Massachusetts Department of Elementary and Secondary Education 75 Pleasant Street, Malden, Massachusetts 02148-4096 Telephone: (781) 338-3700 TTY: N.E.T. Relay 1-800-439-2370 June 20, 2012 Kim Nicoll, Head of School Gregory Woodward, Head of School Roxbury Preparatory Charter School 120 Fisher Avenue Roxbury, MA 02120 Re: Mid-cycle Report Dear Ms. Nicoll and Mr. Woodward: Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Report based on the onsite visit conducted in your district in November 2011. During the Mid-Cycle Review the Department monitored selected special education criteria to determine your district’s compliance with special education laws and regulations. The review consisted of information gathered from one or more of the following activities: interviews, review of student records, examination of documentation, and classroom observation(s). The Department determined that one or more of the criteria monitored in your district was “Partially Implemented” or “Not Implemented.” In all instances where noncompliance was found, the Department has prescribed corrective action for the district. This corrective action must be implemented as soon as possible, but in no case later than a year from the date of this report. You will find these requirements for corrective action included in the enclosed report, along with requirements for submitting progress reports using the enclosed form. Please provide the Department with your written assurance that all of the required corrective action will be implemented by your district within the timelines specified in the report. You must submit your statement of assurance to Darlene Lynch, Director, Program Quality Assurance Services, by July 6, 2012. 1 Your staff's cooperation throughout this Mid-cycle Review is appreciated. If you have questions about this letter or the enclosed report, please do not hesitate to contact Jane Ewing at 781-3383741. Sincerely, Jane L. Ewing, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services cc: Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education Dean Paolillo, Supervisor, Program Quality Assurance Services Greg Shell, Chairperson, Roxbury Preparatory Charter School Board of Trustees Julie Evans, Local Program Review Coordinator Encs: Mid-cycle Report Mid-cycle Progress Report Form 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REPORT ROXBURY PREPARATORY CHARTER SCHOOL Dates of the Mid-cycle Review Onsite: November 21, 2011 Date of this Report: June 20, 2012 PLEASE NOTE THAT THIS REPORT IS IN TWO SECTIONS. Required Special Education Criteria Monitored in this Mid-cycle Review Current special education criteria available by scrolling down to the special education instrument at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion SE 7 Transfer of parental rights and student participation and consent at age of majority Criterion Implemented Not Applicable Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation Roxbury Preparatory Charter School is a middle school serving grades 5-8. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 20, 2012 Page 9 of 9 (b) Progress Report Due Date(s) and Required Elements Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion Document Review According to interview and student record data, Roxbury Preparatory Charter School has an established process to ensure that required IEP Team members attend IEP meetings. Staff Interviews SE 8 IEP Team composition and attendance Student Record Review If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation (b) Progress Report Due Date(s) and Required Elements If a required IEP Team member cannot attend, the school ensures that the parent is notified in advance and offers to reschedule the meeting. If the parent consents to go ahead with the meeting, the district obtains the parent’s agreement to excuse the IEP Team member in writing. Excused required IEP Team members provide written input to Teams for IEP development. SE 18A IEP Development and content PI Document Review Staff Interviews Student Record A review of documentation and student records verified that the school has implemented training and developed procedures regarding the IEP Team’s obligation to document student needs in the IEP when the evaluation indicates that the student’s disability affects social Please ensure that IEP Team chairpersons are trained in the appropriate development and completion of the PLEP B. Please develop an internal monitoring system that includes tracking the completion of the PLEP B in student IEPs and the Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 20, 2012 Page 9 of 9 Please provide evidence of training provided to IEP Team chairpersons, including the signed attendance sheet indicating staff Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation (b) Progress Report Due Date(s) and Required Elements Review skills development or makes them susceptible to bullying, harassment, or teasing. The school’s procedures also address the requirements that the IEP specifically address the skills needed to address bullying for students on the autism spectrum. periodic review of student records for IEP completeness. Please identify person(s) responsible for this internal monitoring by name and title. name and role, the agenda, and training materials. Student records demonstrated that the school has actively supported student needs by developing IEPs that address the possibility of bullying, harassment, or teasing. Student record review indicated that IEP Teams are not consistently addressing a student’s age-specific considerations or language needs on the Present Level of Educational Performance (PLEP) B when applicable. Please select a sample of student records across grade levels to examine IEPs developed subsequent to the school’s implementation of its corrective actions for completion of the PLEP B section. Evidence should demonstrate that students’ PLEP B pages are appropriately completed, including for students with agespecific or language considerations. *Please note that when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade level for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 20, 2012 Page 9 of 9 Please provide a description of the internal review and tracking system and indicate the person(s) responsible for it by October 15, 2012. Please submit the report of the results of the internal review of records. Please include the number of records reviewed and the number of records in compliance. For all records not in compliance, please determine the root Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation signature(s). Document Review Staff Interview SE 25 Parental consent Student Record Review Documentation and interviews confirmed that the charter school has an appropriate policy for when a parent revokes consent for special education services. According to the school’s policy, the school sends a notice immediately to the parents prior to discontinuing all special education services, along with a copy of the parent’s right to procedural safeguards. Additionally, an interview with the Special Education Director verified that the district will not use mediation or request a due process hearing to obtain agreement or a ruling requiring the continuation of services, Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 20, 2012 Page 9 of 9 (b) Progress Report Due Date(s) and Required Elements causes(s) of the noncompliance and submit the district’s plan to remedy the noncompliance. This progress report is due January 14, 2013. Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation consistent with federal regulation. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 20, 2012 Page 9 of 9 (b) Progress Report Due Date(s) and Required Elements Additional Special Education Criteria Monitored in this Mid-cycle Review Current special education criteria available by scrolling down to the special education instrument at http://www.doe.mass.edu/pqa/review/cpr/default.html Criterion SE 3 Special requirements for determination of specific learning disability Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation PI Document Review Staff Interviews Student Record Review Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation The student record review indicated that school’s form for a Team’s Determination of Eligibility for Specific Learning Disability (SLD) did not contain space for IEP Team signatures (mandated form 28M/10). According to interviews, the incorrect version of the form was generated by the school’s contracted information management system. Please ensure that IEP Team chairpersons are trained in the development and completion of the revised IEP Team Determination of SLD Eligibility form. The special education coordinator of Roxbury Preparatory Charter School alerted the software company of the requirement for IEP Team member signatures on the Determination of SLD Eligibility form immediately following the mid-cycle review onsite visit (November 23, 2011). Please develop an internal monitoring system that includes tracking the appropriate documentation of SLD determinations and the periodic review of student records for Team signatures on the SLD Eligibility form. Please identify person(s) responsible for this internal monitoring by name and title. The district must conduct a review of student records after all other corrective actions have been implemented. Select a sample of student records across grade levels of students evaluated for SLD subsequent to the implementation of the school’s corrective actions to Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 20, 2012 Page 9 of 9 (b) Progress Report Due Date(s) and Required Elements Please provide evidence of training provided to IEP Team chairpersons, including the signed attendance sheet indicating staff name and role, the agenda, and training materials. Please also include a blank copy of the mandated form 28M/10 as currently generated by the school’s information management system. Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation review for the implementation of the SLD process. Evidence should demonstrate that SLD documentation is appropriately developed and signed by all IEP Team members. *Please note that when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade level for the record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s). Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 20, 2012 Page 9 of 9 (b) Progress Report Due Date(s) and Required Elements Please provide a description of the internal review and tracking system and indicate the person(s) responsible for it by October 15, 2012. Please submit the report of the results of the internal review of records. Please include the number of records reviewed and the number of student records in compliance. For all records not in compliance, please determine the root causes(s) of the noncompliance Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation (b) Progress Report Due Date(s) and Required Elements and submit the district’s plan to remedy the noncompliance. This progress report is due January 14, 2013. SE 4 Reports of assessment results Document Review Staff Interviews The student record review determined that all related services providers’ evaluation reports included educationally relevant recommendations to meet student needs. Student Record Review SE 26 Parent participation Document Review Staff Interviews Student Record Review The document review, record review and staff interviews determined that the charter school typically calls parents at least a month in advance to schedule the IEP meeting before sending a meeting invitation (N3). According to staff, the school sends the N3 to parents at least one school week prior to the Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 20, 2012 Page 9 of 9 Criterion Criterion Implemented Criterion Partially Implemented (PI) or Not Implemented (NI) Method(s) of Investigation Basis of Determination about Criterion If Partially Implemented or Not Implemented: (a) Required Corrective Action and Timelines for Implementation meeting. The school sampled 22 student records with annual meetings and eight records for re-evaluations between August and October 2011 to determine when the N3 was sent prior to the scheduled IEP meeting. On average, the N3 was mailed to parents at least 10 days prior to the scheduled meeting. In four cases, the meeting notice was sent between two to four days prior to the meeting. The district provided additional analysis of what happened in the four cases where N3s were sent within four days or less. In all four cases, parent rescheduling requests to hold the meeting earlier was the root cause for sending out N3s less than a week prior to the IEP Team meeting. Roxbury Preparatory Charter School Coordinated Program Review Mid-cycle Report June 20, 2012 Page 9 of 9 (b) Progress Report Due Date(s) and Required Elements MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION MID-CYCLE REVIEW ROXBURY PREPARATORY CHARTER SCHOOL M I D – CY C L E P R O G R E S S R E P O R T Date Prepared: ____________________________________ Prepared by: __________________________________________________________________ (name and title) Criterion: _______________________ Topic: ________________________________________________________________________ For each criterion for which you prepare a progress report, please make a copy of this cover page, fill in the information requested above, and attach a complete description of the corrective action taken and any accompanying documentation. (Description of corrective action for each criterion and any accompanying documentation should include all of the “Progress Report Required Elements” for that criterion in the Mid-cycle Report.) Send the whole set of completed progress reports to: Darlene Lynch, Director Program Quality Assurance Services Massachusetts Department of Elementary and Secondary Education 75 Pleasant Street Malden, MA 02148-4906