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 February 15, 2006 Carol M. Jacobs, Superintendent Quaboag Regional School District 48 High Street Warren, MA 01083 Re: Mid-cycle Coordinated Program Review Report Dear Superintendent Jacobs: Enclosed is the Department of Education's Mid-cycle Coordinated Program Review Report. This report contains findings based on onsite monitoring activities conducted to verify the implementation status and effectiveness of corrective action activities approved by the Department that were intended to address findings of noncompliance included in the Quaboag Regional School District Coordinated Program Review Report issued on July 16, 2003. (In the remainder of this letter, please read “district” as meaning “regional school district.”) As you know, one component of the Department’s Mid-cycle Review process is the review of your district's self-assessment in the area of English learner education (ELE). The purpose of this activity is to determine if your district is beginning to implement the significant changes in M.G.L. Chapter 71A, this state’s law governing the education of limited English proficient students that was adopted by voters as Question 2 in 2002. The Department has reviewed your district’s ELE self-assessment documents and is providing you now with advisory comments and actions to be implemented in anticipation of your district’s next scheduled Coordinated Program Review. Where indicated in our report, your district is urged to request technical assistance in areas that, based solely on your self-assessment documents, were found not likely to be fully implemented. To secure assistance, you may consult with your Mid-cycle Review Chairperson or call Robyn Dowling-Grant in Program Quality Assurance Services at 781-3383732. 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/ . The onsite team would like to commend the following areas that were brought to its attention and that the team believes have a significant and positive impact on the delivery of educational services for students enrolled in the Quaboag Regional School District. These areas are as follows: The administration, faculty and staff of the Quaboag Regional School District are committed to individual student success. The district has a uniform protocol that all Special Education Team Chairs follow. IEP’s for elementary students are individualized and contain clear, measurable goals including the use of video tape to record student baseline where appropriate. Elementary student IEP progress reports are individualized and relate to the goals and portions of benchmarks that apply to the reporting period. Secondary student transition needs are regularly discussed and addressed through the IEP process. The district provides comprehensive services for students transitioning to adult services. The district’s District Curriculum Accommodation Plan (DCAP) is a document that is known and used by all staff members to provide support services to all students. While the Department of Education found certain noncompliance issues to be resolved, others were partially corrected, not addressed at all and/or the Department’s onsite team identified new issues of noncompliance. In areas where the district has failed to implement fully its approved Corrective Action Plan, the Department views these findings to be serious. As the Department previously informed you, in cases where a district fails to fully and effectively implement a Corrective Action Plan, which was proposed by your district and approved by the Department, the Department must then prepare a Corrective Action Plan for the district, which must be implemented without further delay. You will find these requirements for corrective action and further progress reporting included in the attached report together with any steps that must be taken by the district to fully implement new special education requirements. Please provide the Department with your written assurance that 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 Department's Onsite Chairperson by February 28, 2006. Your staff's cooperation throughout these Follow-up Monitoring activities is appreciated. Should you require additional clarification of information included in our report, please do not hesitate to contact the Follow-up Team Chairperson at 781-338-3947. Sincerely, Jean E. Jonker, Coordinated Program Review Follow-up Chairperson Program Quality Assurance Services John D. Stager, Administrator Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Lori Landry, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT Quaboag Regional School District ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Date of Coordinated Program Review (CPR): March 5-6, 2003; March 10-13, 2003 Date of Coordinated Program Review Corrective Action Plan Approval: November 5, 2003 Dates of Corrective Action Plan Progress Reports: February 17, 2004,March 17, 2005, June 24, 2004, December 14, 2005, and March 14, 2005 Dates of this Mid-cycle Review Onsite Visit: November 8-10, 2005 Date of this Report: February 15, 2005 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Special Education Requirements (including new IDEA-2004 Requirements Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 1 of 12 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) SE 2 Required and Optional Assessments SE 3 Special requirements for determination of specific learning disabilities SE 6 Determination of Transition Services SE 8 IEP Team composition and attendance SE 12 Frequency of Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Implemented Method(s) of Verification Interviews Student Records Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance All records selected and interviews indicated that the Educational Status Assessment Part A is completed. Not Rated On Hold Documentation Implemented Implemented Implemented Interviews Student Records Documentation Interviews Student Records Documentation Interviews A review of records indicated that 688 forms are completed prior to a student turning 16, and adult agencies are involved in Team meetings. All records selected from the middle and high schools have adequate attendance from general education content area teachers. All records selected indicated that the district conducts a Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 2 of 12 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Student Records re-evaluation SE 13 Progress Reports and content Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Interviews Student Records Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Student record reviews indicated that the district does not always provide parents with progress reports on students’ progress toward reaching the goals set in the IEP at least as often as parents are informed of the progress on non-disabled students and not all reports include all of the student’s goals. The district must ensure that all staff members that complete progress reports receive training on the appropriate completion of progress reports pursuant to this criterion. Ensure that training addresses content of progress reports. Provide the Department with agenda, attendance sheets, and training materials for this training by April 7, 2006. full re-evaluation of the student every three years consistent with the requirements of federal special education law. In some student records, progress reports were appropriately completed; however, this was not always the case at the secondary level. Partially Implemented Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Please provide the Department with a random sample of the IEP goal pages and the last two quarters’ progress reports for 6 students at the middle and high school grade level. Provide this documentation by June 12, 2006. Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 3 of 12 Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Record review and interviews indicated that special education documentation is sometimes translated through an interpreter, when necessary. SE 29 Communications are in English and primary language of the home Partially Implemented Documentation Interviews Student Records Interviews and documentation indicated that the district has resources for accessing interpreter and translation services, when necessary. Documentation indicates that Language Bridge is sometimes contracted to provide some translation services. Documentation indicated that http://www.freetranslation.co m is also a resource that the district uses. Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Documentation and staff interviews indicated that the district does not always use qualified interpreters who are familiar with special education programs, procedures and services. Some individuals listed as translators for Polish listed their expertise as “Born and raised in Poland”, and “owner of bus company. Additionally, the district does not always provide written communications including IEP’s in the primary language of the home. Not all student records that were reviewed that indicated a language other than English was needed are provided with an IEP or Submit a list of the interpreters who are familiar with special education programs, procedures and services used by the district. Include individual qualifications. Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 4 of 12 Submit copies of documents, IEPs and Progress Reports that were provided to parents in the primary language of the home. Include copies of documents, IEP and last 2 progress reports for each translated language. Submit all documentation by April 7, 2006. Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements other documentation in that language. Not all records indicated that a translator was present and what was translated. SE 30 Notice of procedural safeguards SE 32 Parent Advisory Council for Special Education SE 46 Procedures for suspension of students with disabilities more than 10 days Implemented Partially Implemented Implemented Documentation Interviews Documentation Interviews Documentation Interviews The district is providing the 2004 Notice of Procedural Safeguards (formally referred to as Parent’s Rights). The special education Parent Advisory Council meets regularly and has established by-laws. The special education Parent Advisory Council does not serve in an advisory capacity to the school committee on matters that pertain to the education and safety of students with disabilities. Documentation and interviews indicated that the district has developed and implemented procedures for recording and tracking suspensions. Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 5 of 12 Submit evidence that the PAC now serves in an advisory capacity on matters that pertain to the education and safety of students with disabilities to the district by April 7, 2006. Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) SE 50 Responsibilitie s of the Administrator of Special Education MOA 1 Identification of limited English proficient students Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Implemented Implemented Method(s) of Verification Documentation Interviews Student Records Documentation Interviews Student Records MOA 6 Availability of in-school programs for pregnant students Implemented Documentation Interviews MOA 7 Partially Documentation Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements The district has developed and implemented a District Curriculum Accommodation Plan in all school buildings. The district uses qualified staff and appropriate procedures and assessments to identify students who are limited English Proficient and assess their level of English Proficiency. Documentation included an ELL Teacher Resource Handbook. The district’s policy states that pregnant students are permitted to remain in regular education classes. See SE 29 See SE 29 Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 6 of 12 Submit copies of student Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Information to be translated into languages other than English MOA 12A (formerly MOA 11) Notice of nondiscrimination MOA 16 Notice to Students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Implemented Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance Interviews Documentation and interviews indicated that the district has implemented some procedures to provide parents with information in their native language. Implemented Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Documentation Interviews Documentation Interviews Student handbooks do not contain a translated statement in languages other than English that informs parents that handbooks and other information is available in their native language if requested. The district provides annual and continuous notification concerning nondiscrimination and Title IX and Section 504 coordinators. A review of documents and student records provided evidence that the district sends written notice to students and their parents when students are planning to leave school without a high school diploma, certificate of completion or certificate of attainment. Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 7 of 12 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements handbooks that are in languages other than English or copies of student handbooks that do contain a translated statement in languages other than English that informs parents that handbooks and other information is available in their native language if requested by April 7, 2006. Criterion Number and Topic (Refer to full text of 20052006 CPR requirements) Approved Corrective Action Plan Determined to be Substantially Implemented and Effective Or New IDEA Requirements Implemented Method(s) of Verification Basis of Findings Regarding Corrective Action Plan Activities Or Basis of Findings Regarding Implementation of New IDEA Requirements Corrective Action Plan Determined Not Fully Implemented Or Additional Issues Have Been Identified Basis of Findings Regarding Incomplete or Ineffective Implementation of Approved Corrective Action Plan Or Basis of Findings of Additional Noncompliance completion MOA 21 Staff training regarding civil rights responsibilities Implemented Documentation Interviews The district is providing inservice training for all school personnel at least annually regarding civil rights responsibilities, including discrimination and harassment on the basis of students’ race, color, sex, religion, national origin and sexual orientation and the appropriate methods for responding to it in the school setting. Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 8 of 12 Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements Quaboag Regional School District English Learning Education (ELE) Requirements Mid-Cycle Review Advisory Comments Resulting From The Department’s Review Of Local Self-Assessment Documents (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 ELE 2 MCAS Participation ELE 3 Initial Identification ELE 4 Waiver Procedures Advisory Comments Resulting from the Department’s Review of Local ELE Self-Assessment Document Submission The district has established procedures for annually assessing the English proficiency of all students who have a home language other than English. Several teachers have been trained to administer the MELA-O. The district is administering the MELA-O and MEPA. Review of district procedures indicated that all LEP students take part in MCAS. The procedures include a provision for first year LEP students to not take the ELA portion of MCAS. The district utilizes the Kurzweil Software program and provides bilingual dictionaries to all LEP students. The district requires a home language survey of all students upon enrollment. All students who have a second language identified on the home language survey are then assessed for English proficiency. The district provided a narrative description of their identification process. All students upon enrollment are given the IPT, and MELA-O assessment. Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements to be Implemented in Anticipation of the District’s Next Scheduled Coordinated Program Review The district has developed appropriate waiver procedures and a waiver application. It has a list of area contacts to provide necessary translations. The district will want to ensure that consent forms are available in the native language of the parent or have provisions in place to have procedures and forms translated. Submit a copy of forms or a plan for document translation by April 7, 2006. Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 9 of 12 ELE Criterion Number and Topic ELE 5 Program Placement and Structure ELE 6 Program Exit and Readiness ELE 7 Parent Involvement ELE 8 Declining Entry to a Program Advisory Comments Resulting from the Department’s Review of Local ELE Self-Assessment Document Submission Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements to be Implemented in Anticipation of the District’s Next Scheduled Coordinated Program Review The district has staff who have been trained to administer the MELA-O but have not received Sheltered English Immersion training to assist them in instructing LEP students within regular education classrooms. The district needs to provide professional development to instructional staff to ensure that staff are able to provide sheltered instruction for LEP students placed in their classes. Submit copy of the professional development plan that includes this training by April 7, 2006. The district has developed program exit criteria and procedures but does not have appropriate forms to document the student’s progress and the decision to exit the student from the program. The documentation indicated that LEP parents have the same access to district involvement as parents of English proficient students. While this may be appropriate for parents who are English proficient, it does not seem sufficient for LEP parents. There was no documentation provided to indicate that parents receive the information in their native language or have the opportunity to have the notices translated. The district provides waiver forms to parents. If a parent wishes to waive ELL instruction or opt out, they must complete the form. However, there were no forms submitted that have been translated in languages other than English. The district will want to make sure that when notices, letters, emails etc. are sent out, they are sent out from all schools and they are translated into the dominant languages present in the schools. The district may want to consider posting these types of notices on their school Public Notice boards as they do with notices related to special education and civil rights requirements. Submit a copy of a plan to assure that parents receive the information in their native language or have the opportunity to have the notices translated by April 7, 2006. The district should have the waiver or opt-out forms and information translated so parents can make informed decisions, or have a procedure to indicate that parents whose native language is not English understands what they are signing. Submit copy of translated forms or procedure by April 7, 2006. ELE 9 Instructional Grouping The district’s procedures for this criterion meet all requirements. ELE 10 Parental Notification The district has not developed a notification letter. The district should develop its notification letter. It should include all required elements in ELE 10. In addition, the district should revise its implementation procedures to include information regarding how parents will be provided with report cards and progress repots in the same manner and frequency, in a language understandable to the parent, as general education reporting. Submit a copy of the revised implementation procedures and revised notification letter by April 7, 2006. Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 10 of 12 ELE Criterion Number and Topic ELE 11 Equal Access to Academic Programs and Services Advisory Comments Resulting from the Department’s Review of Local ELE Self-Assessment Document Submission The district’s implementation practices indicated that all LEP students have access to and are integrated into general education classrooms. In addition, LEP students can access all curriculum offerings, such as special education services and Section 504 Plans, provided they meet eligibility requirements. Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements to be Implemented in Anticipation of the District’s Next Scheduled Coordinated Program Review The district should revise their implementation practices to include a description of how LEP students are provide with guidance and counseling in their native language. Submit a copy of revised implementation practices by April 7, 2006. ELE 12 Equal Access to Nonacademic and Extracurricular Programs The district submitted a statement that all LEP students can participate in all nonacademic programs and extracurricular activities available in the district. The district should revise their implementation practices to include a description of how LEP students are provided with support to ensure they have equal access to all nonacademic programs and extracurricular activities. Submit a copy of revised implementation practices by April 7, 2006. ELE 13 The district has developed a quarterly monitoring form for LEP students. The district should review and revise the monitoring form to garner substantive information to assist in evaluating student progress. Submit a copy of the revised monitoring form by April 7, 2006. The district submitted an assurance that all teachers in English language classrooms are literate and fluent in English. All teachers in the district hold a teaching license. The district should develop a professional development plan for general education teachers that includes training at all levels to meet the qualification requirements for teaching in a Sheltered English Immersion setting. Submit a copy of the professional development plan by April 7, 2006. Follow-up Support ELE 14 Licensure and Fluency Requirements Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 11 of 12 ELE Criterion Number and Topic ELE 15 Professional Development Requirements ELE 16 Equitable Facilities (To be reviewed during next CPR visit) ELE 17 DOE Data Submission Requirements and Program Evaluation ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) Advisory Comments Resulting from the Department’s Review of Local ELE Self-Assessment Document Submission The district submitted a description of professional development activities that have been held in the district related to English language learners. Required Corrective Action, Timelines for Implementation, and Further Progress Reporting Requirements to be Implemented in Anticipation of the District’s Next Scheduled Coordinated Program Review The district should include in their professional development plan, high quality training for teachers and administrators on second language learning and teaching, sheltering content instruction, assessment of speaking and listening, and teaching reading and writing to limited English proficient students. See submission for ELE 14 above. The district submitted a statement that indicates LEP students are provided with the same facilities, materials and services as those provided to the general student population. The district submits all student information required by the Department annually. The district did a self-assessment for this review and developed an action plan The district should develop an ongoing evaluation process to ensure the ELE program is effective. The district should regularly monitor the action plans developed from the program evaluations. Clear and specific timelines for implementation should be included in the corrective action plans. Submit a copy of the evaluation tool and timelines for implementation by April 7, 2006. The district submitted a statement that cumulative records for ELE students are kept confidential and contain all required documents. During the Department of Education Mid-cycle review, some ELE records were examined. Review of records indicated that not all records contained the required documentation. The district should use the ELE Student Record Review Checklist to monitor compliance with required ELE student record requirements. Review ELE Student Record Checklists and provide a summary of results and action plan developed by April 7, 2006. Quaboag Regional School District Coordinated Program Review Mid-cycle Report February 15, 2006 Page 12 of 12