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 June 26, 2007 Joshua Phillips Roxbury Preparatory Charter School 120 Fischer Avenue Roxbury, MA 02120 Re: Mid-cycle Coordinated Program Review Report Dear Mr. Phillips: 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 Roxbury Preparatory Charter School Coordinated Program Review Report issued on September 10, 2003. 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 and the corresponding corrective action to be implemented. Your district is urged to request technical assistance in relation to any of these findings or this prescribed corrective action from me or from staff in the Department’s Office of Language Acquisition and Achievement at 781338-3534. ELE guidance documents are available on the Department’s website at http://www.doe.mass.edu/ell/ . While the Department of Education found your district to have resolved certain noncompliance issues, others were partially corrected or not addressed at all, or the Department’s onsite team identified new issues of noncompliance, either noncompliance with special education criteria added or substantially changed in response to IDEA 2004, noncompliance with ELE criteria, or other new noncompliance. Where the district has failed to implement its approved Corrective Action Plan, the Department views these findings to be serious. 1 In all instances where noncompliance has been found, the Department has prescribed corrective action for the district that must be implemented without delay. You will find these requirements for corrective action included in the attached report, along with requirements for progress reporting. Please provide the Department with your written assurance that all of the Department's requirements for corrective action will be implemented by your district within the timelines specified. You must submit your statement of assurance to me by July 13, 2007. 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 781-338-3792. Sincerely, Stacey Klasnick, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education William Cowan, Board of Trustees, Chairperson Dana Lehman, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT Roxbury Preparatory Charter School ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS Date of Coordinated Program Review (CPR): March 31-April 3, 2003 Date of Coordinated Program Review Corrective Action Plan Approval: December 9, 2003 Dates of Corrective Action Plan Progress Reports: June 22, 2004, October 15, 2004, February 15, 2005 and October 31, 2005 Dates of this Mid-cycle Review Onsite Visit: May 21, 2007 Date of this Report: June 26, 2007 PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 1 of 28 Criterion Number/Topic (Refer to full text of 2006-2007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective The student record review and document review demonstrated that assessments are appropriately selected and interpreted for evaluation. The student record review demonstrated that appropriately credentialed and trained specialists complete all required and optional assessments. The student record review demonstrated that assessment summaries 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 Special Ed. Criteria Cited in CPR Report and Monitored in Midcycle MOA 4 Dispropor-tionality (if Cited in the CPR Report) SE 1 Assessments Implemented Student record review and document review SE 2 Required and optional assessments Implemented Student record review SE 4 Reports of Assessment results Implemented Student record review Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 2 of 28 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 2006-2007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 9 Timeline for determination of eligibility Implemented Student record review SE 10 End of school year evaluations Implemented Student record review SE 11 Independent Evaluations Implemented Student record review SE 15 Outreach by the Implemented Document review 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 are completed prior to discussion with the Team and are made available to the parents at least two days prior to the Team meting. The charter school is meeting all timeline requirements for determination of eligibility and the provision of documentation to parents. The charter school completes end of year requests for evaluations within the required timelines. The charter school responds to all parental requests for independent evaluations as required by state and federal regulation. The charter school conducts annual Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 3 of 28 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 2006-2007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification school district SE 18A IEP development and content Basis of Determination that Corrective Action was Implemented and has been Effective Partial Student record review and document review 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 Partial The charter school does not create vision statements for students fifteen and older that reflect the student’s interests and preferences. The charter school must provide evidence of staff training of IEP development and content in the areas of vision statements for students fifteen and older and accommodations listed under State and school-wide Assessments to be consistent with the accommodations listed on PLEP A and PLEP B of the IEP. outreach to a variety of community agencies and their school. The charter school develops IEPs to include specifically designed instruction, measurable annual goals and is written in generally understandable language. The student record review demonstrated that accommodations listed under state and school-wide assessments aren’t consistent with the accommodations listed on PLEP A and PLEP B of the IEP. Please include the agenda, signed attendance sheet, and any training materials to the Department by October 5, 2007. The charter school will conduct an internal monitoring of IEPs for students fifteen years and older for at least a 3 month Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 4 of 28 Criterion Number/Topic (Refer to full text of 2006-2007 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 period post-training to ensure that vision statements are including student preferences and interests. The monitoring will indicate the # of student records reviewed, the results of the review, the person responsible for the review, and any additional steps taken if non-compliance is found. The charter school will conduct another internal monitoring of a new sampling of IEPs instructional accommodations to ensure that they are consistent with the. MCAS accommodations. The monitoring will indicate the # of student records reviewed, the results of the review, the person responsible for the review, Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 5 of 28 Criterion Number/Topic (Refer to full text of 2006-2007 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 and any additional steps taken if non-compliance is found. Please provide the documentation to the Department by January 14, 2008. SE 18B Provision of IEP Partial Student record review and staff interviews The staff interviews indicated that the charter school provides the parent(s) with a copy of the service delivery grid at the conclusion of the IEP meeting. Partial The charter school is providing the service delivery grid, however, the charter school does not provide a written statement of the agreements reached at the conclusion of the IEP meeting. *Please note that the Department has recently changed the implementation requirements for providing an IEP “immediately” following its development in a Team Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 6 of 28 The charter school must provide evidence of staff training on the requirements pertaining to the “immediate” provision of the IEP to the parent. Please include the agenda, signed attendance sheet, and any training materials to the Department by October 5, 2007. The charter school will provide documentation provided to a parent at the conclusion of an IEP meeting from a sample of Criterion Number/Topic (Refer to full text of 2006-2007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 19 Extended Evaluations Implemented Student records SE 20 Least restrictive program provided Yes Student record review, document review, and staff interviews SE 21 School day and school year No Student record review 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 meeting. Refer to the Department’s Special Education website at http://www.doe.mass.ed u/news/news.asp?id=31 82 three IEP meetings held post-training. Please provide the documentation to the Department by October 5, 2007. The charter school does not indicate on IEPs whether disabled students require The charter school must conduct training for staff on annually determining the need for “Extended School The charter school conducts extended evaluations, as required and extended evaluations are not used to deny a program or services determined necessary by the Team. The charter school actively seeks to provide educational services in the least restrictive setting for disabled students. Please see the Department’s comments to the right. Corrective Action Not Effective Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 7 of 28 Criterion Number/Topic (Refer to full text of 2006-2007 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 extended year services. General education summer programs offered to all students enrolled in the school might not address the very specific needs identified by the IEP Team and documented in the student’s IEP that require specialized instruction, related services and other components of special education. Year” services for all students. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 8 of 28 Please include the agenda, signed attendance sheet, and any training materials to the Department by October 5, 2007. The charter school will conduct an internal monitoring of IEPs or IEP Amendments documenting the need for extended school year services for a 3- month period post-training to ensure that extended school year services are considered. The monitoring will indicate the # of student records reviewed, the results of the review, the person responsible for the review, and any additional steps taken if non-compliance is found. Criterion Number/Topic (Refer to full text of 2006-2007 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 Please provide the documentation to the Department by January 14, 2008. SE 24 FAPE Partial Student record review The student record review demonstrated that the charter school provides N-1 notices to parents. Partial The N-1 forms do not completely address the six required questions of the N1 form. The charter school must conduct training for the special education staff regarding writing N-1 notices that include addressing the six key questions. Please provide an agenda, signed attendance sheet, and training materials to the Department by October 5, 2007. The charter school will conduct an internal monitoring of N-1 forms for at least a 3 month period post-training to ensure that they address answering the six key questions. The monitoring will indicate the Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 9 of 28 Criterion Number/Topic (Refer to full text of 2006-2007 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 # of student records reviewed, the results of the review, the person responsible for the review, and any additional steps taken if non-compliance is found. Please provide the documentation to the Department by January 14, 2008. SE 27 Notice to Parents Partial Student record review The student record review indicated that the charter school is providing meeting invitations to parents. New Issue The Team meeting invitations are not accurately reflecting the meeting type and purpose. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 10 of 28 The charter school must conduct training for the special education staff regarding writing Team meeting invitations that include stating the specific meeting type and purpose. Please include an agenda, signed attendance sheet, and training materials to the Department by October 5, 2007. Criterion Number/Topic (Refer to full text of 2006-2007 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 The charter school will conduct an internal monitoring of Team Meeting Invitations for at least a 3-month period posttraining to ensure that they demonstrate the specific meeting type and purpose. The monitoring will indicate the # of student records reviewed, the results of the review, the person responsible for the review, and any additional steps taken if non-compliance is found. Please provide the documentation to the Department by January 14, 2008. SE 29 Communications are in English and primary language of home Implemented Student record review The student record review indicated that the charter school routinely translates IEPs, evaluations, and meeting Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 11 of 28 Criterion Number/Topic (Refer to full text of 2006-2007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective Student record review, document review, and staff interview Student record review and staff interview 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 notices in the parent’s primary language. The document review indicated that the charter school offers services to students with disabilities consistent with the identified needs of the students. The student record review and staff interviews indicated that specialized materials and equipment are specified in the students’ IEPs. SE 34 Continuum of services Implemented SE 35 Assistive Technology Implemented SE 43 Behavioral Interventions Implemented Student record review The charter school’s IEP Teams consider student behavioral needs and conduct Functional Behavioral Assessments when required. SE 50 Administrator of Special Education Implemented Document review The document review indicated that the charter school has appointed an Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 12 of 28 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number/Topic (Refer to full text of 2006-2007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 54 Professional Development Implemented Document review SE 53 Use of paraprofessionals Partial Staff interviews 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 Individual Needs Coordinator who is responsible for ensuring compliance with all federal and state special education laws. The document review indicated that the charter school provided training to all special education staff on state and federal requirements regarding identification, evaluation, and placement of students with disabilities. The charter school has employed one paraprofessional. New Issue The staff interviews indicated that the paraprofessional is designing instruction for students with disabilities. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 13 of 28 The charter school must provide a signed assurance statement from the Special Education Director of the charter school stating that paraprofessionals will not be used to design instruction. The charter school Special Education Director will Criterion Number/Topic (Refer to full text of 2006-2007 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 review with the teaching staff their responsibility to design the instruction that the paraprofessional staff will deliver. Please provide the written assurance and staff notification to the Department by October 5, 2007. SE 56 Program Evaluation Implemented Document review The document review indicated that the CoDirectors, the Special Education Director, and the Learning Specialist annually evaluate the special education program. The program evaluation includes an analysis of the following areas: Review of the end-of-the-year self-audit; Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 14 of 28 Criterion Number/Topic (Refer to full text of 2006-2007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Basis of Determination that Corrective Action was Implemented and has been Effective SE 57 Special education Child Count Implemented Document review 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 Review of staff evaluations; Review of family evaluation form; Review of student performance; Review of the Child Study Process; Review of the Continuum of Services; and Review of Professional Development. The document review indicated that the charter school maintains appropriate procedures to ensure that an accurate and unduplicated child count is provided. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 15 of 28 Required Corrective Action, Timelines for Implementation, and Progress Reporting Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Criterion Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Partial Student record, and document review The charter school provided a policy regarding their transition services. Partial The student record review indicated that the school is not using the mandated transition planning charts. The charter school will provide a revised copy of the school’s policy in regards to transition services to include the statement, “The discussion should begin no later than age fifteen regardless of grade level.” The charter school must also provide evidence of staff receiving training consistent with regulatory requirements for transition services. Special Education Criteria created or revised in response to IDEA-2004 SE 6 ##1 - 3 Determination of Transition Services *Pleases note that recently enacted IDEA2004 regulations have changed the requirements for transition planning. The transition-planning chart will become a mandated form, which should be maintained with the IEP, Refer to Administrative Advisory SPED 2007-1 for guidance at http://www.doe.mass.ed ue/sped/advisories/01_1 .html or the Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 16 of 28 Please include the agenda, signed attendance sheet, and any training materials by October 5, 2007. Department’s guidance on transitioning planning at http://www.doe.mass.ed u/sped/links/tranisiton.h tml. The charter school will conduct an internal monitoring of student transition planning charts for at least a 3- month period post-training to ensure that the appropriate chart is being implemented. The monitoring will indicate the # of student records reviewed, the results of the review, the person responsible for the review, and any additional steps taken if non-compliance is found. Please provide the documentation to the Department by January 14, 2008. SE 8 IEP Team composition and attendance Partial Student record review, document review, and staff interviews The charter school’s Special Education Director determines appropriate people to attend each Team meeting and ensures that attendance sheets are signed to verify attendance by the required Team participants. Partial The charter school’s local process does not include excusing Team members from IEP meetings when they are unable to attend. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 17 of 28 The charter school must create a process by which parents may excuse Team members from a meeting and document the parent’s consent. The charter school must conduct training to all staff regarding the process of excusing Team members from IEP meetings. Please include an agenda, signed attendance sheet, and training materials. Please provide the documentation to the Department by October 5, 2007. SE 12 Frequency of re-evaluation Implemented SE 13 Progress Reports and content Partial Student record review The student record review demonstrated that the charter school re-evaluates students every three years as required. Student record review, document review, and staff interviews The document review indicated that the charter school’s procedures for progress reports stipulate that when effective progress is not being made by the student, four courses of action can be taken: 1. The special education staff works with teachers to complete Child Study forms; 2. The special education staff works with the child’s parents/guardians to complete Child Study Forms 3. The special Partial While the school’s procedures indicate a Team meeting will be held for students with progress reports indicating the student is not making effective progress, the student record review and staff interviews indicated that the charter school does not reconvene the IEP Team when the progress report reflects lack of student progress. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 18 of 28 The charter school must conduct training to all staff regarding the school’s procedure for reconvening an IEP Team when the progress report reflects a lack of student success and ensuring that documentation is kept in the student record. Please include an agenda, signed attendance sheet, and training materials. Please provide the documentation to the Department by October 5, 2007. *Please note that recently enacted IDEA-2004 education staff compiles additional assessment information such as trimester grades, tutoring reports, standardized test scores; and 4. A Team meeting will be held. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 19 of 28 regulations have now changed the content requirements for IEP progress reports. Refer to Administrative Advisory SPED 2007-1 for guidance. The Department has changed the progress report form and it is now available on the Department’s Special Education website at: http://www.doe.mass.edu/sp ed/iep/eng_toc.html. Criterion Number and Topic Criterion Implemented SE 14 Review and revision of IEPs Partial Method(s) of Verification Basis of Determination that Criterion was Implemented Student record review The student record review demonstrated that IEP Teams meet annually, on or before the anniversary date of the implementation of the IEP to consider the student’s progress and to review, revise, or develop a new IEP or refer the student for a reevaluation, as appropriate. Criterion Determined to be Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Required Corrective Action, Timelines for Implementation, and Progress Reporting Partial The staff interviews indicated that the charter school is failing to issue a new IEP or generate an IEP Amendment when changing or adding services within the IEP period. The charter school must conduct training to all staff regarding writing an IEP Amendment when discussing changes or adding services to an existing IEP. Please include an agenda, signed attendance sheet, and training materials by October 5, 2007. The charter school will conduct an internal monitoring of IEP Amendments for a 3- month period post-training to ensure the appropriate use of an Amendment.. The monitoring will indicate the # of student records reviewed, the results of the review, the person responsible for the review, and any additional steps taken if non-compliance is found. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 20 of 28 Please provide the documentation to the Department by January 14, 2008. SE 25B Resolution of disputes Implemented Document review The charter school has not had any dispute resolution sessions, however, the document review indicated that the charter school’s policies contain all the required elements. SE 33 Involvement in the General Curriculum Implemented Student record review and staff interviews The student record review and staff interviews indicated that all students with disabilities participate in the general education curriculum. SE 39A Procedures for services to eligible private school students whose parents reside in the district Not Applicable This criterion does not apply to charter schools. (SE 39A does not apply to charter schools or vocational Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 21 of 28 schools) SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state Not Applicable This criterion does not apply to charter schools. (SE 39B does not apply to charter schools or vocational schools) SE 46 Procedures for suspension of students with disabilities more than 10 days Implemented Student record review, document review, and staff interviews The charter school has procedures consistent with federal requirements for the suspension of students with disabilities when such removals exceed ten days. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 22 of 28 Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemented and Effective Method(s) of Verification Implemented Document review 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 Civil Rights (MOA) and Other General Education Requirements MOA 1 Identification of limited English Proficient students The charter school identifies Limited English Proficient (LEP) students by using the following assessments: LAS R/W LAS Oral The LAS R/W and LAS oral are available in age spans from preschool to high school. The charter school has hired an ELE administrator who is qualified to administer the assessments. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 23 of 28 Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements Roxbury Preparatory Charter School 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 ELE 1 Annual Assessment Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Implemented Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting No corrective action is required. ELE 2 MCAS Participation Implemented No corrective action is required. ELE 3 Initial Identification Implemented No corrective action is required. ELE 4 Waiver Procedures Implemented No corrective action is required. ELE 5 Program Placement Implemented No corrective action is required. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 24 of 28 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) Required Corrective Action, Timelines for Implementation, and Progress Reporting The charter school’s policy states that LEP students may be redesignated as FLEP students when: He/She is deemed English proficient using the LAS R/W and MELA-O; and He/She is able to participate in the general educational program without the use of adapted or simplified English materials; and He/She performs at “proficient” levels on state-mandated assessments. The charter school must conduct training to all staff regarding the implementation of the charter school’s policy for re-designating LEP students. Please include an agenda, signed attendance sheet, and training materials. and Structure ELE 6 Program Exit and Readiness Partially Implemented Please provide the documentation to the Department by October 5, 2007. An interview with the ELE Administrator indicated that the charter school does not implement its own policy but rather re-designates LEP students on a case-by- case basis using some of the criteria stipulated in the policy and at other times not adhering to the policy. ELE 7 Parent Involvement Implemented No corrective action is required. ELE 8 Declining Entry to a Program Implemented No corrective action is required. ELE 9 Instructional Grouping Implemented No corrective action is required. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 25 of 28 ELE Criterion Number and Topic ELE 10 Parental Notification Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Partially Implemented Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting The charter school notifies parents in their primary/home language, as well as in English, regarding the ELE program their child is enrolled in. The letter does not contain the charter school’s specific exit requirements nor does it clearly identify the parents’ right to apply for a waiver. Please provide the Department with the charter school’s revised notice to parents to include the charter school’s specific exit requirements and the parents’ right to apply for a waiver. ELE 11 Equal Access to Academic Programs and Services Implemented Please provide the documentation to the Department by October 5, 2007. No corrective action is required. ELE 12 Equal Access to Nonacademic and Extracurricular Programs Implemented No corrective action is required. ELE 13 Follow-up Support Partially Implemented ELE 14 Licensure Requirements Implemented The student record review indicated that there is no formal monitoring of students who have exited an English learner education program, however, the staff interview indicated that students are monitored informally. Please provide the Department with a description of the charter school’s formal monitoring system for students who have exited an English learner education program by October 5, 2007. No corrective action is required. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 26 of 28 ELE Criterion Number and Topic ELE 15 Professional Development Requirements Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Implemented Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) Required Corrective Action, Timelines for Implementation, and Progress Reporting No corrective action is required ELE 16 Equitable Facilities Implemented No corrective action is required. ELE 17 Program Evaluation Implemented No corrective action is required. ELE 18 Records of LEP Students(To be reviewed during next CPR visit.) Partially Implemented The student records were missing ELE progress reports and evidence of follow up monitoring. The charter school will devise a checklist of items for ensuring the completeness of ELE records and distribute to appropriate staff. The charter school will conduct an internal monitoring for record completeness and indicate the # of student records reviewed, the results of the review, the person responsible for the review, and any additional steps taken if non-compliance is found. Please provide the documentation to the Department by October 5, 2007. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 26, 2007 Page 27 of 28