2004.
As you know, 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 documents and, based solely on that selfassessment, is providing you in this report with comments on your ELE program and, where
necessary, corrective action to be implemented. Your district is urged to request technical
assistance in relation to any of these comments or prescribed corrective action. To secure
assistance, you may consult with your Mid-cycle Review Chairperson. You may also consult with
staff in the Department’s Office of Language Acquisition and Achievement at 781-338-3534 and
obtain additional ELE guidance documents through the Department’s web site at
http://www.doe.mass.edu/ell/ .
While the Department of Education found your district to have resolved most noncompliance
issues, others were partially corrected or not addressed at all, or the Department’s onsite team
identified new issues of noncompliance, either noncompliance with special education criteria
added or substantially changed in response to IDEA 2004, noncompliance with ELE criteria, or
other new noncompliance.
1
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 school district within the
timelines specified. Your statement of assurance must be submitted to the Mid-cycle Review
Chairperson by Thursday, September 14, 2006.
Your staff's cooperation throughout these follow-up monitoring activities is appreciated. Should
you like clarification of any part of our report, please do not hesitate to contact the Mid-cycle
Review Chairperson at 781-338-3726.
Sincerely,
Thomas Taylor, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
Terese Nelson, School Committee Chairperson
Mr. Anthony Teso, District Program Review Follow-up Coordinator
Encl.: Mid-cycle Coordinated Program Review Report
Mid-cycle Cover Letter 2006.doc
Rev. 6/5/06
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
Provincetown Public Schools
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL NONCOMPLIANCE REQUIRING CORRECTIVE ACTION
Date of Coordinated Program Review (CPR): May 12-16, 2003
Date of Coordinated Program Review Corrective Action Plan Approval: October 6, 2003
Dates of Corrective Action Plan Progress Reports: November 30, 2003
Dates of this Mid-cycle Review Onsite Visit: May 22 and 23, 2006
Date of this Report: August 15, 2006
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 1 of 16
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective

Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
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
Education
Criteria
Originally
Cited in CPR
Report and
Monitored in
Mid-cycle
SE 3
Determining
Specific
Learning
Disabilities

SE 4
Reports of
Assessment
Results

Documentation
and Staff
Interviews
Student Record
Review,
Documentation
and Staff
Interviews
The district has hired a
school psychologist. This
has eliminated the confusion
concerning the determination
of specific learning
disabilities. Also, the school
psychologist conducts staff
training on assessments and
determining eligibility.
Team meetings always have
in attendance a staff member
to commit the district
resources.
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 2 of 16
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 6
Determination
of transition
services
SE 8
IEP
composition
and attendance
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Student Record
Review,
Documentation
and Staff
Interviews
The student record review
indicates that Teams
considerthe parent and
student input into transition
planning. Students age 15
years or older are invited and
attend Team meetings.
Students do have a
Transition Plan.
Student Record
Review and
Staff Interviews
Team attendance sheets
indicate that required
personnel are attending Team
meetings. Representatives
from public agencies are
invited and attending Team
meetings when appropriate.



Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 3 of 16
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 9
Timeline for
determination
of eligibility
and provision
of
documentation
to parent
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Student Record
Review and
Staff Interviews
The district has a monitoring
procedure in place to track
timelines. Student records
indicate that the provision of
the IEP and eligibility
notices are given to the
parents within 3 school
working days.


Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 4 of 16
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 12
Frequency of
re-evaluation
SE 13
Progress
reports and
content
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Student Record
Review and
Documentation
The district has indicated
through documentation that
three-year re-evaluations are
substantially completed on
time.
Student Record
Review and
Documentation
Progress Reports included
information on the progress
of the student that would
indicate sufficient progress in
the IEP goals by the end of
the year. Related service
providers have submitted
goals and benchmarks on the
progress reports. Also,
progress reports were
completed with the report
card cycle.



Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 5 of 16
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
SE 14
Review and
revision of
IEPs
SE 15
Outreach by
the school
district
(Child Find)
Approved
Corrective
Action
Determined
to be
Implemented
and Effective
Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective


Student Record
Review,
Documentation
and Staff
Interviews

Documentation
and Staff
Interviews
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective Or
Basis of Finding of New
Noncompliance
The onsite team found that
the district conducts initial,
annual, and re-evaluations
within the timelines and a log
is used to track them.
The district has submitted
documentation to verify that
they utilize a variety of
avenues to conduct outreach
to all required groups within
the community.
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 6 of 16
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number
and
Topic
Criterion
Implemen
ted

Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Student Record
Review,
Documentation
and Staff
Interviews
The district is evaluating young
children exiting Early
Intervention and providing
services to young children by
their third birthday.
Student Record
Review
Parent concerns and vision for
the student are documented in
the IEP. The district has clearly
designated personnel that are
able to commit the district
resources and attend Team
meetings.
(Refer to full
text of 20052006 CPR
requirements)
Special
Education
Criteria created
or revised in
response to
IDEA-2004
SE 17
Initiation of
services at age
three and Early
Intervention
transition
procedures
SE 18A #1 and
#2
IEP
development
and content


Criterion
Determined
to be
Partially
Implemented
or Not
Implemented

Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 7 of 16
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
SE 20
Least restrictive
program
selected
SE 25B
Resolution of
disputes
SE 30
Notice of
procedural
safeguards
SE 32
Parent advisory
council for
special
education
SE 34
Continuum of
alternative
services and
placements




Partial
Student Record
Review and
Staff Interviews
The onsite team found special
education students on all levels
attending regular education
classes with modification to the
curriculum as indicated on their
Individual Education Program.
Student Record
Review and
Documentation
The district has a policy and
procedure in place to address
resolution of disputes and the
15-day requirement to convene
the Team for resolution of the
dispute.
Student Record
Review and
Documentation
The district provides the Notice
of Procedural Safeguards to the
parent and it is documented in
the student record.
Documentation
and Staff
Interviews
The Parent Advisory Council
(PAC) continues to be a
challenge to generate
membership. The fact that the
district has a large School
Choice student population
contributes to this challenge.
The district has a PAC and
continually provides outreach to
the special education parents.
Student Record
Review and
Documentation
The district provides a
continuum of services to their
special education population
including related services,
vocational offerings and
alternative placements.
Partial
See SE 49
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 8 of 16
See SE 49
SE 35
Specialized
material and
assistive
technology
SE 36
IEP
implementation
accountability
and financial
responsibility
SE 37
Procedures for
approved and
unapproved
out-of-district
placements
SE 46
Procedures for
suspension of
students with
disabilities
more than 10
days

Partial
Student Record
Review and
Documentation
Student Record
Review
The onsite team has determined
that students that require
specialized materials and/or
assistive technology receive
those services.
The student record indicates that
the IEP is implemented without
delay upon parent consent.

Student Record
Review and
Documentation
The district has a procedure for
approved and unapproved outof-district placements and that
these placements are monitored.
The onsite team found all
students were appropriately
placed.

Student Record
Review and
Documentation
The district has in place a policy
and procedure to address
suspensions for students with
disabilities more than 10 days.
The policy includes suspension
logs kept by the special
education department,
behavioral intervention plans,
functional behavior assessments
and manifestation
determinations.
See SE 49
Partial
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 9 of 16
See SE 49
SE 49
Related services
Partial
Student Record
Review and
Staff Interviews
See comments to the right
SE 54
Professional
development
regarding
special
education

Documentation
and Staff
interviews
The district provides a variety of
professional development
opportunities including five
professional development days.
Professional and
paraprofessional staffs attend
joint trainings. The district
provides training in the required
areas of professional
development.
Partial
The district is still
experiencing difficulty
with recruiting and
maintaining qualified
speech and language
service providers. The
district has continued to
try and recruit qualified
staff without success. The
district is aware of the
need for compensatory
services when speech and
language services aren’t
provided as indicated on
the student IEP.
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 10 of 16
The district will provide a
more aggressive plan for
recruiting and hiring qualified
speech and language staff
and/or a means to contract for
those services from other
districts or private providers.
Please provide this plan or
evidence of having hired or
contracted for those services by
Monday, October 30, 2006.
In addition, a review of all
IEPs with speech and language
goals and speech and language
service delivery logs for the
’05-’06 school year must be
made to determine which
students may be entitled to
compensatory services. This
review, along with the
evidence that the elements of
603 CMR 28.06 (2)(d)(2) has
been initiated for the ’06-’07
school year, must be provided
to the Department by Monday,
October 30, 2006.
Criterion
Number
and
Topic
(Refer to full
text of 20052006 CPR
requirements)
MOA 4
Disproportionality
[included in
this report if
the CPR
report
included a
finding under
MOA 4 of
noncompliance
with respect to
racial/ethnic
distribution in
special ed,
special ed
placements, or
disability
categories]
MOA 17A
Use of physical
restraint
Approved
Corrective
Action
Determine
d to be
Implement
ed and
Effective



Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Review of data
reports
The review of the district’s data
indicates that any
disproportionate representation
in populations are too low in
number to be statistically
relevant.
Documentation
and Staff
Interviews
The onsite team found that staff
are aware of the physical
restraint policy and the district
has publicized policies and
procedures.
Corrective
Action
Determined
Not to have
been
Implemented
or Not to
have been
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective
Or
Basis of Finding of New
Noncompliance
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 11 of 16
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Requirements
MOA 22
Accessibility of
district
programs and
services for
students with
limited
physical
mobility
MOA 24
Curriculum
review process

Staff Interviews
and
Observations
The onsite team found that both
school buildings are accessible
for students with limited
physical mobility.

Documentation
and Staff
Interviews
The district does have a
curriculum review process in
place to meet the provisions of
this criteria.
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 12 of 16
Provincetown Public Schools
English Learner Education (ELE) Requirements
Mid-Cycle Review Comments and Corrective Action Based on the Department’s Review Of Local Self-Assessments
(Please refer to full text of 2005-2006 CPR-ELE legal requirements 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
Comments Based on the Department’s Review of Local
ELE Self-Assessment
The district utilizes the MCAS and MEPA for assessment
instruments. The district has provided no evidence that the
MELA-O is used.
ELE 2
MCAS
Participation
The district has administered the MCAS to all limited English
proficient students.
ELE 3
Initial
Identification
The district provides home language surveys. However, the
district doesn’t provide any initial identification testing.
ELE 4
Waiver
Procedures
ELE 5
Program
Placement and
Structure
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
The district must submit two samples of student records demonstrating the use of
the MELA-O to assess the oral competency of LEP students in grades K-12.
The district must respond to the Department by Monday, October 30, 2006.
The district must submit two samples of student records that demonstrate other
means of initially identifying LEP students in addition to the home language
survey. Also, the home language survey should be in the language of the home
as well as English. The district must respond to the Department by Monday,
October 30, 2006.
The district has developed a waiver procedure and has
translated documentation regarding program descriptions and
waiver practices.
The district uses the Sheltered English Immersion (SEI)
model. However, there is no evidence of training for staff
other than the ELE Coordinator. The content instruction is
based on the Massachusetts Curriculum Frameworks. There
The district needs to demonstrate that staff members working with LEP students
are trained in sheltered English immersion. The district must submit signed staff
attendance sheets and training agendas or a plan for this training to take place
during the ’06-’07 school year. The district must respond to the Department by
Monday, October 30, 2006.
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 13 of 16
ELE Criterion
Number
and
Topic
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
is no evidence that the English language development
instruction is based on the English Language Proficiency
Benchmarks and Outcomes.
ELE 6
Program Exit
and Readiness
ELE 7
Parent
Involvement
ELE 8
Declining Entry
to a Program
ELE 9
Instructional
Grouping
ELE 10
Parental
Notification
There is no evidence that students who are limited English
proficient (LEP) are exited from the program upon their
readiness and offered language support.
The district must submit data indicating classroom performance and assessment
results from the MELA-O, MEPA, LAS-O, and LAS/RW for the two students
that were exited from the ELE program in order to determine that the students
were exited appropriately and designated as formerly limited English proficient
(FLEP). The district must respond to the Department by Monday, October 30,
2006.
The district did not provide any evidence of parental
involvement of parents or guardians of LEP students in
matters that pertain to their children’s education.
The district must document its efforts to solicit parent participation. For example
what written notifications were provided to parents of LEP students to participate
in school councils? The district must respond to the Department by Monday,
October 30, 2006.
The district did not provide evidence that language support
was provided to those students whose parents declined entry
to sheltered English immersion, two-way bi-lingual, or other
ELE programs. Through staff interviews it was determined
that the ELE Coordinator is the only ESL trained staff
member and the Spanish teacher provides support.
The district must clarify what options exist for students of parents who do not
wish their child to be enrolled in the SEI classrooms. Describe what alternatives
exist to provide these students with support. The district must respond to the
Department by Monday, October 30, 2006.
The district does provide appropriate instructional groupings
for LEP students. The districts groupings ensure that LEP
students receive instruction at appropriate academic levels.
The district did not provide the onsite team with copies of
notifications sent to parents of LEP students written in the
primary/home language, as well as in English.
The district must provide copies of its English and other language written
notifications to parents. The district must respond to the Department by Monday,
October 30, 2006.
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 14 of 16
ELE Criterion
Number
and
Topic
ELE 11
Equal Access to
Academic
Programs and
Services
ELE 12
Equal Access to
Nonacademic
and Extracurricular
Programs
ELE 13
Follow-up
Support
ELE 14
Licensure and
Fluency
Requirements
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
The district through documentation and student record review
has demonstrated to the onsite team that LEP students have
equal access to all academic and extra-curricular programs
and services. Announcements of academic, nonacademic and
extra curricular programs and services in the native languages
have been provided to the onsite team.
The district through documentation and student record review
has demonstrated to the onsite team that LEP students have
equal access to all academic and extra-curricular programs
and services. Announcements of academic, nonacademic and
extra curricular programs and services in the native languages
have been provided to the onsite team.
The district did not provide the onsite team with any evidence
that follow up support was provided to LEP students. The
district lacked a plan to monitor students who have exited
English learner education programs.
There is insufficient information provided by the district on its follow up
procedures. The district is to identify which staff members are designated to
conduct the follow up. Describe how the follow up is documented and by whom.
The district must develop a formalized process for the monitoring of FLEP
students. The district must respond to the Department by Monday, October 30,
2006.
The district employs only one English language learner staff
member. The ELE Coordinator is the only staff member
appropriately licensed. The district has a very small LEP
population identified.
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 15 of 16
ELE Criterion
Number
and
Topic
Comments Based on the Department’s Review of Local
ELE Self-Assessment
Required Corrective Action, Timelines for Implementation, and Progress
Reporting
ELE 15
Professional
Development
Requirements
The district has not diligently provided professional
development for all staff instructing LEP students. The ELE
Coordinator has received professional development and has a
professional development plan.
The district is advised to have a district wide goal to train instructional staff in
assessment instruments and sheltered English immersion instruction. The district
must provide the Department with signed attendance sheets and workshop
agendas. The district must respond to the Department by Monday, October 30,
2006.
ELE 16
Equitable
Facilities (To be reviewed
during next
CPR visit)
Through staff interviews, observation and documentation the
district has demonstrated to the onsite team that all facilities,
materials and services provided to LEP students are
comparable to those provided to the overall student
population.
ELE 17
DOE Data
Submission
Requirements
and Program
Evaluation
ELE 18 Records
of LEP
Students(To be reviewed
during next
CPR visit.)
The district has not done a self -evaluation of ELE
programming. The district has not utilized the Department
data to evaluate the ELE program.
The district must demonstrate how data is used to evaluate the effectiveness of
the ELE program. Please submit the self-evaluation material to the Department
by Monday, October 30, 2006.
The Department did not review student records for ELE
students during the Mid-cycle Review. ELE student records
will be reviewed during the next Coordinated Program
Review.
Mid-cycle Report Format 2006.doc
Rev. 6/5/06
Provincetown Public Schools Coordinated Program Review Mid-cycle Report
August 15, 2006
Page 16 of 16