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 July 15, 2005 John Kosko Superintendent of Schools South Shore Vocational Technical High School 476 Webster Street Hanover, MA 02339 Re: Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action Plan Verification and Special Education Mid-cycle Review Dear Superintendent Kosko: 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 July 29, 2005. 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 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 July 29, 2005. 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 781-338-3714. Sincerely, Nancy S. Hicks, Coordinated Program Review Follow-up Chairperson Program Quality Assurance Services John D. Stager, Administrator Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Robert Molla, School Committee Chairperson Pamela Titus, District Program Review Follow-up Coordinator Maureen Francis, Director of Special Education Encl.: Follow-up Monitoring Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION COORDINATED PROGRAM REVIEW South Shore Regional Vocational Technical School ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Action Plan Submitted on October 21, 2002 Progress Reports Submitted on January 29, 2003 and May 28, 2003 Onsite Visit Conducted on May 25, 2005 and May 27, 2005 Date of this Report: July 15, 2005 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Special Education Requirements 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 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 3 Special requirements for determination of specific learning disabilities 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 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 record review indicated that the district used the form when the primary disability was not SLD. The form would only be used for initial and three-year reevaluations; however, the district used By October 14, 2005, the district must submit a description of the district’s procedures regarding the use of the form to certify the Team’s finding that a student has a specific learning disability. No sooner than January 4, 2006, the Department of Education will conduct a record review to confirm that the certification that a student has a SLD is correctly documented in conjunction with an evaluation as required. Documentation, Records, and Interviews A form was used to document the certification of the Team’s finding that a student has a specific learning disability. Partially Implemented the form annually as standard practice for any disability. 2 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) 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 transition) 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 Partially Implemented Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Documentation, Records, and Interviews The anticipated graduation date was included in the IEP. Partially Implemented Student records indicated that students were consistently invited to Team meetings and they most often attended. Student input was noted on the vision statement of the IEP. Partially Implemented Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Documentation, Records, and Interviews Progress reports were written on a form that included the IEP goal. Some progress reports contained specific information regarding the progress that was made on an annual goal and indicated if the progress was 3 Partially Implemented Post secondary transitional planning was not included in IEPs of students. The correlation between the student’s vision and longterm goals and the IEP goals and objectives was not expressed. Interviews indicated that the district provided many transitional supports but they are not documented in the IEP. No sooner than January 4, 2006, the Department of Education will conduct a record review to determine that transitional elements of the IEP are correctly documented. Student records indicated that progress reports did not all contain specific information. No sooner than January 4, 2006, the Department of Education will conduct a record review to determine: That progress reports contain specific When the district indicated that there was a lack of 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 sufficient for the student to achieve the goal by the end of the IEP period. 4 progress on a goal, there was no documentation of action taken by the district to address the issue. information on goals. That when a progress report indicates a lack of progress, there is documentation of the action taken by the district to address the issue. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 15 Outreach by the School District (Child Find) 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 Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting The record review indicated that goals were not always measurable. No sooner than January 4, 2006, the Department of Education will conduct a record review to determine: That IEPs contain measurable goals. That the PLEP B page of the IEP is completed appropriately. Interviews Partially Implemented Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Interviews indicated that the district used test results and teacher recommendations to identify a student who may need special education services. Not Applicable. The district provides services to students in grades 9-12 only. Documentation, Records, and Interviews The record review indicated that the Team developed an IEP using a standard form and it was written in generally understandable language. 5 Partially Implemented The PLEB B page of the IEP was not often completed. IEPs did not include age specific considerations. Behavior and social emotional 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 considerations were not checked when it was clear that these were student needs. 6 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 18B Determination of placement; immediate provision of IEP to parent SE 20 Least restrictive program selected SE 22 IEP implementation and availability 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 Documentation, Records, and Interviews Documentation, Records, and Interviews Documentation, Records, and Interviews After the development of the IEP, the Team determined the placement of the student. The record review indicated that the IEP was most often provided to the parent within three to five days of the Team meeting. Interviews and records indicated that the school consistently selected a placement that was in the least restrictive environment consistent with the needs of the student. Class size was consistently small and there were many Team taught classes or classes taught by teachers certified in both regular and special education. Records and interviews indicated that the IEP and services were implemented immediately. School personnel 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) (Emphasis on provision of IEP services 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)) 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 all were provided with a copy of the IEP at the beginning of the school year. 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 26 Parent participation in meetings (Emphasis on district’s attempts to ensure parent participation at IEP Team meetings) SE 28 Parent provided the IEP or notice of no eligibility together with notification of procedural safeguards and parents' rights SE 29 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 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 Documentation indicated that 47% of the Team meetings held over a threemonth period did not have a parent present. By October 14, 2005, the district must submit a plan to improve parent participation in Team meetings. Documentation and Interviews Documentation and Interviews Documentation indicated that parents who did not attend Team meetings were involved in alternate ways. Conference calls were often used to involve parents in the Team process. Efforts to involve the parent would be appropriately documented under Additional Information in the IEP. The district did not have any student records with a finding of no eligibility. Documentation indicated that the required notice would be provided. The school did not have any 9 Partially Implemented No sooner than January 4, 2006, the Department of Education will conduct a record review to monitor parent participation in Team meetings. Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) 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 Documentation and Interviews students whose primary language of home was not English. The district has developed procedures that would ensure that documents would be translated if required and that interpreters would be provided for parents if needed. 10 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 32 Parent advisory council for special education SE 50 Responsibilities of the School Principal and Administrator of Special Education SE 54 Professional development regarding special education SE 56 Special 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 Documentation and Interviews Documentation and Interviews Documentation and Interviews Documentation and The district had a parent advisory council for special education that met requirements. The principal with the assistance of the Administrator of Special Education coordinated the delivery and supervision of special education services within the school building. Services were provided as required for students at home or in the hospital. Training has been provided in the required topics. The district evaluated the effectiveness of their special 11 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) education programs and services are evaluated Other Requirements SE 1 Assessments SE 2 Required and Optional 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 Interviews Partially Implemented Record Review Partially Record Review and education program based on information on student success. Input from staff members was considered as well as the drop out and graduation rates. The record review indicated that counseling needs were included on students’ IEPs. Partially Implemented Educational assessments provided information regarding a student’s ability in relation to 12 Partially Assessments were not always tailored to assess specific areas of educational need. When a student has a suspected emotional disability, emotional needs were not consistently evaluated. For the three-year reevaluation, the assessment tools were not No sooner than January 4, 2006, the Department of Education will conduct a record review to determine: That assessments are tailored to address specific areas of educational need. That students’ behavioral and emotional needs are evaluated when required. No sooner than January 4, 2006, the Department of Education will Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) 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 Implemented SE 24 Parent Notice Interviews the learning standards of Massachusetts Curriculum Frameworks and the district curriculum. Record Review The notice to parent contained all required elements. Page 2 of the IEP Form N1 was included when notice was sent to parents and all questions were addressed. The district consistently obtained parent consent before completing an evaluation. Record Review Partially Implemented Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting always tailored to the area of educational need. Educational assessments did not include a history of the student’s educational progress in the general curriculum. conduct a record review to determine that assessment tools are tailored to the area of educational need and that the Educational Assessments include a history of the student’s progress in the general curriculum. Parent consent forms were not always consistent with the actual assessments that were administered. Frequently parents consented to assessments that were not completed. No sooner than January 4, 2006, the Department of Education will conduct a record review to determine that information on consent forms is consistent with the actual assessments that are completed. SE 25 Parent Consent Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Implemented 13 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 Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting For students whose behavior impedes their learning or the learning of others, the IEP did not always include information on how the behaviors impact progress in general education and did not include information on behavioral accommodations or modifications necessary for effective progress. No sooner than January 4, 2006, the Department of Education will conduct a record review to determine that IEPs contain information on how behavior impacts learning and behavioral accommodations and or modifications necessary for effective progress. SE 43 Behavioral Interventions Record Review and Interviews SE 46 Procedures for suspension of students with disabilities when suspensions exceed 10 school days Record Review and Interviews Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Student records indicated that the Team met to develop or review a functional behavioral assessment as required. The school meets to complete the functional behavior assessment before the student exceeded the 10 days of suspension. 14 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 49 Related Services 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 MOA 17 A Physical Restraints MOA 21 Civil Rights Training Method(s) of Verification Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Not all staff members received the mandated restraint training overview at the beginning of the school year. By October 14, 2005, the district must submit a dated agenda of the restraint training that was held during the first month of the school year. The district must also send a letter of assurance stating that newly hired staff members will receive training within a month of their employment. Interviews indicated that By October 14, 2005, the Record Review and Interviews Counseling services were included in a student’s IEP when recommended by the Team. Record Review and Interviews Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Interviews and Documentation Civil rights training has been provided for all school personnel. MOA 7 B 15 Criterion Number and Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Structured Learning Time 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 students were not receiving physical education as required. There were no physical education classes taught during the 20032004 and the 2004-2005 school years. district must submit to the Department the fall schedule of classes showing that all students are scheduled to receive physical education as required by law. Interviews 16