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
September 9, 2005
Mr. Douglas Greer, Acting Director
Robert M. Hughes Charter School
90 School Street
Springfield, MA 01105
Re:
Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action
Plan Verification and Special Education Mid-cycle Review
Dear Mr. Greer:
Enclosed is the Department's Coordinated Program Review Follow-up Monitoring Report
together with findings regarding your district’s Coordinated Program Review Mid-cycle Review.
This report contains the Department's findings based on the onsite activities conducted in your
school district to verify the implementation status and effectiveness of corrective steps taken in
response to your Coordinated Program Review Report issued on August 14, 2002.
The Department will notify you of your district's next regularly scheduled Coordinated Program
Review several months before it is to occur. At this time we anticipate the Department's next
routine monitoring visit to occur sometime during the 2007-08 school year, unless the
Department determines that there is some reason to schedule this visit earlier.
While the Department of Education found certain noncompliance issues to be resolved, others
were partially corrected, not addressed at all and/or new issues were identified by the
Department’s onsite team. 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
September 23, 2005. The district’s continuing failure to implement the required Corrective
Action Plan described in this report will result in recommendation to the Commissioner of
Education the withholding of state or federal funds and/or other enforcement action by the
Department.
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 Onsite Team Chairperson at (413) 284-0382.
Sincerely,
Joseph H. Dow, Supervisor
Program Quality Assurance Services
John D. Stager, Administrator
Program Quality Assurance Services
cc:
David P. Driscoll, Commissioner of Education
Carol Aranjo, School Committee Chairperson
Yvette Joseph, District Program Review Follow-up Coordinator
Encl.: Follow-up Monitoring Report
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
COORDINATED PROGRAM REVIEW
Robert M. Hughes Charter School
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION
Action Plan Submitted on: May 21, 2003
Progress Reports Submitted on: August 19, 2004 and April 5, 2005
Onsite Visit Conducted on: April 14, 2005 and April 15, 2005
Date of this Report: September 9, 2005
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Special
Education
Requirements
SE 1
Assessments
are
appropriately
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The charter school does
not utilize assessments
that use information from
a variety of sources to
By October 14, 2005, the
charter school will train all of
its staff members, in addition
to its services coordinator and

Document
Reviews
Student
Assessments are selected and
interpreted for students referred
for special education.
Partially
Implemented
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
selected
and
interpreted for
students
referred for
evaluation
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
gather relevant functional
and developmental
information. In addition,
the charter school is not
using technically sound
instruments that assess the
relative contribution of
cognitive and behavioral
factors that include
physical and
developmental factors too.
For example, the charter
school uses an evaluator
whose assessments
determine that every
student in the school that
is eligible for special
education or related
services has a visionrelated
disability/disabilities.
Lastly, the charter school
Team is basing its
its special education teachers,
who evaluate students,
including contracted staff that:
1. Assessments must be
appropriately selected
and tailored to assess
specific areas of
educational need.
2. Assessments will be
provided in the
student’s native
language when
appropriate
3. Only prescribed
language modifications
by the assessment
developer may be used
by the charter school
evaluators.
4. A Team meeting will be
immediately convened
for all incoming students
to review the student’s

Record
Reviews
Interviews
2
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

findings/determinations
on incomplete data and
tests.
IEP, review current
district placement
options, and determine
what placement
conforms to the student’s
IEP in the least
restrictive environment.
The charter school must
conduct its own trainings
that meet all of the standards
stated above. By January 17,
2006, the charter school
must submit a copy of the
following:
1. Training dates
2. Training agenda
3. Name (s) of presenter (s)
4. Sign-in sheet(s) that have
staff person’s name and
position.
SE 2
Document
Partially
3
The charter school does
By October 14, 2005, the
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Required
and
optional
assessments
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
not consistently conduct
evaluations in all areas of
suspected disability or
disabilities. Also, the
charter school does not
conduct the required
educational assessments
for all students that are
referred for a special
education evaluation.
charter school will train all of
its staff members who evaluate
students for eligibility or reeligibility, including contracted
staff that:
1. Conduct assessments in all
area(s) of suspected
disability (ies).
2. Conduct assessments for the
consideration of any needed
assistive technology
devices.
3. Conduct educational
assessments/observations for
all students referred for a
special education evaluation
utilizing all of the required
elements on the
Department’s Educational
Assessment forms, Part A
and Part B.
By January 17, 2006, the
charter school will submit a

Reviews
Implemented
Student
Record
Reviews
Interviews
4
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

copy of the following:
1. Training date(s)
2. Training agenda
3. Name(s) of presenter (s)
4. Sign-in sheet(s) that have
staff person’s name, and
position.
SE 3
Special
requirements
for
determination
of specific
learning
disabilities
Not
Implemented
5
Under the previous
standard, the charter
school’s policies and
procedures do not adhere
to the mandated
requirements for
determining a specific
learning disability;
Therefore, the charter
school does not
implement the required
process for SLD.
“Statutory requirements for
the determination of specific
learning disabilities have
been revised under the
recently reauthorized IDEA
2004. Therefore, until final
implementing regulations
have been adopted, the
Department is not making
findings related to school
district/charter school
practices under the MidCycle Review Criterion SE 3.
For districts/charter schools
seeking to resolve a previous
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

finding in this area, the
Department will extend the
date required for final
actions on part of school
district/charter school to
June 2006 and will consider
resolution at any time
following promulgation of
final regulations.”
6
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 4
Report of
assessment
results
SE 6
Determination
of transition
services
(Emphasis on
practices in
determining
needed
transition
planning and
services and
consideration of
courses of study
related to
needed
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Substantially
Implemented

Document
Reviews
Student
Record
Reviews
Not
Applicable
Interviews
None
The charter school does
summarize in writing the
procedures employed, the
results, and the diagnostic
impressions of its utilized
assessments in terms that are
educationally relevant to the
student’s needs.
The charter school only serves
students in grades kindergarten
through eighth.
7
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


transition)
8
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 7
Transfer of
parental rights
at age of
majority and
student
participation
and consent at
the age of
majority
SE 8
Evaluation
Team
composition
SE 9
Eligibility
determination:
Timelines for
evaluation,
immediate
provision of
IEP
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The charter school does
not use required elements
on the N1 form when
developing an IEP. It
only uses the required
elements of the N1 form
when proposing an
evaluation/assessment.
See findings under SE 1 and
SE 2. Furthermore, the charter
school must submit to the
Department five N1 forms used
in the process of developing an
IEP by January 17, 2006.

Not
Applicable
None
The charter school only serves
students in grades kindergarten
through eighth.
Substantially
Implemented
Student
Record
Reviews
The charter school has the
appropriate personnel present at
all of its Team meetings.
Interviews
Document
Reviews
Partially
Implemented
Student
Record
Reviews
Interviews
9
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

Basically, the charter
school is using its own
form that does not
encompass the elements
from the N1 form.
10
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 10
End of
School Year
Evaluations
SE 11
Schedule
district
response
to
parent
request
for
independent
educational
evaluation
SE 12
Frequency
of
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Substantially
Implemented
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The charter school has a
defective policy
concerning parental
requests for independent
education evaluations.
The policy is defective
because it allows the
charter school to approve
or disapprove a parent’s
right to request an
independent education
evaluation.
The charter school is
utilizing defective
assessments when it is
The charter school must revise
its current policy concerning
parental requests for
independent education
evaluations so that it adheres to
all of the regulatory
requirements. A copy of this
revised policy must be
submitted to the Department by
January 17, 2006.

Document
Reviews
The charter school does
consistently conduct end of the
school year evaluations.
Student
Record
Reviews
Interviews
Document
Reviews
Not
Implemented
Interviews
Document
Reviews
The charter school does in all
cases, with parental consent,
conduct full re-evaluations
11
Partially
Implemented
See findings under SE 1 and
SE 2.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
re-evaluation
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

Student
Record
Reviews
every three years or sooner for
all its students that are
consistent with the requirements
of federal law.
Interviews
12
conducting these threeyear evaluations. See
findings under SE 1 and
SE 2.
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 13
Progress
Reports and
content
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Substantially
Implemented

Document
Reviews
Student
Record
Reviews
Interviews
SE 14
Annual
review
Team meeting
Substantially
Implemented
SE 15
Outreach by the
School District
(Child Find)
Substantially
Implemented
Document
Reviews
Student
Record
Reviews
Interviews
Documents
Reviews
Interviews
The charter school does
routinely send parents of
children with disabilities reports
on their progress toward
reaching the goals set forth in
their IEPs, at least as often as
parents are informed of progress
of non-disabled children.
The charter school does in all
cases, at least annually on or
before the anniversary date of
the implementation of the IEP,
review, revise, or develop a new
IEP.
The charter school has annual
outreach to the community
groups, schools, and
professionals from which
promotion or transfer of
students in need of special
13
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


education may be expected.
14
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 17
Initiation of
services at age
three and Early
Intervention
transition
procedures
SE 18A
IEP
development
and content
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The charter school does
not after the IEP has been
fully developed determine
the appropriate placement
to deliver services on a
student’s IEP. Also, the
placement selection by the
By October 14, 2005 the
district will train all special
education staff members:
1. Prior to a change in
placement, a Team
meeting must be convened;
2. Placement selected by the

Not
Applicable
None
The charter school only serves
students in grades kindergarten
through eighth.
Substantially
Implemented
Document
Reviews
The charter school’s IEP Teams
do develop IEPs with the
appropriate content.
Student
Record
Reviews
Interviews
SE 18B
Determination
of placement;
immediate
provision of
IEP to parent
Student
Record
Reviews
Partially
Implemented
Interviews
15
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

Team is not in all cases
the least restrictive
environment.
16
Team is the least restrictive
environment consistent
with student needs.
By January 17, 2006 the
district will submit a copy of
the following:
1. Training date(s)
2. Training agenda
3. Name(s) of presenter(s)
Sign-in sheet(s) that have staff
person’s name and their
positions.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 19
Extended
Evaluation
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Substantially
Implemented
Document
Reviews
Interviews
Document
Reviews
SE 20
Least restrictive
program
selected
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The charter school does
routinely conduct extended
evaluations if the Team finds a
student eligible for special
education and finds the
evaluation information
insufficient to develop a full or
partial IEP.
Partially
Implemented
Student
Record
Reviews
Substantially
Implemented
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

Student
Record
Reviews
SE 22
IEP
implementation
and availability
(Emphasis on
provision of
IEP services
Comments Regarding
Corrective Action Plan
Implementation
Interviews
Student
Record
Reviews
Interviews
The charter school has an IEP in
effect for eligible students at the
beginning of each school year
and begins IEP services without
delay once an IEP has been
accepted by the student’s
parents.
17
The charter school does
not provide small group
settings for students even
though the settings are
recommended by the IEP
team.
See findings under SE 18B.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


without delay;
provision of the
IEP at the
beginning of the
school year;
and, alternative
methods of
service delivery
where there is a
lack of space
and/or
personnel))
18
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 24
Notice to
Parent
regarding
proposal or
refusal to
initiate or
change the
identification,
evaluation, or
educational
placement of
the child or the
provision of
FAPE
SE 25
Parental
consent
SE 26
Parent
participation in
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Partially
Implemented
Student
Record
Reviews
Interviews
Substantially
Implemented
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The charter school does
not utilize N1 or N2
forms to notify parents of
its refusal to initiate or
change the identification,
evaluation, or educational
placement of the student.
Also, the charter school
does not utilize these
forms, the N1 and N2, to
notify parents of the
provision of FAPE.
By January 17, 2006, the
charter school must choose five
randomly selected student
records and provide copies of
the N1 or N2 forms to the
Department that were utilized
along with any other
supporting evidence including
parent referral letters.

Document
Reviews
Substantially
Implemented
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Student
Record
Reviews
Interviews
Student
Record
Reviews
The charter school obtains
informed parental consent as
required by state and federal
laws.
The charter school does
consistently ensure that parents
are part of the IEP Teams.
19
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
meetings
(Emphasis on
district’s
attempts to
ensure parent
participation at
IEP Team
meetings)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


Interviews
20
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 27
Content of
Team
meeting
notice to
parent
SE 28
Parent provided
the IEP or
notice of no
eligibility
together with
notification of
procedural
safeguards and
parents' rights
SE 29
Communications are in
English and
primary
language of
home
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Substantially
Implemented
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The charter school does
not consistently provide
an IEP to the
parent/parents
immediately following the
development of the IEP at
the Team meeting.
The charter school must
provide documentation of what
it presently provides to parents
immediately following the
development of the IEP at the
Team meeting.
This documentation is due at
the Department by January
17, 2006.

Student
Record
Reviews
Team notices contain the
required contents.
Student
Record
Reviews
The charter school does provide
parents with notification of
procedural safeguards and
parents’ rights.
Interviews
Substantially
Implemented
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Document
Reviews
Interviews
The charter school does provide
information to a parent or
parents in the native language of
the home, when it is necessary.
21
Partially
Implemented
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Partially
Implemented
The charter school’s PAC
is not active and it does
not have any officers or
by-laws.
Partially
Implemented
The charter school does
not provide a full
continuum of services for
students enrolled.
The charter school along with
the current PAC members must
create by-laws and elect
officers for its parent advisory
council. The charter school
must provide a copy of its bylaws and a list of its officers
indicating what role that they
serve to the Department by
January 17, 2006.
The charter school must submit
to the Department a list and a
description of the continuum of
services that it provides to the
students enrolled from the least
restrictive to the most
restrictive educational setting.
This requirement is due at the
Department by January 17,
2006.

Student
Record
Reviews
SE 32
Parent advisory
council for
special
education
The charter school has
established a parent advisory
council (PAC).
Interviews
Document
Reviews
SE 34
Continuum of
alternative
services and
placements
SE 37
Procedures for
approved and
Method(s)
of Verification
Student
Record
Reviews
Not
Applicable
None
The district is a Commonwealth
Charter School.
22
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


unapproved
out-of-district
placements
23
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 38
Educational
services in
institutional
Settings (ESIS)
SE 39
Procedures used
to provide
services
to eligible
students
enrolled in
private schools
at a private
expense
SE 42
Programs for
young children
three and four
years of age
SE 43
Behavioral
interventions
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

Substantially
Implemented
Interviews
The charter school implements
its responsibilities to students in
institutional settings.
Not
Applicable
None
The district is a Commonwealth
Charter School.
Not
Applicable
None
The charter school only serves
students in grades kindergarten
through eighth.
Document
Reviews
Partially
Implemented
24
The charter school does
not in all cases conduct
behavioral assessments or
By October 14, 2005 the
charter school will train all
special education staff,
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
create behavioral
intervention plans for
students whose behavior
impedes their learning or
the learning of others.
including the Director, the
disciplinarian, and, the
psychologist that positive
behavioral interventions must
be:
Implemented within the
1. general education
classroom before referring
the student to alternative
programs;
2. Procedurally implemented
on a consistent basis
throughout the district;
3. Implemented on a
consistent basis as
indicated by a student’s
IEP.
By January 17, 2006 the
district will submit a copy of
the following:
1. Training date(s)
2. Training agenda
3. Name(s) of presenter(s)

Student
Record
Reviews
Interviews
25
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

4. Sign-in sheet(s) that have
staff person’s name and
position.
26
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Not
Implemented
Interviews
SE 49A
Special
transportation
Not
Applicable
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The charter school does
not provide the related
services for each eligible
student, as indicated on
his/her IEP.
The charter school must
provide copies of 10 randomly
selected service delivery grids
for students and any
documentation to evidence that
the students received the
services that were required on
the IEP. Also, the charter
school must submit a list of the
related services that it provides
to its students along with the
names and qualifications of the
individuals that provide them.
These requirements are due at
the Department by January
17, 2006.

Student
Record
Reviews
SE 49
Related
services
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
None
The charter school is
responsible for the provision of
special transportation only for
students who reside outside of
the district in which the charter
school is located. By the terms
of its charter, the Robert M.
27
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


Hughes Charter School does not
enroll students who reside
outside of
the district.
28
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 50
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Responsibilities
of the School
Principal and
Administrator
of Special
Education
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The charter school does
not currently have a
District Curriculum
Accommodation Plan
(DCAP). Also, the
charter school did not
provide any
documentation on the
duties and responsibilities
of the director as they
pertain to the process.
The charter school must
develop a DCAP, which may
be part of a multi-year strategic
plan. Also, the charter school
needs to ensure that the
director of the school or his/her
designee has oversight of the
process.
By October 14, 2005 the
charter school will ensure that
the director fulfills all required
elements of the curriculum
accommodation plan and that
all staff members are trained
on these requirements (refer to
MOA 18 in the 2005 –
2006 Coordinated Program
Review School District
Information Package for
further details).
By January 17, 2006, the
charter school will submit a
copy of the following:

Document
Reviews
(MOA 18 in
2005-2006
monitoring
instruments)
Comments Regarding
Corrective Action Plan
Implementation
The charter school has
appointed a director and a
special education administrator.
Student
Record
Reviews
Interviews
29
Partially
Implemented
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

1.
2.
3.
4.
30
Training date(s)
Training agenda
Name(s) of presenter(s)
Sign-in sheet(s) that have
staff person’s name,
and position.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 53
Use of
paraprofessiona
ls
SE 54
Professional
development
regarding
special
education
SE 56
Special
education
programs and
services are
evaluated
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The charter school does
not have a formal process
in place to evaluate its
special education
programs and services.
The charter school must draft a
proposal of how it plans to
regularly evaluate its special
education programs, services,
and administrative areas. A
copy of this proposal must be
provided to the Department by
January 17, 2006.

Not
Applicable
None
Substantially
Implemented
Document
Reviews
Interviews
The charter school currently
does not employ any
paraprofessionals.
The charter school considers the
needs of all staff in developing
training opportunities and
provides a variety of offerings,
which include the required
topics.
Document
Reviews
Not
Implemented
Interviews
Civil Rights
Requirements
31
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Although the charter
school has completed
home language surveys
for all students, it has not
completed the required
screening instruments for
those students indicating a
first language other than
English at home and
therefore cannot
adequately determine how
many students must be
classified as limited
English proficient.
The charter school has
developed a useful policy
manual for its ELE
program, but to date has
not created an adequate
SEI program for eligible
students.
The district must complete the
required testing and forward
the results to the Department of
numbers of students
determined to be LEP based on
the results by January 17,
2005.

MOA 1
Identification
of
limited English
proficient
students
Partially
Implemented
MOA 2
Program
modifications
and support
services for
limited English
proficient
students
Not
Implemented
32
The charter school must
implement the requirements of
an ELE program for those
students identified as limited
English proficient and describe
to the Department all elements
of the full implementation of
this program by January 17,
2005.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
MOA 3
Access to full
range of
education
programs
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Substantially
Implemented
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The charter school has a
policy statement
regarding pregnant
students, but the policy is
deficient because it
requires pregnant students
to obtain a doctor’s
excuse for activities to be
avoided.
By October 14, 2005, the
charter school must develop a
new policy for pregnant
students that meets all of the
requirements under this
criterion. A copy of this new
policy must be submitted to the
Department by January 17,
2006.

Document
Reviews
The charter school provides all
of its students access to its
education programs.
Student
Record
Reviews
Interviews
Document
Reviews
MOA 6
Availability
of in-school
programs for
pregnant
students
MOA 7
Information
to be
translated into
languages
other than
Method(s)
of Verification
Partially
Implemented
Interviews
Substantially
Implemented
Document
Reviews
Interviews
The charter school does
translate general announcements
and notices of extracurricular
activities and other
opportunities in the primary
language of the home.
33
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


English
34
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

MOA 13
Availability of
information and
counseling on
general
curricular
and
occupational/
vocational
opportunities
Substantially
Implemented
MOA 14
Counseling and
counseling
materials free
from bias and
stereotypes
Substantially
Implemented
MOA 17A
Use of physical
restraint on any
student enrolled
in a publicly
Substantially
Implemented

Document
Reviews
Student
Record
Reviews
The charter school does offer
information and counseling on
the general curriculum and
occupational/vocational
opportunities to all of its
students.
Interviews
Document
Reviews
Interviews
Document
Reviews
Interviews
The charter school ensures that
counseling and counseling
materials are free from bias and
stereotypes on the basis of race,
color, sex, religion, national
origin, sexual orientation,
disability, and homelessness.
The charter school has
developed and implemented
staff training at least annually
on the use of restraint consistent
with regulatory requirements.
35
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


funded
education
program
MOA 23
Comparability
of
facilities
Substantially
Implemented
Document
Reviews
The charter school provides
equitable facilities for all of its
students.
Interviews
Observations
Title I
Requirements
36
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
TI 8
Evidence
regarding
selection of
LEP students
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Substantially
Implemented
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Although the charter
school has a school-parent
compact, there is no
evidence of a parental
involvement policy that
meets the required
information for this
criterion.
By October 14, 2005 adopt, in
writing, policies and
procedures for parental
involvement that meet the
criteria and ensure that this
policy is adopted in
collaboration with parents and
distributed to them in the
language of the home. A copy
of these policies and
procedures must be received at

The charter
school has
completed a
statement
indicating
that LEP
students are
served on
the same
basis as
other
students.
No further action is required.
TI 11
Evidence of
written policies
and procedures
for parental
involvement
Partially
Implemented
37
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be Substantially
Implemented
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

the Department by January
17, 2006.
TI 24
Evidence of
comprehensive
needs
assessment
Substantially
Implemented
The charter
school
presented
evidence of
a comprehensive
needs
assessment
The charter school shall
continue to conduct a
comprehensive needs
assessment on an annual basis.
TI 24A
Establish a
mechanism to
annually
evaluate the
effectiveness of
the Title I
program and
services
Not
Implemented
38
The charter school has not
established a mechanism
to annually evaluate the
effectiveness of the Title I
program and services.
By October 14, 2005, have in
place a mechanism to evaluate
the effectiveness of the Title I
program and services and
complete an evaluation of the
2004-2005 school year
program using this procedure.
A copy of the written
description of this mechanism
and a copy of the evaluation
for the 2004-2005 school year
is due at the Department by
January 17, 2006.
39