The Massachusetts Department of Elementary and Secondary Education 75 Pleasant Street, Malden, Massachusetts 02148-4096 Telephone: (781) 338-3700 TTY: N.E.T. Relay 1-800-439-2370 July 16, 2013 Steven Moore, Interim Superintendent Randolph Public Schools 70 Memorial Parkway Randolph, MA 02368 Re: Mid-cycle Report Dear Interim Superintendent Moore: Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Report based on the onsite visit conducted in your district in March 2013. During the Mid-Cycle Review the Department monitored selected special education criteria to determine your district’s compliance with special education laws and regulations. The review consisted of information gathered from one or more of the following activities: interviews, review of student records, examination of documentation, and classroom observation(s). The Department determined that one or more of the criteria monitored in your district was “Partially Implemented” or “Not Implemented.” In all instances where noncompliance was found, the Department has prescribed corrective action for the district. This corrective action must be implemented as soon as possible, but in no case later than a year from the date of this report. You will find these requirements for corrective action included in the enclosed report, along with requirements for submitting progress reports using the enclosed form. Please provide the Department with your written assurance that all of the required corrective action will be implemented by your district within the timelines specified in the report. You must submit your statement of assurance to Darlene Lynch, Director, Program Quality Assurance Services, by August 2, 2013. 1 Your staff's cooperation throughout this Mid-cycle Review is appreciated. If you have questions about this letter or the enclosed report, please do not hesitate to contact Deborah Conover at 781338-3736. Sincerely, Deborah Conover, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services cc: Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education Vani Rastogi-Kelly, Supervisor, Program Quality Assurance Services Andrew Azer, School Committee Chairperson Maria Lopes, Local Program Review Coordinator Encs: Mid-cycle Report Mid-cycle Progress Report Form 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REPORT Randolph Public Schools Date of the Mid-cycle Review Onsite: March 28, 2013 Date of this Report: July 16, 2013 PLEASE NOTE THAT THIS REPORT IS IN TWO SECTIONS. Required Special Education Criteria Monitored in this Mid-cycle Review Current special education criteria available by scrolling down to the special education instrument at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion SE 7 Transfer of parental rights and student participation and consent at age of majority Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) PI Method(s) of Investigation Student Records Interviews Basis of Determination about Criterion One year prior to the student turning 18 years of age, the district does not consistently inform the student and parent/guardian of the rights that will transfer from the parent/guardian to the student upon the student’s 18th birthday. The notification provided to If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation For those students whose records were identified by the Department, provide notice to the student and parent/guardian of the transfer of parental rights. Ensure that the notification states that all rights accorded to parents/guardians under special education law will transfer to the student once he or she turns 18 years of age. For those student records identified by the Department, submit a copy of the notification provided to the student and parent/guardian. Develop procedures for informing the Provide a copy of Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 1 of 15 (b) Progress Report Due Date(s) and Required Elements Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion both the student and parent/guardian should indicate that all the rights provided to the parent under special education law will transfer to the 18-year-old student. If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation student and parent/guardian of the transfer of parental rights requirements one year prior to the student reaching the age of 18. Train all high school IEP Team chairpersons on the procedures. Develop an internal oversight and tracking system to ensure the implementation of the age of majority procedures. The tracking system should include supervisory oversight and periodic reviews by the Director of Special Education to ensure ongoing compliance. Develop a report of the results of an internal review of records for students who turned 17 years of age, after implementation of all of the district’s corrective actions, for evidence of compliance with provision of notification one year prior to the student reaching the age of majority. *Please note that when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the record review; b) Date of the review; Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 2 of 15 (b) Progress Report Due Date(s) and Required Elements the procedures and evidence of Team chairperson training at the high school. Submit the agenda and signed attendance sheet with the name and role of staff. Submit a description of the internal oversight and tracking system with periodic reviews, along with the name and role of the designated person. Submit the above information by October 25, 2013. Submit the results of a review of Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation c) Name of person(s) who conducted the review with their roles(s) and signature(s). (b) Progress Report Due Date(s) and Required Elements records and include: SE 8 IEP Team composition PI Student Records Not all required Team members are consistently present at the IEP Team meeting, including the Review the Team meeting composition from a sample of IEP Teams that have convened between March and June of the 2012-2013 school year, where not all Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 3 of 15 Number of records reviewed; Number in compliance; Results of the root cause analysis of any records not in compliance; and The specific corrective actions taken to remedy the noncompliance. Submit the above information by January 24, 2014. Submit the results of the root cause analysis with specific proposals Criterion and attendance Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Interviews Basis of Determination about Criterion student’s general education teacher (if the student is involved in a general education program) and the parent. When a member of the Team does not attend the IEP Team meeting, the district is not following appropriate procedures to excuse the Team member that include: The district and the parent agreeing, in writing, that the attendance of the Team member is not necessary because the member’s area of the curriculum or related services is not being modified or discussed; or The district and the parent agreeing, in writing, to excuse a required Team member’s participation and the excused member provides written input into the If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation required members of the Team were in attendance. Select representation from across elementary, middle and high school levels and analyze the information to establish the root cause(s) for the noncompliance. Based on this root cause analysis, indicate the specific corrective actions that will be taken to remedy the non-compliance. for remedying the non-compliance and proposed timelines for corrective actions. Submit this information by October 25, 2013. Select a sample of student records from a cross-section of schools and levels in which Team meetings were held since implementation of all of the district’s corrective actions. Develop a report of the results of an internal review for evidence of compliance with IEP Team composition and attendance, excusal procedures, and documentation of efforts for parent participation. Submit the results of the second review of records and include the following: Number of records reviewed; Number of records in compliance; Results of the root cause analysis of any records not in compliance; Specific corrective actions taken *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 4 of 15 (b) Progress Report Due Date(s) and Required Elements Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation development of the IEP to the parent and IEP Team prior to the meeting. by the district to remedy any noncompliance. Submit the above information by January 24, 2014. When the parents are unable to attend the IEP Team meeting, the district does not consistently document that it has used alternative means, such as video conference or a conference call, to ensure parent participation. SE 18A IEP development and content Student Records PI Interviews Students are invited to attend IEP Team meetings when a purpose of the meeting is to discuss transition services, or if otherwise appropriate. For students identified with a disability on the autism spectrum and for those students whose disability affects social skills development or whose disability makes them vulnerable to bullying, harassment, or teasing, the For those students whose records were identified by the Department, the district must reconvene the IEP Teams to consider and address the skills and proficiencies needed to avoid and respond to bullying, harassment or teasing. Please see Technical Assistance Advisory SPED 2011-2: Bullying Prevention and Intervention for assistance and guidance Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 5 of 15 (b) Progress Report Due Date(s) and Required Elements For those student records identified by the Department, submit a copy of the IEP and the Special Education Team Meeting Attendance Sheet Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion IEP Team is not consistently considering and addressing the skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing. Age specific considerations are being appropriately addressed in the Present Levels of Educational Performance B (PLEP B) section of the IEP for students age 16-22. If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation on meeting this requirement: http://www.doe.mass.edu/sped/advisories/ 11_2ta.html Provide the IEP Team chairpersons with training on the requirements for addressing bullying prevention and intervention in the IEP. Develop an internal oversight and tracking system to ensure that IEP Teams consider and address the skills and proficiencies needed to avoid and respond to bullying, harassment and teasing. The tracking system should include supervisory oversight and periodic reviews by the Director of Special Education to ensure ongoing compliance. Develop a report of the results of an internal review of records to ensure that IEP Teams, that have convened after all corrective actions have been implemented, are addressing the skills and proficiencies needed to avoid and respond to bullying, harassment or teasing in the IEP. *Please note when conducting internal monitoring the district must maintain Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 6 of 15 (b) Progress Report Due Date(s) and Required Elements (N3A) to indicate that the IEP Teams have reconvened. Submit evidence of the IEP Team chairperson training and include the agenda, materials and signed attendance sheet with the name and role of staff. Submit a description of the internal oversight and tracking system with periodic reviews, along with the name and role of the designated person. Submit the information indicated above Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 7 of 15 (b) Progress Report Due Date(s) and Required Elements by October 25, 2013. Submit the results of the review of records and include the following: Number of records reviewed; Number of records in compliance; For any records not in compliance, determine the root cause; and Specific corrective actions taken to remedy the noncompliance. Please submit the above information by January 24, Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation (b) Progress Report Due Date(s) and Required Elements 2014. Student Records Interviews SE 25 Parental consent When a parent revokes consent, in writing, to special education services, the district provides written notice to the parent of its proposal to discontinue services based on the written revocation of consent as well as information on how the parent can obtain a copy of his/her rights to procedural safeguards. The district provides notice within a reasonable time before it intends to discontinue services. Staff members are aware that they may not use mediation or request a due process hearing to obtain agreement or a ruling for continuation of services. Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 8 of 15 Additional Special Education Criteria Monitored in this Mid-cycle Review Current special education criteria available by scrolling down to the special education instrument at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion SE 4 Reports of assessment results SE 6 Determination of transition services SE 9 Timeline for determination of eligibility and provision of documentation to parent SE 13 Progress Reports and content Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Student Records Student Records Interviews Student Records Interviews PI Student Records Basis of Determination about Criterion Assessment reports define in detail and in educationally relevant and common terms the student’s needs, offering means for meeting those needs. IEP Teams discuss the student’s transition needs starting at age 14 and document this discussion on the Transition Planning Form. The district conducts evaluations within 30 school working days of receiving consent to an initial evaluation or a re-evaluation and holds an IEP Team meeting and provides either a proposed IEP and placement or a finding of no eligibility to the parent within 45 school working days of receipt of consent. Review of student records from across grade levels indicates that progress reports are not consistently maintained in the records; therefore, there is no If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation Provide training to special education staff responsible for completing progress reports on writing reports that address the student's progress towards the Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 9 of 15 (b) Progress Report Due Date(s) and Required Elements Submit the training information, including the agenda and signin sheet. Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation indication that progress reports are sent to parents at least as often as parents are informed of the progress of non-disabled students. Progress reports that were reviewed in the records do not consistently include written information on the student's progress towards reaching the annual goals set forth in the IEP. annual IEP goals, issuing reports at least as often as parents are informed of the progress of nondisabled students and maintaining reports in the student records. Develop an internal oversight and tracking system for ensuring that progress reports are issued consistently, maintained in the student record and contain information on the student's progress towards the annual IEP goals. The oversight and tracking system should include periodic reviews by the Director of Special Education to ensure ongoing compliance. Develop a report of the results of an internal review of student records, in which progress reports were written subsequent to implementation of all corrective actions, to ensure appropriate completion and inclusion in the student record. Please note when conducting internal monitoring, the Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 10 of 15 (b) Progress Report Due Date(s) and Required Elements Submit a description of the internal oversight and tracking system with periodic reviews, along with the name and role of the designated person. Submit the information indicated above by October 25, 2013. Submit the results of the review of student records and include the following: Number of records reviewed; Number of records in compliance; For any records not in compliance, determine the root cause; and Specific corrective actions taken to remedy Criterion SE 14 Review and revision of IEPs Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) PI Method(s) of Investigation Student Records Interviews Basis of Determination about Criterion Team meetings are not consistently held on or before the anniversary date of the IEP to consider the student’s progress and to review, revise, or develop a new IEP or to refer the student for a re-evaluation, as appropriate. If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). Review a sample of student records from all levels in which the IEP Team convened between March and June of the 20122013 school year and the Team meeting was not held prior to the anniversary date of the IEP. Analyze the information to establish the root cause(s) for the non-compliance. Based on this root cause analysis, indicate the specific corrective actions that will be taken to remedy the noncompliance. Develop a report of the results of an internal review of records from all levels, in which an IEP Team convened subsequent to implementation of the district’s corrective actions, for evidence Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 11 of 15 (b) Progress Report Due Date(s) and Required Elements the noncompliance. Submit the above information by January 24, 2014. Submit a description of the root cause analysis with the results, as well as specific proposal(s) for remedying the non-compliance and associated timelines. Submit this information by October 25, 2013. Submit the results of a second review of student records and include the following: Number of records reviewed; Number of records in compliance; Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation of compliance with annual review and revision of the IEP. SE 20 Least restrictive program selected PI Student Records Interviews The Non-Participation Justification statement does not consistently state why the removal of a special education student from the general education classroom is considered critical to the student’s program. The IEP also does not indicate the basis of the Team’s conclusion that education of the student in a less restrictive environment, with the use of supplementary aids and services, could not be achieved satisfactorily. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). Review a sample of student records across all levels in which an IEP was written between March and June of the 20122013 school year and analyze the information to establish the root cause(s) for the non-compliance. Based on this root cause analysis, indicate the specific corrective actions that will be taken to remedy the non-compliance. Develop a report of the results of an internal review of records from across all grade levels, in which IEPs have been written Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 12 of 15 (b) Progress Report Due Date(s) and Required Elements For any records not in compliance, determine the root cause; and Specific corrective actions taken to remedy any noncompliance. Submit the report by January 24, 2014. Submit the description of the root cause analysis with the results, as well as specific proposal(s) for remedying the non-compliance and associated timelines. Submit this information by October 25, 2013. Submit the results of the second review of student records and include the following: Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation since implementation of all of the district’s corrective actions, for evidence of compliance with ensuring appropriate completion of the Non-Participation Justification statements. Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of the student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s), and signature(s). SE 26 Parent participation in meetings SE 29 Communications are in English and primary language of home PI Student Records (b) Progress Report Due Date(s) and Required Elements Number of records reviewed; Number of records in compliance; For any records not in compliance, determine the root cause; and Specific corrective actions taken to remedy the noncompliance. Submit the above information by January 24, 2014. See SE 8. Interviews PI Student Records Interviews While the district has procedures and forms for providing oral and written translations, the review of student records indicated that translated IEPs, progress reports, and notices are not being maintained in the student record. For those students whose records were identified by the Department, provide evidence of translated documents, including the most recent IEP, progress reports and Notice of Proposed School District Action (N1). Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 13 of 15 For those student records identified by the Department, submit a copy of the translated IEP, progress reports and N1 form. Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation Review a sample of student records between March and June of the 2012-2013 school year in which the primary language of the home is other than English and the IEP Team convened and progress reports were issued. Analyze the information to determine the root cause(s) of the non-compliance. Based on this root cause analysis, indicate the specific corrective actions the district will take to remedy the non-compliance. Develop a report of the results of an internal review of records, after all corrective actions have been implemented, for ensuring translated special education documentation is included in the student record for parents requiring communications in a language other than English. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 14 of 15 (b) Progress Report Due Date(s) and Required Elements Submit the results of the root cause analysis with specific proposals for remedying the noncompliance and associated timelines. Submit the above information by October 25, 2013. Submit the results of the review of student records and include the following: Number of records reviewed; Number of records in compliance; For any records not in compliance, determine the root cause; and Specific corrective actions taken to remedy Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation upon request a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, their role(s) and signature(s). SE 48 Equal opportunity to participate in all programs SE 55 Special education facilities & classrooms Document Review Interviews Observation All students receiving special education have an equal opportunity to participate in remedial services, specifically through Title I, which may be available as part of the general education program. An onsite visit to the Lyons Elementary School indicated that the time out areas are located within the special education classrooms, allowing for confidentiality. Randolph Public Schools Coordinated Program Review Mid-cycle Report July 16, 2013 Page 15 of 15 (b) Progress Report Due Date(s) and Required Elements the noncompliance. Submit the above information by January 24, 2014. MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REVIEW School District: Randolph Public Schools M I D – CY C L E P R O G R E S S R E P O R T Date Prepared: ____________________________________ Prepared by: __________________________________________________________________ (name and title) Criterion: _______________________ Topic: ________________________________________________________________________ For each criterion for which you prepare a progress report, please make a copy of this cover page, fill in the information requested above, and attach a complete description of the corrective action taken and any accompanying documentation. (Description of corrective action for each criterion and any accompanying documentation should include all of the “Progress Report Required Elements” for that criterion in the Mid-cycle Report.) Send the whole set of completed progress reports to: Darlene Lynch, Director Program Quality Assurance Services Massachusetts Department of Elementary and Secondary Education 75 Pleasant Street Malden, MA 02148-4906