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 5, 2008 Dr. Richard Silverman Superintendent of Schools Randolph Public Schools 70 Memorial Drive Randolph, MA 02368 Re: Mid-cycle Coordinated Program Review Report Dear Superintendent Silverman: 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 or ordered by the Department to address findings of noncompliance included in the Randolph Public School District Coordinated Program Review Report issued on July 8, 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. While the Department of Education found your district to have resolved certain noncompliance issues, others were partially corrected or not addressed at all. 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. Where the district has failed to implement its approved Corrective Action Plan, the Department views these findings to be serious. 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 1 specified. You must submit your statement of assurance to me by February 26, 2008. 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 781-338-3761. Sincerely, Lynn A. Summerill, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: Jeffrey Nellhaus, Acting Commissioner of Education Larry Azer, School Committee Chairperson Karen Clasby, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT Randolph Public School District ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS Date of Coordinated Program Review (CPR): January 7-8, 12-15 & 20, 2004 Date of Coordinated Program Review Corrective Action Plan Approval: October 7, 2004 Dates of Corrective Action Plan Progress Reports: March 17, 2005, June 24, 2005, June 14, 2006, October 30, 2006, January 16, 2007 Dates of this Mid-cycle Review Onsite Visit: May 15-17, 2007 Date of this Report: February 5, 2008 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented 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 Required Corrective Action, Timelines for Implementation, and Progress Reporting A review of records indicates that educational assessments are not The district will conduct trainings at the elementary and high school levels on writing Special Ed. Criteria Cited in CPR Report and Monitored in Mid-cycle & Criteria Reviewed as a Result of Complaints SE 2 Required and optional Review of student Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 1 of 30 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) assessments Approved Corrective Action Implemented 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 records Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting included in student records at the elementary and high school levels. This is an area of continued noncompliance. educational assessments that include a history of the student’s educational progress in the general curriculum. Submit an agenda, signed attendance sheets, and identify the staff member(s) responsible for monitoring educational assessments at these levels. Submit this information to the Department by April 1, 2008. Occupational therapy assessments at the elementary level were frequently conducted without parental consent. The district will conduct training for elementary level related service providers and Team chairpersons on the requirement of obtaining written consent prior to conducting assessments. Identify the staff member responsible for monitoring this criterion to ensure that consent is received prior to conducting assessments. Submit this information and a copy of the training agenda and signed attendance sheets to the Department by April 1, 2008. Conduct an internal review on the following: Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 2 of 30 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented 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 Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 3 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting 1. Report to the Department on the number of records reviewed at the elementary and high school level, and the number that contained appropriately written educational assessments. Include a description of any additional steps taken if non-compliance was found. 2. Report on the number of records reviewed at the elementary level and the number of parental consent forms received prior to testing. Report on any corrective action taken if non-compliance was found. Report on the above by June 30, 2008. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 4 Reports of Assessment results SE 5 State and District-Wide assessment Approved Corrective Action Implemented 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 Review of student records Review of student records and interviews Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting A review of records indicates that psychological assessment reports at the elementary level generally do not contain written recommendations or diagnostic impressions; reports primarily consist of test descriptions. When reports do include diagnostic impressions, reports contain identical language analysis for different disability categories. Reports are not individualized. The district will conduct training for school psychologists at the elementary level on the requirements of writing assessment reports. Submit an agenda and signed attendance sheet to the Department by April 1, 2008. A review of records and interviews indicate that IEP Teams for students taking the alternate MCAS assessment do not identify the learning strands and standards indicating how students Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 4 of 30 The district will conduct an internal review at the elementary level on this criterion. Report to the Department on the number of written summaries of psychological assessments reviewed and the number that contain individualized recommendations and diagnostic impressions. Include any corrective action taken if non-compliance is determined by June 30, 2008. The district will conduct training on how to document student participation in alternate assessments, including the identification of strands and standards to be assessed on IEP 7. Submit an agenda, signed attendance Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented 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 will participate, as required in section 2 on IEP page 7. This is an area of continued noncompliance. At the high school level, testing accommodations do not consistently correspond with accommodations that students receive during routine instruction. Required Corrective Action, Timelines for Implementation, and Progress Reporting sheet and training materials to the Department by April 1, 2008. The district will conduct training for special education staff at the high school level on the requirements of testing accommodations. Submit an agenda and signed attendance sheet to the Department by April 1, 2008. Submit copies of IEP page 7 for five students taking the alternate assessment during the 2007-2008 SY by June 30, 2008. The district will conduct an internal review at the high school and report to the Department on the number of IEPs reviewed and the number of IEPs that include testing accommodations that correspond with accommodations received during routine instruction. Include any corrective action taken if non-compliance is Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 5 of 30 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented 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 Required Corrective Action, Timelines for Implementation, and Progress Reporting found by June 30, 2008. SE 7 Transfer of parental rights at age of majority and student participation and consent at the age of majority Review of student records A review of student records indicates that the district routinely notifies parents and students regarding the transfer of student rights at the age of majority at least one year prior to the student’s 18th birthday. Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 6 of 30 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 9 Timelines for determination of eligibility Approved Corrective Action Implemented 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 Review of student records and interviews Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Review of student records and interviews indicate that evaluations conducted as a result of referrals from Early Intervention and at the kindergarten level were not conducted within regulatory timelines. Consent was not sent within five days and evaluations were not completed within 30 days. Conduct training with preschool and elementary school staff, as well as school psychologists at the high school, on timeline requirements for conducting evaluations. Submit an agenda and signed attendance sheet to the Department by April 1, 2008. A review of student records at the high school level indicates that psychological evaluations were not always conducted within 30 days of receipt of written consent from the parent. 1) Report to the Department on the number of early childhood and kindergarten level referrals received since September 2007 and the number of referrals that were processed within required timelines. Conduct an internal review of the following: 2) Report on the number of psychological assessments conducted at the high school level since September 2007 and the number of psychological assessments that were conducted within the required timeframes. Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 7 of 30 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented 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 Required Corrective Action, Timelines for Implementation, and Progress Reporting Submit these findings to the Department and any corrective action taken if non-compliance was found by June 30, 2008. Review of student records SE 18B Determination of placement; provision of IEP to parent Review of student records indicates that at the elementary level, proposed IEPs were not provided to the parent immediately and findings of no eligibility were not sent to parents within ten days of the Team meeting. The district will conduct training on the requirements of providing IEPs to parents immediately and providing findings of no eligibility within ten days of the Team meeting. Submit an agenda and signed attendance sheet to the Department by April 1, 2008. The district will conduct an internal review at the elementary level. Report on the number of Team meetings held post training and the number of IEPs and findings of no eligibility sent within the required timelines. Submit the results of this review and any corrective action taken if noncompliance was found by June 30, 2008. SE 20 Least restrictive program Review of student records and interviews IEP Teams consistently consider why the removal of students from the general education environment is critical to the Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 8 of 30 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification selected SE 22 IEP implementation and availability Basis of Determination that Corrective Action was Implemented and has been Effective Review of student records 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 student’s program and why the education of the student in a less restrictive environment, with the use of supplementary aides and services, could not be achieved satisfactorily. IEPs are consistently signed and indicate if parents/students have accepted or rejected the IEP. Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 9 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 24 Notice to parent regarding proposal or refusal to initiate or change the identification, evaluation, or educational placement of a child or the provision of FAPE Approved Corrective Action Implemented 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 Review of student records and interviews Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting A review of student records and interviews indicate that the district does not process referrals immediately upon receiving them from parents or Early Intervention (EI). The district does not send out consent forms until the district has documentation that students coming from EI have enrolled in the district. The district does not send evaluation consent forms to parents within five days of receiving a referral. N1 notices at the elementary and high school levels do not consistently list each assessment to be used as a basis for the proposed school district action. N1 notices do not contain a description of options that were considered and reasons why those options were rejected. The district will conduct training with special education and related service staff on the required content of N1 and N2 notices. Submit an agenda and signed attendance sheet to the Department by April 1, 2008. Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 10 of 30 The district will conduct an internal review and report to the Department on the number of N1 and N2 notices reviewed, the number found to include all required information and any corrective action taken if non-compliance is found. Submit the results of the internal review by June 30, 2008. See also SE 9 above. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues Identified Review of student records SE 25 Parental consent SE 25A Sending a copy of notice to Special Education Appeals Method(s) of Verification Partial Review of student records IEPs are consistently signed and indicate if parents/students accept or reject the IEP. Partial Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance At the elementary level, N1 and N2 notices do not contain a description of other factors that are relevant to the agency’s proposal or refusal. See SE 22 above regarding consent for occupational therapy assessments. A review of records indicates that the district does not always notify the BSEA within five calendar days of receiving notice that a parent has rejected an IEP at the high school level. Required Corrective Action, Timelines for Implementation, and Progress Reporting See SE 22. The district will conduct training at the high school level on the requirements of this criterion for Team chairpersons and secretarial staff processing rejected IEPs. Submit an agenda and signed attendance sheet to the Department by April 1, 2008. The district will conduct an internal review and will report the number of IEPs rejected at the high school level, the number of IEPs that were sent to the BSEA within five calendar days, and any corrective action taken if noncompliance was found by June 30, 2008. Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 11 of 30 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 29 Communications are in English and primary language of home SE 33 Involvement in the General Curriculum Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Review of student records, documents, and interviews The district consistently translates information for parents and documents when parents require translations. Review of student records A review of student records indicates that the district consistently documents involvement in the general curriculum in IEPs. Nonparticipation justification statements contain all required information. 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 Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 12 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) SE 36 IEP implementation accountability and financial responsibility SE 37 Procedures for approved and unapproved out-of-district programs SE 40 Instructional grouping requirements for students age five and older Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Review of student records The district consistently monitors students in out of district placements. Review of student records See SE 36 above Corrective Action Not Implemented or Not Effective or New Issues Identified Review of documents and interviews Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting A review of documents and interviews indicate that the cooperative program at the Donovan School has three classes that exceed instructional grouping requirements. The high school has one learning skills class and one special education US History class that exceed instructional group size requirements. The district did not submit notification to the Department of increased The district will review all resource room and substantially separate class groupings at all levels to ensure that all classes meet instructional group size requirements. The district will report the total number of classes and the number of classes that are in compliance with regulatory requirements. The district will submit an instructional group size notification, if necessary, by April 1, 2008. Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 13 of 30 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented 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 Required Corrective Action, Timelines for Implementation, and Progress Reporting instructional group size. This is an area of continued noncompliance. Review of documents and interviews SE 41 Age span requirements Review of documents and interviews indicate that the special education prevocational programs at the high school exceed age span requirements. The district did not apply for required waivers. This is an area of continued noncompliance. SE 43 Behavioral interventions SE 45 Procedures for suspension up to 10 days and after 10 days Review of student records Review of documents The district will review all special education prevocational class groupings at the high school level to ensure that groupings do not exceed an age span of 48 months. Report the number of classes that are in compliance and submit applications for age span waivers if required to the Department by April 1, 2008 IEPs consistently contain behavior plans and functional behavior assessments. Review of documents indicates that the district does not have current IDEA 2004 procedures for the discipline of students with special needs in all student handbooks. Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 14 of 30 The district will revise student disciplinary procedures to include current IDEA 2004 procedures for suspension up to 10 days and after 10 days. The district will submit the following: A copy of the revised discipline procedures Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented 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 This is an area of continued noncompliance. Required Corrective Action, Timelines for Implementation, and Progress Reporting Review of documents and interviews SE 51 Appropriate special education teacher certification Review of documents and interviews indicate that special education teachers throughout the district are not teaching at levels for which they are licensed. The district has not applied for waivers or encouraged staff to apply for licenses at different levels. This is an area of continued noncompliance. SE 55 Special Documents from The district submitted floor plans documenting that facilities Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 15 of 30 consistent with IDEA 2004; A plan for distributing these revised procedures; and A statement that the updated procedures will be included in the next publication of student handbooks. Submit these documents to the Department by April 1, 2008. The district will submit a copy of its current special education teacher roster that includes: Staff (by initials) Grade levels and content areas for which they are assigned Copies of licenses or waivers for each staff member Submit this documentation to the Department by April 1, 2008. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective previous progress reports education facilities and classrooms 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 The district did not submit documentation indicating that it has regularly evaluated its special education programs and services. maximize the inclusion of students in the life of the school at the Lyons Elementary School and the John F. Kennedy Elementary School. SE 56 Special education programs and services are evaluated This is an area of continued noncompliance. Special Education Criteria created or revised in response to IDEA-2004 SE 6 Determination of transition services Review of student records Required Corrective Action, Timelines for Implementation, and Progress Reporting Review of student records indicates that IEPs consistently contain vision statements for students 15 years and older. Vision statements consistently address the student’s future goals, and the Team utilizes the Transition Planning Form. Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 16 of 30 Submit a copy of the special education evaluation by June 30, 2008. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented 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 Review of student records and interviews SE 8 IEP Team composition and attendance Basis of Determination that Implementation of Corrective Action was Incomplete or Ineffective or Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Review of student records indicates that at the elementary level, written input from absent Team members is not provided at Team meetings. The district will develop and submit procedures for ensuring the participation of general educators at Team meetings by April 1, 2008. Review of student records and interviews indicate that at all levels, general education teachers do not consistently have representation at annual review meetings. At the elementary and middle school levels, representatives with the authority to commit resources were not always present for annual review meetings. Special education teachers report that they must check with higher authorities to commit resources and services at annual review meetings. SE 12 Frequency of re-evaluation Review of student records The district is conducting reevaluations every three years and when the district suspects that the student may no longer Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 17 of 30 The district will conduct training on the following topics: Procedures for excusing Team members Attendance of general education teachers and representatives with the authority to commit resources at Team meetings Submit the agenda and signed attendance sheets from the training by April 1, 2008. Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented 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 Required Corrective Action, Timelines for Implementation, and Progress Reporting need services as required. SE 13 Progress Reports and content Review of student records Review of student records indicates that progress reports at all levels do not consistently include information on the student’s progress towards annual IEP goals. At the high school level there is no evidence in student records that the district took action to address the lack of progress in counseling goals. Nor was there evidence that the district provides students who have graduated or exceeded the age of eligibility with a summary of their academic achievement and functional performance, including recommendations on how to assist students in meeting their postsecondary goals. *Please note that IDEA Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 18 of 30 Submit a plan to monitor the required elements of progress reports by April 1, 2008. Conduct training at the high school level on taking action to address the lack of progress in counseling goals and the requirement of providing summaries of academic achievement to students who are graduating or exceeding the age of eligibility. Submit an agenda and signed attendance sheet by April 1, 2008. Conduct an internal review at the high school level on the following: 1. Report on the number of records reviewed and the number in which there was evidence that the district provided students who have graduated or exceeded the age of eligibility with a summary of their academic achievement and Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented 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 2004 regulations have now changed the content requirements for IEP progress reports. Refer to Administrative Advisory SPED 2007-1 for guidance. The Department has also revised the progress report form, which may be found at the Department’s Special Education website at http://www.doe.mass.edu/ sped/iep/eng_toc.html. Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 19 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting functional performance, including recommendations on how to assist students in meeting their postsecondary goals. Provide a description of any corrective action taken if noncompliance was found. 2. Report on the number of progress reports reviewed containing counseling goals, the number of progress reports indicating that the child is not making progress, and the action taken to address the lack of progress in the counseling goals. Report these results to the Department and any corrective action taken if required by June 30, 2008. Criterion Number and Topic Criterion Implemented SE 14 Review and revision of IEPs Partial SE 18 A IEP development and content Method(s) of Verification Basis of Determination that Criterion was Implemented Review of student records The district documents IEP amendments appropriately. Criterion Determined to be Partially Implemented or Not Implemented Partial Review of student records Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Review of student records indicates that at the middle school level, annual reviews are not always conducted on or before the anniversary date of the IEP. The district will develop a tracking and monitoring system to ensure that annual reviews are being scheduled in advance of the expiration of the current IEP. Provide a description of the district’s tracking and monitoring system by April 1, 2008. Review of student records indicates that IEP Teams at the elementary and high school levels do not develop specially designed instruction based on individualized student Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 20 of 30 Report to the Department on the district’s internal monitoring of this criterion. Report the number of annual reviews conducted at the middle school, the number of annual reviews that were conducted on or before the expiration of the IEP, and any corrective action taken if noncompliance is found. Report these results to the Department by June 30, 2008. The district will conduct training at the elementary and high school levels on developing IEPs containing specially designed instruction and measurable goals and benchmarks. Submit the needs. IEPs do not contain goals and benchmarks for social skills and counseling services. agenda and signed attendance sheet by April 1, 2008. This is an area of continued noncompliance. 1. At the elementary and high school levels, report on the number of IEPs reviewed, the number of IEPs that contain specially designed instruction based on individualized student needs and any corrective action take if noncompliance is found by June 30, 2008. Conduct an internal review of the following: 2. At the elementary and high school levels, report on the number of IEPs that contain social skills and counseling services in the service delivery grid, and the number of IEPs that contain goals and benchmarks for these services, as well as any corrective action taken if non-compliance is found by June 30, 2008. SE 25B Resolution of disputes Review of student records and interviews The district’s procedures are consistent with IDEA 2004 regarding the resolution of disputes. SE 39A Procedures for services to eligible private The district did not submit a description of procedures for students enrolled in private school Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 21 of 30 Submit a description of procedures for students enrolled in private school at private expense and completed school students whose parents reside in the district (SE 39A does not apply to charter schools or vocational schools) SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state (SE 39B does not apply to charter schools or vocational schools) SE 46 Procedures for suspension of students with disabilities when suspensions exceed 10 consecutive school days or a pattern has developed for suspensions Review of student records and interviews at private expense or complete proportionate share worksheets. proportionate share worksheets by April 1, 2008. See SE 39 above. See SE 39 above The district conducts functional behavioral assessments and follows appropriate procedures for the suspension of students with disabilities when the number of suspensions exceeds 10 consecutive days or a pattern has developed exceeding 10 cumulative days. Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 22 of 30 exceeding 10 cumulative days; responsibilities of the Team; responsibilities of the district Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Civil Rights (MOA) and Other General Education Requirements MOA 2 MOA 3 Access to a full range of educational programs MOA 4 Placement of disabled, linguistic and racial/ethnic minority, homeless and female/male students MOA 7 Information to Approved Corrective Action Implemented 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 See ELE below. See MOA 4 below. Review of data Data indicates that there was an equal proportion of African American students in advanced placement classes during the 2006-2007 SY. Review of documents Student handbooks document that codes of conduct will be Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 23 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements be translated into languages other than English MOA 10A Student handbooks and codes of conduct translated upon the request of parents and guardians who are limited English proficient. Review of documents Review of handbooks indicates that handbooks contain multiple procedures for the investigation of complaints involving harassment and discrimination that are not aligned with one another. The high school handbook does not contain due process procedures for disciplinary proceedings. Handbooks contain outdated references to Chapter 766 regulations. The district did not provide a code of conduct for teachers. The district will revise its policies and procedures with regard to the following: Current IDEA 2004 regulations regarding the discipline of special needs students and students on Section 504 Accommodation Plans. Consistent procedures for accepting, investigating and resolving complaints involving discrimination and harassment. Due process procedures for disciplinary proceedings at the high school. Submit copies of the revised policies and procedures, a plan for distributing the revised policies and procedures and a statement that the updated policies and procedures will be included in the next handbook publication. Submit this information by April 1, 2008. The district will also develop and submit a code of conduct for teachers by June 30, 2008. MOA 12 A Annual and Review of documents The district did not provide documentation Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 24 of 30 The district will submit a copy of the brochure given to that brochures given to prospective employees contain an appropriate non-discrimination statement. continuous notification concerning nondiscrimination and coordinators MOA 14 Counseling and counseling materials free from bias and stereotypes This is an area of continued noncompliance. The district did not provide documentation indicating that the district has a formal process to monitor the requirements of this criterion. prospective employees with the appropriate non-discrimination statement by April 1, 2008. Submit procedures for monitoring and ensuring that counseling and counseling materials are free from bias and stereotypes. Submit this information by April 1, 2008. This is an area of continued noncompliance. MOA 16 Notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion MOA 17A Physical Restraint Review of student records The district consistently sends notices to students 16 or over following their 15th day of consecutive absence; notices indicate that students may request a meeting within 10 days. MOA 21 The district did not provide documentation indicating that annual restraint training was conducted for all staff during the first month of the school year. The district did not submit Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 25 of 30 Submit the agenda and attendance sheet from the physical restraint training conducted within the first month of the 2007-2008 school year. Submit this information by April 1, 2008. Provide training on civil rights Staff training regarding civil rights responsibilities documentation indicating that it provided annual civil rights training during the 2006-2007 SY. responsibilities to all staff and submit agendas and signed attendance sheets for each school by April 1, 2008. This is an area of continued noncompliance. MOA 22 Accessibility of district programs and services for students with disabilities MOA 25 Institutional self evaluation Partial Observation of facilities The high school provides appropriate access for disabled students. Review of ELL documents The district’s ELL department submitted comprehensive documentation that annual selfevaluations have been conducted. Partial The district did not submit documentation indicating that self-evaluations have been conducted for all aspects of its K-12 program other than ELL. This is an area of continued noncompliance. Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 26 of 30 The district will conduct a selfevaluation of all aspects of its K-12 programs and submit this information by June 30, 2008. Randolph Public School District 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 Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 1 Annual Assessment ELE 2 MCAS Participation ELE 3 Initial Identification ELE 4 Waiver Procedures ELE 5 Program Placement and Structure Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 27 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting ELE Criterion Number and Topic ELE 6 Program Exit and Readiness ELE 7 Parent Involvement ELE 8 Declining Entry to a Program Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 9 Instructional Grouping ELE 10 Parental Notification ELE 11 Equal Access to Academic Programs and Services ELE 12 Equal Access to Nonacademic Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 28 of 30 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 Self-Assessment Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) and Extracurricular Programs ELE 13 Follow-up Support ELE 14 Licensure Requirements Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 29 of 30 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 Self-Assessment ELE 15 Professional Development Requirements ELE 16 Equitable Facilities ELE 17 Program Evaluation ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Randolph Public Schools Coordinated Program Review Mid-cycle Report February 5, 2008 Page 30 of 30 Required Corrective Action, Timelines for Implementation, and Progress Reporting