Massachusetts Department of
Elementary and Secondary Education
350 Main Street, Malden, Massachusetts 02148-5023
Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
April 24, 2007
Eric Hieser
Director
Sturgis Charter School
427 Main Street
Hyannis, MA 02601
Re: Mid-cycle Coordinated Program Review Report
Dear Mr. Hieser:
Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Coordinated
Program Review Report (Mid-Cycle 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
Sturgis Charter School Coordinated Program Review Report issued on May 10, 2004. The Midcycle Report also contains findings based on onsite monitoring of special education compliance
criteria that have been created or substantially changed in response to IDEA 2004.
Another component of the Department’s Mid-cycle Review is the review of your school district
or charter school's self-assessment in the area of English learner education (ELE). (In the
remainder of this letter, please read “district” as meaning “school district or charter school.”) The
purpose of this review is to determine whether your district is implementing the significant
changes in M.G.L. Chapter 71A, governing the education of limited English proficient students,
that were adopted by voters by means of Question 2 in 2002. The Department has reviewed your
district’s ELE self-assessment (documentation and any written analysis of compliance) and, based
solely on that self-assessment, is providing you in this report with findings on your ELE program
and the corresponding corrective action to be implemented. Your district is urged to request
technical assistance in relation to any of these findings or this prescribed corrective action from
me or from staff in the Department’s Office of Language Acquisition and Achievement at 781338-3534. ELE guidance documents are available on the Department’s website at
http://www.doe.mass.edu/ell/ .
While the Department of Elementary and Secondary 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 Thursday, May 17, 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 781-338-3726.
Sincerely,
Thomas Taylor, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
Olive Chase, Chairperson of the Board of Directors
Susan Lacombe, District Program Review Follow-up Coordinator
Encl.: Mid-cycle Coordinated Program Review Report
2
MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY
EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
Sturgis Charter School
ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS
Date of Coordinated Program Review (CPR): March 22-26, 2004
Date of Coordinated Program Review Corrective Action Plan Approval: June 28, 2004
Dates of Corrective Action Plan Progress Reports: January 17, 2006
Dates of this Mid-cycle Review Onsite Visit: January 16 and 17, 2007
Date of this Report: April 24, 2007
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 1 of 15
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
Special Ed.
Criteria Cited in
CPR Report and
Monitored in
Mid-cycle
MOA 4
Disproportionality
(if Cited in the
CPR Report)
SE 1
Assessments are
properly selected
and interpreted
for students
referred for an
evaluation
SE 2
Required and
optional
assessments
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective
Record Review
Record reviews indicated that
Educational Assessments Part
A & B are completed for
initial and re-evaluations, if
needed. Also, assessments
are provided prior to the
Team meeting.
Record and
Documentation
Reviews
Record and documentation
reviews indicate that in
addition to educational
assessments being completed,
optional assessments in
related areas are contracted
out with outside
professionals.

Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective or
Basis of Finding of New
Noncompliance
NA


Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 2 of 15
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
SE 4
Reports of
assessment results
SE 6
Determination of
transition services
SE 7
Transfer of
parental rights at
age of majority
and student
participation
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective

Record Review


Record and
Documentation
Reviews

Record and
Documentation
Reviews
Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective or
Basis of Finding of New
Noncompliance
Record review indicated that
all appropriate assessments
were found in the student
records.
Record and documentation
reviews indicate that
transition services discussions
are documented and reflected
in the students’ goals and
vision statements. A copy of
a transitional planning chart
was provided to the onsite
team.
Record/documentation
reviews and staff interviews
indicated that a letter and
signed statement addressing
consent at age of majority
was included in the students’
record.
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 3 of 15
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective
Record Review
Record review indicated that
Team meeting invitations and
Team attendance sheets were
in the students’ records. All
required Team members were
in attendance.

SE 8
IEP team
composition and
attendance

SE 9
Eligibility
determination

Record Review
SE 12
Frequency of reevaluation

Record Review
SE 13
Progress Reports
and content

Record Review
and Staff
Interviews
Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective or
Basis of Finding of New
Noncompliance
Record review indicated that
timelines were being met and
the 45-day timeline
requirement was being
adhered to.
Record review indicated that
re-evaluations were being
conducted every three years,
if there is a parental request
for re-evaluation, and if IEP
services are no longer needed.
Record review and staff
interviews indicate that
Progress Reports are
completed as often as regular
education students. Progress
Reports address the goals and
objectives of the student, and
the charter school has assured
the onsite team that a
summary of achievements,
functional performance and
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 4 of 15
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective

Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective or
Basis of Finding of New
Noncompliance
recommendations are
available to the student for
postsecondary activities.
SE 14
Review and
revision of IEPs

SE 18A
IEP development
and content

SE 18B
Determination of
placement;
provision of IEP
to the parent

Record Review
and Staff
Interviews
Record reviews and staff
interviews indicate that
annual reviews are completed
according to the timeline and
IEP amendments are handled
appropriately.
Record Review
Record reviews and staff
interviews indicated that the
charter school utilizes the
evaluation data and IEP Team
input to develop measurable,
annual goals for the student.
Record Review
and Staff
Interviews
Parents leave the IEP Team
meeting with a meeting
summary. A draft IEP is
worked on at the Team
meeting and the final IEP
mailed within 5 days.
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 5 of 15
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
SE 22
IEP
implementation
and availability
SE 24
Notice to parent
regarding
proposal or
refusal
SE 25B
Resolution of
disputes
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective
Record Review
and Staff
Interviews
The IEP is implemented after
receiving parental approval.
Regular education teachers
attend Team meeting on a
regular basis. The Sturgis
Charter School has provided
training to all staff on their
specific responsibilities on
implementing the students’
IEP.
Record Review
The onsite team was able to
locate the Notice of Proposed
School District Action (N1
Form) in the student records.
Documentation
Review and
Staff Interviews
The onsite team was able to
verify that the Sturgis Charter
School has a policy and
procedure in place that
addresses these criteria.




Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective or
Basis of Finding of New
Noncompliance
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 6 of 15
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
SE 28
Parents provided
notice
SE 36
IEP
implementation,
accountability
and financial
responsibility
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective



Record Review
and Staff
Interviews
Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective or
Basis of Finding of New
Noncompliance
The onsite team was able to
locate documentation in the
student records that the
Notice of Procedural
Safeguards was sent to
parents.
Student Records
Staff Interviews
The onsite team has
determined that new IEPs are
not implemented without
parent consent. Also,
services listed on the
student’s IEP are the financial
responsibility of the charter
school.
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 7 of 15
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
SE 46
Procedures for
suspensions of
students with
disabilities when
suspensions
exceed 10
consecutive
school days or a
pattern has
developed for
suspensions
exceeding 10
cumulative days;
responsibilities of
the Team;
responsibilities of
the district
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective
Documentation
Review and
Staff Interviews
The onsite team found that
Sturgis Charter School has a
procedure in place to address
suspensions of students with
disabilities and suspensions
that exceed 10 consecutive
school days or a pattern
exceeding 10 cumulative
days. The policy and
procedure is outlined in the
student handbook.


Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective or
Basis of Finding of New
Noncompliance
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 8 of 15
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
SE 48
FAPE Equal
opportunity to
participate
Se 49
Related services
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective
Record Review,
Documentation
Review and
Staff Interviews
The onsite team found that
the Sturgis Charter School
offers counseling to eligible
students. The school has
hired an additional guidance
counselor to address this
student needs. The school
has in place for all students a
lunch program and offers a
physical education program
for grades 9-12.
Record Review
and Staff
Interviews
The onsite team found that
students receive all services
that are listed on their Service
Delivery Grid.



Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective or
Basis of Finding of New
Noncompliance
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 9 of 15
Required Corrective Action,
Timelines for
Implementation,
and Progress Reporting
Criterion
Number/Topic
(Refer to full text
of 2006-2007 CPR
requirements)
SE 50
Responsibility of
the School
Principal and
Administrator of
Special Education
SE 58
Federal Special
Education
Entitlement
Grant
Approved
Corrective
Action
Implemented
and Effective
Method(s) of
Verification
Basis of Determination
that Corrective Action
was Implemented and
has been Effective

Partial
Record Review,
Documentation
Review and
Staff Interviews

Documentation
Review and
Staff Interviews
Corrective
Action Not
Implemented
or Not
Effective
or
New Issues
Identified

The district has provided
training to all instructional
staff concerning the function
of the pre-referral process and
the utilization of the Student
Support Team (SST).
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
Although the Sturgis Charter
School has provided staff
training on accommodating
diverse learning needs,
meeting notes on students
referred to the SST for
interventions are not
routinely placed in the
student record.
The Sturgis Charter School must
submit 2 copies of the SST
meeting notes of students referred
for intervention strategies. Please
submit documentation by
Monday, June 18, 2007.
The onsite team has
determined that the charter
school administrators provide
ongoing monitoring of the
federal special education
entitlement grant to ensure
full implementation as
approved.
Sturgis Charter School
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 10 of 15
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
Criterion
Determined to
be Implemented
Based on Review
of Local ELE
Self-Assessment

Findings of Noncompliance Based on Department’s
Review of Local ELE Self-Assessment
(Criterion Determined to be Partially Implemented or
Not Implemented)
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
The Sturgis Charter School (SCS) was unable to provide
verification of appropriate screening and assessment
instruments.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with this criteria: Copies of screening and assessment
instruments;Description of identification, evaluation, and
placement practices and procedures; Copies of identification and
placement criteria; List of district staff who are Qualified
MELA-O Trainers (QMT’s) or Qualified MELA-O
Administrators (QMA’s) (see
http://www.doe.mass.edu/mcas/2004/news/0223melao_lep.html);
Names and qualifications of persons administering assessments,
evaluating students, and making decisions about placement in
ELE programs.
ELE 2
MCAS
Participation
SCS was unable to provide verification of appropriate
modification practices for limited English proficient
(LEP) students taking the MCAS test.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with these criteria: Description of MCAS testing modification
practices.
ELE 3
Initial
Identification
Although SCS was able to provide a copy of a home
language survey, SCS was unable to provide verification
of LEP student identification through the avenues of
assessment and testing data.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with these criteria: Copies of assessment instrument(s), names
and qualification of persons implementing identification
procedures and testing data.
SCS was unable to provide verification of any waiver
SCS must provide to the Department by Monday, June 18,
ELE 1
Annual
Assessment
ELE 4
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 11 of 15
ELE
Criterion
Number
and
Topic
Waiver
Procedures
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)
procedures in place.
ELE 5
Program
Placement
and Structure
SCS was unable to provide documentation of program
placement and structure.
ELE 6
Program Exit
and
Readiness
SCS was unable to provide verification of program exit
and readiness.
ELE 7
Parent
Involvement
SCS was unable to provide verification of any outreach
to parents of LEP students.
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
2007, the following documentation that addresses compliance
with this criteria: Copy of wavier procedure notice in parent’s
native language, description of the charter school’s waiver
process, waiver guidelines, and copy of a waiver form.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with this criteria: a description of implementation practices,
narrative summary of the charter school’s ELE programs and
services fully describing the nature of these instructional
programs; copy of written policies and procedures for sheltered
English immersion (SEI), two-way bilingual or other ELE
programs, evidence of teacher licensure or professional
development for ELE teachers providing SEI, and a copy of the
English language development curriculum.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with these criteria: description of redesignation practices and a
copy of program exit criteria and practices.
ELE 8
Declining
Entry to a
Program
SCS was unable to provide documentation to verify
support for students whose parents decline entry to an
ELE program.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with these criteria: copy of outreach notice sent to parents of LEP
students in the native language of the home.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with this criteria: description of implementation practices,
including a description of educational supports for students
whose parents have chosen to opt-out of English language
learner programs, sample opt-out form, and form used to monitor
progress of opted-out students.
ELE 9
SCS was unable to provide documentation to indicate
SCS must provide to the Department by Monday, June 18,
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 12 of 15
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)
Instructional
Grouping
that there are implementation practices in place for
instructional groupings.
ELE 10
Parental
Notification
SCS was unable to provide documentation that parents
were notified in the primary/home language as well as
English of the ELE status of their child.
ELE 11
Equal Access
to Academic
Programs
and Services
SCS does not presently have LEP students enrolled in
their academic programs and services and was unable to
provide documentation.
ELE 12
Equal Access
to
Nonacademic
and
Extracurricular
Programs
SCS does not presently have LEP students enrolled in
their nonacademic and extracurricular programs and was
unable to provide documentation.
ELE 13
Follow-up
Support
SCS does not presently have LEP students enrolled in
English language learner education programs that would
require active monitoring.
ELE 14
SCS does not presently have LEP students enrolled and
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
2007, the following documentation that addresses compliance
with these criteria: description of implementation practices, and
copy of curriculum for instructional groupings.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with this criteria: description of implementation practices, and a
copy of a sample notice in the home language upon student’s
placement in any ELE program and annually thereafter.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with this criteria: description of implementation practices,
including a description of the means by which the charter school
ensures that LEP students participate fully with their Englishspeaking peers and a description of the support provided, a copy
of the list of academic program and services, and a description of
curriculum accommodations available.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with this criteria: description of implementation practices,
including a description of the means by which the charter school
ensures that LEP students participate fully with their English
speaking peers in extracurricular activities, copies of notices to
LEP students regarding access to programs; evidence of
translation of announcements of extracurricular activities into
students’ native language when necessary.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with these criteria: a description of follow-up policies and
procedures, and any monitoring forms used in follow-up.
SCS must provide to the Department by Monday, June 18,
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 13 of 15
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)
Licensure
Requirements
hence, the faculty does not reflect teachers who are
properly licensed or waived to teach LEP students.
ELE 15
Professional
Development
Requirements
SCS does not presently have LEP students enrolled in
English language learner education programs. SCS was
not able to submit documentation concerning
professional development on English language education.
ELE 16
Equitable
Facilities
SCS does not presently have LEP students enrolled in
English language learner education programs.
ELE 17
Program
Evaluation
SCS does not have an established ELE program.
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
2007, the following documentation that addresses compliance
with this criteria: a copy of a plan to employ or contract qualified
personnel to instruct LEP students enrolled at SCS.
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with this criteria: SCS Professional Development Plan, and a list
of ELE topics covered at recent professional development
opportunities
SCS must provide to the Department by Monday, June 18,
2007, the following documentation that addresses compliance
with this criteria: A description of how the charter school ensures
that LEP students are provided facilities, materials, and services
comparable to those provided to other students.
SCS must provide to the Department by Friday, June 18, 2007,
the following documentation that addresses compliance with
these criteria: A description of how the charter school intends to
evaluate the effectiveness of its ELE program.
Mid-cycle Report Format 2007.doc
Rev. 1/3/07
Sturgis Charter School Coordinated Program Review Mid-cycle Report
April 24, 2007
Page 14 of 15