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 January 24, 2007 David Papagni, Superintendent –Director Southern Worcester County Regional Vocational School District Bay Path Regional Vocational Technical High School 57 Old Muggett Hill Road Charlton, MA 01507 Re: Mid-cycle Coordinated Program Review Report Dear Superintendent-Director Papagni: 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 South Worcester County Regional Vocational School District Coordinated Program Review Report issued on June 23, 2004. 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'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 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 selfassessment, is providing you in this report with findings on your ELE program and, where necessary, 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 781-338-3534. 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 February 9, 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 781-338-3947. Sincerely, Jean E. Jonker, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene A. Lynch, Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Benjamin LaMountain, School Committee Chairperson Timothy Gilrein, District Program Review Follow-up Coordinator Encl.: Mid-cycle Coordinated Program Review Report 2 MASSACHUSETTS DEPARTMENT OF EDUCATION MID-CYCLE COORDINATED PROGRAM REVIEW REPORT ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS Southern Worcester County Regional Vocational School District Date of Coordinated Program Review (CPR): March 1-4, 2004 Date of Coordinated Program Review Corrective Action Plan Approval: September 21, 2004 Dates of Progress Reports: January 5, 2005, June 9, 2005, August 16, 2005, December 1, 2005, June 15, 2006 Dates of this Mid-cycle Review Onsite Visit: November 14-15, 2006 Date of this Report: January 24, 2007 Criterion Number/ Topic (Refer to full text of 20062007 CPR requirements) SPECIAL EDUCATION Approved Corrective Action Implemen -ted and Effective PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS. Corrective Method(s) Basis of Determination that Action Not Basis of Determination of Corrective Action was Implementhat Implementation Verification Implemented and has been ted or Not of Corrective Action Effective Effective was Incomplete or or New Ineffective or Issues Basis of Finding of New Noncompliance Required Corrective Action, Timelines for Implementation, and Progress Reporting Criteria SE 1 Assessments are appropriately selected and interpreted DocumentReview, Student Record Review, Interviews The district has met its obligation in this area. Assessments used include ageappropriate evaluations, individualized to address specific suspected disabilities. The district uses information from a variety of sources to ensure placement in a least Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 1 of 33 Criterion Number/ Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemen -ted 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 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 restrictive environment. SE 2 Required and Optional Assessments SE 18A IEP Development and Content Partial Document Review, Student Record Review, Interviews The district has met its obligation in this area. The record review indicated that students are assessed in all areas of suspected disability. Student Record Review, Interviews The record review indicated that the Team uses evaluation data to guide development of annual goals. Partial Not all IEP goals are measurable, are not always individualized and do not always include specially designed instruction. The district is to conduct training for Special Education Team Chairpersons, and Special Education Teachers, on writing individualized measurable goals and on specially designed instruction. Provide to the Department of Education, by May 31, 2007, evidence of training to include attendance (name, title, role), and the agenda. Conduct a random review of IEPs to check that this element is fully in compliance. Report to the Department steps taken by the district if non-compliance is found during the review and the person responsible for ensuring that this criterion is met, and results of a follow-up review by May 31, 2007. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 2 of 33 Criterion Number/ Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemen -ted and Effective Method(s) of Verification Documents, Student Record Review, Interviews of personally identifiable information Student Record Review, Interviews SE 26 Parent Participation in Meetings Student Record Review, Interviews SE 20 Least Restrictive Program Selected SE 23 Confidentiality Partial Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented or Not Effective or New Issues 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 Parents do not always attend IEP Team meetings, and not all records contained documentation regarding the district’s attempts to facilitate the parents’ participation. Conduct training with all staff assigned as IEP chairpersons, and those who on any occasion fulfill the chairperson’s role, on the need to document multiple attempts to facilitate parent attendance/ participation at IEP Team meetings. The district has met its obligation in this area. Documentation and record review indicated that students are placed in the least restrictive environment. The district has met its obligation in this area. The district protects the confidentiality of any personally identifiable information that is collected, used or maintained. Team meetings are held in an area that provides privacy. The district consistently provides parents with the required written notice prior to conducting a Team meeting. The district coordinates a meeting time with the parent before issuing the Team meeting notice, to ensure parent participation. Partial Provide to the Department, by May 31, 2007, evidence of training to include attendance (name, title, role) Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 3 of 33 Criterion Number/ Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemen -ted 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 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 the agenda. After the training, conduct a review of records from students whose parents did not attend a Team meeting to determine compliance with this criterion, and report the results to the Department by May 31, 2007. Include any steps taken by the district to correct non-compliance if found and the person responsible for implementing corrective action pertaining to this criteria. SE 29 Communications are in English and primary language of the home Partial Documents, Student Record Review, Interviews See comment to right. Partial Some communications are in English and the primary language of the home; however, not all elements of the IEP including progress reports are provided in the language of the home. No later than May 31, 2007, the district will submit revised procedures that provide for translation services that meet state and federal requirements. Specifically, the district must describe how it will provide translation services for all elements of the IEP process and documentation when the primary language of the home is other than English. Include a description of how it will ensure that individuals who provide verbal translations are fluent in the primary language of the home Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 4 of 33 Criterion Number/ Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemen -ted 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 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 are familiar with special education procedures, programs and services. The district must describe how verbal translations and other modes of communication are documented in the student records. In addition, submit a sampling of translated IEP’s including notification letters and progress reports. SE 32 Parent Advisory Council for Special Education SE 34 Continuum of Alternative Services and Placements Documents, Interviews The district has met its obligation in this area. The district has established a parent advisory council that has bylaws, regularly meets and serves in an advisory capacity for the school committee. The district and the PAC conduct an annual workshop on the rights of students and parents under state and federal special education laws. Documents, Student Record Review, Interviews The district has met its obligation in this area. The district provides a continuum of services that meets the needs of special education students. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 5 of 33 Criterion Number/ Topic (Refer to full text of 20062007 CPR requirements) Approved Corrective Action Implemen -ted 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 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 Students receive support in both academic and technical courses. SE 45 Procedures for Suspensions up to 10 days and after 10 days: General Requirements SE 49 Related Services SE 50 Responsibilities of the School Principal and Administrator Documents, Student Record Review, Interviews The district has met its obligation in this area. The district provides services, including related services, to students who are suspended up to and after 10 days. Student Record Review, Interviews Students are provided with related services as required by their IEPs. Documents, Interviews The district has met its obligation in this area. The district has a Director of Special Education and also has a District Curriculum Accommodation Plan (DCAP) Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 6 of 33 Criterion Number/ Topic (Refer to full text of 20062007 CPR requirements) of Special Education Action Implemen -ted and Effective SE 53 Use of Paraprofessionals Documents, Interviews The district has met its obligation in this area. Paraprofessionals are appropriately trained and are not required to design instruction. Documents, Interviews The district has met its obligation in this area. All required topics regarding special education are annually covered in the district’s professional development plan. Onsite Observation, Interviews The DOE inspected all facilities issues noted in the 2004 CPR, and all issues have been since corrected. SE 54 Professional Development Regarding Special Education SE 55 Special Education Facilities and Classrooms Approved Corrective 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 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 in place. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 7 of 33 Criterion Number and Topic Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Student Record Review, Document Review, Interviews The district has a form to document transition planning for students at age 15 or older. 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 Not all student records contained evidence of transition planning for students age 15 or older. No later than May 31, 2007, the district will submit evidence of training staff on the requirements for sections #1-6 of this criterion to ensure that the forms are complete and filed in student records. Include attendance (name, title, role), and the agenda. Document the results of the district’s periodic internal monitoring for compliance with this standard. Develop a checklist with the items listed in sections 1 – 6 of this criterion. Select a sample of student records for recently conducted team meetings where transition services were discussed and report the rate of compliance. The Special Education Criteria created or revised in response to IDEA-2004 SE 6 Determination of Transition Services Partial Partial Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 8 of 33 results should indicate the date the review was conducted, the number of records reviewed and a description of additional steps taken where noncompliance was noted. Identify the person(s) responsible for conducting the review and the person(s) responsible for follow-up activities. Report to the Department by May 31, 2007. SE 8 IEP Team composition and attendance Partial Student Record Review, Document Review, Interviews Team meetings had the required persons in attendance. Partial The Annual Review Team Meeting Notice informs parents that they are limited to selecting no more than two classroom teachers, and that in doing so, a current team member would need to be eliminated. Some teachers leave a written report if they cannot make the meeting and not all OT, PT and SLP staff attend team meetings. Some meetings are held when parents do not show up for the scheduled meeting. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 9 of 33 Revise and submit, by May 31, 2007, a copy of the Annual Meeting Notice. The district must provide training to staff regarding the requirements in sections #113 of this criterion. The district will develop a protocol which provides enough time to ensure that all participants are able to attend the Team meeting, including alternate means, or provides for the rescheduling of the Team meeting if needed. The district will submit a copy of the protocol. The district will monitor attendance for annual review Team meetings to ensure that at least one teacher or specialist trained in the area of the student’s suspected special needs, and one regular education teacher attends the Team meeting. See also the Department’s corrective action order for SE 26 regarding parent attendance/participation. Evidence of training to include attendance (name, title, role) and the agenda. Document the results of the district’s periodic internal monitoring for compliance with this standard. Inform teaching staff by way of a memo and verbally at a staff meeting, of the federal and state regulations for Team meeting attendance. Provide the Department with evidence of the memo and staff meeting by May 31, 2007. Develop a checklist with the items listed in sections 1 – 13 of this criterion. Select a sample of student records for recently conducted team meetings and report the rate of compliance. The results should indicate the date the review was conducted, the number of records reviewed and a description of additional steps taken where Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 10 of 33 non-compliance was noted. Identify the person(s) responsible for conducting the review and the person(s) responsible for follow-up activities. Report to the Department by May 31, 2007. SE 12 Frequency of re-evaluation Partial Student Record Review, Interviews The district conducts a reevaluation whenever it is suspected that a student is no longer eligible for special education. Partial The record review and interviews indicated that the district does not always conduct a reevaluation every three years consistent with the requirements. The district is to conduct staff training on the requirements of section 1 of this criterion. Evidence of training to include attendance (name, title, role), and the agenda should be provided by May 31, 2007. Develop a tracking system for monitoring timelines, including relevant documentation, for reevaluations. Provide the Department with a description of the tracking system. Conduct a review of timelines and evaluations completed to include determining the factors for any timeline and evaluation completion violation; and design interventions in response to all noncompliance found, and identify the person(s) Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 11 of 33 responsible for follow-up. Report to the Department on these activities by May 31, 2007. SE 13 Progress Reports and content The record review and documentation indicate that progress reports are regularly provided to parents. Not all goals and benchmarks were addressed in progress reports. The district is to conduct training for service providers during the 2006-2007 school year on the IDEA 2004 requirements of SE 13, Progress Reports and Content and for the provision of translated progress reports (See SE 29 and MOA 7). Submit evidence of training to include attendance (name, title, role), and the agenda by May 31, 2007. Document the results of the district’s internal monitoring for compliance with this standard. After the training, select a sample of student records from each grade level for recently provided progress reports including a sample of those provided in languages other than English. The results should indicate the date the review was conducted, the number of records reviewed and a description of additional Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 12 of 33 steps taken where noncompliance is noted. Identify the person(s) responsible (title, role) for conducting the review and the person(s) responsible (title, role) for follow-up activities. Report to the Department by May 31, 2007. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 13 of 33 Criterion Number and Topic SE 14 Review and revision of IEPs SE 25B Resolution of disputes SE 33 Involvement in the General Curriculum Criterion Implemented Method(s) of Verification Basis of Determination that Criterion was Implemented Interviews and record review IEPs are reviewed annually. Documentation, Student Record Review, Interviews The district has met its obligation in this area. The district convenes a meeting with the parent and relevant Team members within 15 days of receiving notice that the parent has requested an official hearing with BSEA. Documentation, Student Record Review, Interviews The district has met its obligation in this area. Staff understand the MA Curriculum Frameworks and the expectations of the state for student performance as well as understanding the rights of students with disabilities to be full participants in the general curriculum. Criterion Determined to be Partially Implemented or Not Implemented Basis of Determination that Criterion was Partially Implemented or Not Implemented Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 14 of 33 Required Corrective Action, Timelines for Implementation, and Progress Reporting SE 39A Procedures for services to eligible private school students whose parents reside in the district Not Applicable (SE 39A does not apply to charter schools or vocational schools) SE 39B Procedures for services to eligible students in private schools in the district whose parents reside out of state Not Applicable (SE 39B does not apply to charter schools or vocational schools) SE 46 Procedures for suspension of students with disabilities more than 10 days Documentation, Student Record Review, Interviews The district has met its obligation in this area, and adheres to its procedures for students with disabilities whose suspensions exceed 10 consecutive school days or a pattern has developed for suspensions exceeding 10 cumulative days. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 15 of 33 Criterion Number/ Topic (Refer to full text of 20062007 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, 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 Partial The district is in the process of translating general materials into languages other than English and developing a procedure to provide for translated information and materials in low incidence languages. Required Corrective Action, Timelines for Implementation, and Progress Reporting Requirements Civil Rights (MOA) and Other General Education Requirements MOA 3 Access to a Full Range of Education Programs MOA 7 General Information and Materials in Languages Other than English Partial Documents, Student Record Review, Interviews The district has met its obligation in this area. All students with disabilities have access to the full range of academic and technical programs. Documents, Interviews See comments to the right. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 16 of 33 The district must provide translated general materials in the native language of students and parents and must provide a process for ensuring that translated information and materials are provided to students and parents of low incidence languages. Provide the Department by May 31, 2007, copies of general information and materials that have been translated and provide a description of the district’s process to ensure that students and parents of low incidence languages are provided with translated information. If appropriate, include documentation to support the implementation of translation services in a language(s) other than English. MOA 10A Student Handbooks and Codes of Conduct MOA 11A Designation of Liaison/Coor dinator(s); Grievance Procedures The district submitted a copy the district’s student handbook and program of study. Partial Partial Document Review Document Review The district submitted a copy of the district’s student handbook. Partial Partial Review of the program of studies indicates that the nondiscrimination policy does not include ‘national origin’ or ‘sexual orientation’ as a category. Review of the student handbook indicates that the nondiscrimination policy does not include ‘national origin’ as one of the categories and the discipline procedures do not include procedures for students on Section 504 Accommodation Plans. Review of the district’s grievance policies and procedures are very specific with regards to sexual harassment and due process but do not reference other protected categories and due Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 17 of 33 No later than May 31, 2007, submit a draft of the student handbook that includes disciplinary procedures for students on Section 504 Accommodation Plans and an updated nondiscrimination policy and a draft of the program of studies that contains an updated non-discrimination policy. No later than May 31, 2007, submit a draft of the student handbook that includes an updated discrimination and harassment policy that includes all protected categories and their due process rights. process. Note: The district may use the same due process and investigation procedures outlined in its sexual harassment policy to investigate allegations of discrimination and harassment. If so, then the district must provide written notice in the student handbook that the same grievance procedures will be followed for allegations of harassment and discrimination. MOA 16 Notice to Students 16 or Over Leaving School Without a High School Diploma MOA 21 Staff training regarding civil rights responsibility Partial Document Review The district submitted a copy of the notice that is provided to students 16 or over who leave school without a diploma. See comment to the right. Partial Document Review Partial Partial The letter does not contain all of the required elements, specifically the requirement to provide written notice to the student’s parents or guardians. No later than May 31, 2007, the district must revise the notice to students who plan to leave school without a diploma, when they are at least 16 or older, to adhere to the required elements of this criterion. The district provides staff with civil rights training; however, contracted educational and related service providers are not aware of their civil rights responsibilities and are not provided training. The district is to develop a policy to ensure that outside educational and related service providers receive at least annual training on civil rights responsibilities including the prevention of discrimination and harassment on the basis of Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 18 of 33 students’ race, color, sex, religion, national origin and sexual orientation and the appropriate methods for responding to it in the school setting. The district must provide the above training to the outside educational and related service providers and submit a copy of the training agenda and attendance to the Department by Mary 31, 2007. Other Regulated Programs Monitored During this Mid-cycle Review Criterion Number/Topic (Refer to full text of 20062007 CPR requirements) CTE 4 / CVTE 3 Methods of measuring Approved Corrective Action Implemented and Effective Partial Method(s) of Verification Document Review, Interviews Basis of Determination that Corrective Action was Implemented and has been Effective Corrective Action Not Implemented, Not Effective Or New Issues Identified The district has taken steps to align career/vocational technical programs with the Vocational Technical Education Frameworks. Partial 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 Requirements At the time of the onsite, not all programs have been completed. The district did not demonstrate that the The district will submit documentation of the following: 1.The universal procedure the district will implement Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 19 of 33 academic and technical competency gain and competency attainment are appropriate. CTE 10/ CVTE 12 Strategies to improve career and technical skills for all students exist. CTE 11 / CVTE 16 Technology is used to improve academic and career and technical measurement of to document students students’vocational competency attainment. competency attainment 2. 2. Documentation from are consistently each shop evidencing the documented for each system to document student. competency attainment. Further, while teachers 3. Documentation that are required to provide parents/guardians receive completed competency competency checklists. checklist to the This information will be administration twice submitted with the Progress yearly, there was no Report due May 31, 2007. evidence that competency checklists are being sent home for students or parent/guardian review. The district provided copies of competency attainment checklist generated from Skills Manager (software), as well as Curriculum Guides and blank final exams for each program. Partial Document Review, Interviews Document Review, Interviews Some programs have been aligned to state/national industry certifications. Partial While progress has been made in aligning programs with relevant industry certifications, some programs are not aligned with the current Vocational Technical Education Frameworks. The district has made considerable progress in ensuring that technology is used to improve both academic and career/vocational technical education for all students, including the recent requirement of ensuring all students complete the career Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 20 of 33 Submit to the Department a plan, including a timeline, to align all programs with the Vocational Technical Education Frameworks. This information will be submitted with the Progress Report due May 31, 2007 education. safe online training, as well as increased access to the Media Center for technical teachers. The career/vocational technical programs are structured so that students acquire technological knowledge and skills, which includes the use of the district’s Media Center, as well as a school-wide Portfolio requirement as a graduation component. Additional Progress Reports on this criterion are not required. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 21 of 33 CTE 20 / CVTE 29 / CVTE 31 Instructional facilities meet the demands of the workforce including those for state of the art facilities, as well as for a healthy, safe environment. Partial Document Review, Interviews School administration is currently pursuing a building expansion project. Partial Despite the serious overcrowding issues faced in most of the technical programs, this school year the school accepted the largest incoming ninth grade class in the school’s history. While the district submitted a recently completed (11/13/2006) Statement of Interest Form (draft form, unsigned), demonstrating the school’s intent to apply to the MA School Building Authority, the district’s building expansion project has been on hold since 2002. Further, there was no evidence or documentation provided identifying the members of the Building Expansion Committee or that the committee currently exists. This past spring, the MA Division of Occupational Safety completed a technical assistance visit to the district. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 22 of 33 The district will submit to the Department documentation identifying members of the Building Committee and a status report regarding the building expansion project. This information will be submitted with the Progress Report due Mary 31, 2007 IMMEDIATELY: The district will submit documentation regarding the status of each safety item. This information is due Immediately. These items include the items listed below, noted in the report as having the greatest potential for causing harm: The current air ventilation rate does not provide acceptable exhaust ventilation in Auto Body. In Carpentry, half of the woodworking equipment is not connected to any dust collection system. As a result, there is a visible haze of dust in the shop when students are actively working in the shop – a potential to create an explosive dust environment. Several recommendations and corrective actions were outlined in the report. The district submitted a corrective action plan to the MA Division of Occupational Safety addressing their concerns, on July 12, 2006. CTE 21 / CVTE 36 The school has developed and implemented a system of program evaluation that includes, at a minimum, the four core indicators and program outcomes. Document Review, Interviews Based on documentation provided by the district, there was no evidence that the school has developed and implemented a system to regularly evaluate their curricula, teaching, and services. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 23 of 33 One student was observed using compressed air for selfcleaning. Unacceptable levels of carbon dioxide in traditional classrooms. Some of those classes required immediate action. Submit notification of the system implemented to evaluate curricula, teaching, and services. This information will be submitted with the Progress Report due May 31, 2007 CVTE 4 Information concerning career/vocatio nal technical education programs is provided to students and their parents/guardi ans at least once a year before students enter the programs, and in no case later than the beginning of ninth grade… New Issue CVTE 6 Individuals are appropriately admitted to the school and/or to career/vocatio nal technical education programs/cour ses within the school. New Issue Document Review, Interviews New Issue Document Review, Interviews New Issue Documentation and interviews revealed the following: 1. The district is currently using an admission application that is not in compliance with the Vocational Technical Education Regulations 603 CMR 4.00 Guidelines. 2. While the Student Handbook has been translated into Spanish, recruitment information and program outreach materials are not made available in languages other than English. Submit to the Department the following: 1. A revised admission application that is in compliance with the Vocational Technical Education Regulation Guidelines. Due date: Immediate. The district provides information to applicants regarding an Early Admission Process. However, such a process is not included in the district’s approved Admission Policy on file with the Department. The school’s admission application and policy is currently available only in English. The district inappropriately includes The district will submit, Immediately to the Department, a revised admission policy and application for the district’s postgraduate program. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 24 of 33 2. Copies of translated recruitment materials. This information will be submitted with the Progress Report due May 31, 2007 Submit, by May 31, 2007: 1. Copies of translated High School admission application and policy. 2. Documentation that the home language survey is removed the home language survey as part of the application package, which may have the effect of being discriminatory. The district does not routinely provide test accommodations, when necessary, for applicants taking the placement tests. from the application package. 3. Documentation of the process implemented to consistently provide test accommodations, as necessary, when administering placement tests. The district currently uses the same application for ninth graders, as they do for postgraduates. The district does not currently have a written, published admission policy and application for the postgraduate program. CVTE 18 Cooperative Education is implemented in accordance with applicable laws, regulations and policies. New Issue Document Review, Interviews The Cooperative Education Program Coordinator monitors and reviews worksites of the students in the program. New Issue Documentation and interviews revealed the following: 1. The Cooperative Education Program is not supervised by a person holding the required Cooperative Education Coordinator license. 2. A staff member from the school does not conduct an onsite safety Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 25 of 33 The district will submit to the Department the following documentation: 1. Notification that an appropriately licensed person is supervising the Cooperative Education Program. Include the name and certification. Due date: Immediate. 2. Documentation of the revised procedure that an review of the workplace prior to the student’s start date. The district currently sends employers a safety checklist for them to complete, relying on employers to conduct the safety review using the provided checklist. 3. The district currently uses the MA WorkBased Learning Plan to evaluate the employability skills and uses the weekly time cards to document general skills to be acquired for students participating in cooperative education. However, there was no evidence that the current reporting system requires employers to assess and document the acquisition of the safety & health, academic, technical, management & entrepreneurship and technological knowledge and skills acquired for each student during cooperative education. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 26 of 33 onsite safety review of Cooperative Education worksites are conducted prior to student’s placement. Due date: Immediate. 3. Documentation of the employer reporting system that assesses students’ safety & health, academic, technical, management & entrepreneurship and technological knowledge and skills acquired during cooperative education. This information may be submitted with the Progress Report due May 31, 2007. 4. Documentation that students’ accommodations are discussed and provided, as necessary during participation in the cooperative education program. This information may be submitted with the Progress Report due May 30, 2007. 4. Accommodations, where necessary, are not discussed for students with disabilities participating in the district’s cooperative education program. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 27 of 33 Southern Worcester County Regional Vocational School District Coordinated Program Review 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 Partial Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) The district does not annually assess the English proficiency of all limited English proficient (LEP) students. Required Corrective Action, Timelines for Implementation, and Progress Reporting Provide to the Department by May 31, 2007, documentation that identified LEP students are administered required annual assessments: the Massachusetts English Proficiency Assessment (MEPA) in grades 3-12 and the Massachusetts English Language Assessment – Oral (MELAO) in grades K-12. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 28 of 33 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 2 MCAS Participation ELE 3 Initial Identification ELE 4 Waiver Procedures 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 Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 29 of 33 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 5 Program Placement and Structure Not Implemented Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) The district does not provide LEP students with instruction based upon the requirements of this criterion. Required Corrective Action, Timelines for Implementation, and Progress Reporting Submit the following documentation by May 31, 2007: Explanation of how the district intends to deliver an English Language Learner program consistent with the requirements of Chapter 71A. Description of the English language support program in place for students K-12 for the 2006-07and 2007-08 SY. List of ELL students for the 06-07 SY. Indicate the grade level and the classroom placement of each student, as well as the type and amount of English language support that the student needs. Indicate when the student receives instruction that is based on the English Language Proficiency Benchmarks and Outcomes. Include a copy of their most recent annual language proficiency assessments. Qualifications of the ESL/ELD teacher(s), including copy of current certification and/or waiver Names of teachers participating in sheltered English instruction training for the 06-07 SY. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 30 of 33 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 6 Program Exit and Not Implemented Findings of Noncompliance Based on Department’s Review of Local ELE Self-Assessment (Criterion Determined to be Partially Implemented or Not Implemented) The district’s program exit and readiness procedures do not follow the requirements and the implementation guidance of this criterion. The district submitted some information about program exit procedures. Required Corrective Action, Timelines for Implementation, and Progress Reporting Provide the Department with written procedures for re-designating a student from LEP to FLEP, including the program exit Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 31 of 33 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 Readiness However, the district did not submit documentation regarding the specific procedures (e.g., test scores) in place to re-designate a student from LEP to FLEP status. criteria and the multiple measures used to make the determination. Submit the above documentation by May 31, 2007. ELE 7 Parent Involvement The district provides some translation services when requested; however, the district has not developed a mechanism that provides multiple opportunities and a variety of methods for including parents or guardians of LEP students in matters pertaining to their children’s education. Describe the district’s implementation practices in this area. Develop a mechanism for including parents or guardians of LEP students in matters pertaining to their children’s academic and technical education and submit to the Department by May 31, 2007. Partial Note: The district should provide multiple opportunities and a variety of methods for parent-teacher communication and document the availability of such opportunities. ELE 8 Declining Entry to a Program ELE 9 Instructional Not Implemented Partial The district does not provide LEP students with English language support to students whose parent/guardians have declined the student’s entry to a program based upon the requirements of this criterion. Develop an implementation plan for providing supports to LEP students whose parents decline entry into an ELE program that meets the requirements of this criterion and submit to the Department by May 31, 2007. The district provided a one-page summary of its efforts with regard to implementing ELE criteria; however, the district does not provide Develop and provide the Department with the following: Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 32 of 33 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Grouping ELE 10 Parental Notification ELE 11 Equal Access to Academic Programs and Services Partial Partial 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 students with ESL/ELD instruction at the appropriate proficiency level and based on the English Language Proficiency Benchmarks and Outcomes. Process for placing LEP students in instructional groupings; and Description of English language development curriculum. Provide the Department with evidence of the above, and with evidence that these have been shared with appropriate personnel in the district by May 31, 2007. The district has a parental notification letter (translated); however, the letter does not contain how the program will meet the educational strengths and needs of the student; how the program will specifically help the child learn English; the specific exit requirements; and the parents’ right to apply for a waiver, or to decline to enroll their child in the program. Review and revise the district’s parental notification letter so that it contains the required elements of this criterion and submit a copy of the letter, including translations, to the Department by May 31, 2007. The district’s implementation practices indicate that all LEP students have access to and are integrated into general education classrooms. In addition, LEP students can access all curriculum offerings, such as special education services and Section 504 Plans, provided they meet eligibility requirements; however, the district’s implementation practices do not provide LEP students with the opportunity to receive support services in a language that the student understands and the district’s DCAP does not address what support services are available for LEP students. The district should revise their implementation practices to meet the requirements of this criterion. Submit a copy of the revised implementation practices including the revised section(s) of the district’s DCAP to the Department by May 31, 2007. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 33 of 33 ELE Criterion Number and Topic ELE 12 Equal Access to Nonacademic and Extracurricular Programs Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment Partial ELE 13 Follow-up Support Partial ELE 14 Licensure Requirements Partial 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 district’s implementation practices indicate that all LEP students have access to nonacademic and extracurricular programs; however, the district’s implementation practices do not meet the requirements of this criterion because LEP students are not provided with translators or translated materials to ensure equal access to the programs. The district should revise their implementation practices to meet the requirements of this criterion. The district provides support to LEP students; however, the district does not actively monitor LEP students as required by this criterion. Describe the district’s plan to provide follow-up monitoring for students who have exited the ELE program and submit to the Department by May 31, 2007. All teachers in the district hold either a teaching or vocational license but have not all had training in sheltering content instruction. See ELE 15 for further details. The district does not have any staff that hold current ESL teacher licenses or an approved ELL waiver for staff who provide English language development instruction. The district is advised that even if it has only one identified ELE student requiring ESL instruction, it must hire or contract with appropriate personnel to provide English language development instruction. Submit to the Department, by May 31, 2007 evidence that LEP students are receiving English language development instruction from an appropriately licensed teacher as required by this criterion. Provide a copy of the students’ weekly instructional schedules that indicate the receipt of services along with the staff person’s name and copy of license. Submit a copy of the updated implementation practices to the Department by May 31, 2007. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 34 of 33 ELE Criterion Number and Topic Criterion Determined to be Implemented Based on Review of Local ELE Self-Assessment ELE 15 Professional Development Requirements Not Implemented ELE 16 Equitable Facilities At the time of the review, the district met the requirements of this criterion. ELE 17 Program Evaluation Not Implemented In addition, the district has not developed an ongoing evaluation process to ensure the ELE program is effective. 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 district has not implemented a professional development plan that provides teachers and administrators with high quality training as prescribed by the Department to ensure the progress of LEP students in developing oral comprehension, speaking, reading and writing of English. The district must develop a professional development plan that meets the requirements of this criterion for teachers and administrators that provides high quality training as prescribed by the Department in: 1. Second language learning and teaching 2. Sheltering content instruction 3. Assessment of speaking and listening; and 4. Teaching reading and writing to limited English proficient students. The district must provide training opportunities for teachers of LEP students in developing oral comprehension, speaking, reading and writing of English. Submit a copy of the professional development plan to the Department by May 31, 2007 with copies of agendas, attendance sheets (name, title, role) and materials provided at the trainings of teachers and administrators. The district must develop a proposal for evaluating the effectiveness of its ELE program and submit it to the Department by May 31, 2007. Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 35 of 33 ELE Criterion Number and Topic ELE 18 Records of LEP Students- 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 (To be reviewed during next CPR visit.) Not Rated Southern Worcester County Regional Vocational School District Coordinated Program Review Mid-cycle Report January 23, 2007 Page 36 of 33