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
February 21, 2008
Dr. Susan Parrella, Superintendent
Waltham Public Schools
617 Lexington Street
Waltham, MA 02452
Re: Mid-cycle Coordinated Program Review Report
Dear Dr. Parrella:
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
Waltham Public Schools Coordinated Program Review Report issued on June 22, 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
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/.
With respect to the Department’s monitoring of the implementation and effectiveness of the
corrective action approved or ordered after the district’s Coordinated Program Review, the
enclosed Mid-Cycle Review Report describes continued serious noncompliance with state and
federal law, particularly in special education. In 2004, the district proposed corrective action to
remedy all areas of noncompliance identified by the Department at that time. The Department
approved this corrective action--or in some cases disapproved it and made its own order of
corrective action--and since that time the district has provided the Department with written
progress reports describing implementation of the approved or ordered corrective action.
However, as a result of the mid-cycle monitoring in June 2007, which consisted of staff
interviews, student record reviews, documentation review and/or classroom observations, the
1
Department has found that the approved corrective action (1) has not been implemented as
approved or ordered by the Department; (2) has been very unevenly implemented at the building
level; or (3) has been implemented but has been ineffective in addressing the identified
noncompliance. Findings in the first two cases are in direct contrast to progress reports submitted
by the district and statements of assurance filed by the district with the Department as a condition
for receiving state and federal funds.
The Department documented 37 findings of special education noncompliance by the district in
2004, and the enclosed Mid-Cycle Report documents 27 findings of noncompliance in the
Waltham Public Schools special education programs, 15 of which are areas of continuing
noncompliance. This is not acceptable after three years of reported corrective action.
In consideration of the seriousness of the Department’s findings, we are requesting a meeting
with you, the special education director and the assistant superintendent to review the
Department’s determinations with regard to the Mid-cycle Review Report and our concerns
regarding the items of continuing noncompliance, including the need for prompt remediation.
Please contact Michelle Griffin in order to schedule a meeting regarding this matter.
The Department’s onsite team has also identified new issues of noncompliance, either
noncompliance with special education criteria added or substantially changed in response to
IDEA 2004, noncompliance with ELE criteria, non-compliance with civil rights criteria or other
new noncompliance.
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 March 10, 2008.
Your staff's cooperation throughout this Mid-cycle Review is appreciated. Should you require
clarification of our report, please do not hesitate to contact me at 781-338-3755.
Sincerely,
Michelle Griffin, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
c:
Jeffrey Nellhaus, Acting Commissioner of Elementary and Secondary Education
Mayor Jeannette McCarthy, School Committee Chairperson
Paula Alexander, District Program Review Follow-up Coordinator
Encl.: Mid-cycle Coordinated Program Review Report
Attachment A – SE 40
2
MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION
MID-CYCLE COORDINATED PROGRAM REVIEW REPORT
WALTHAM PUBLIC SCHOOLS
ONSITE MONITORING OF IMPLEMENTATION OF CORRECTIVE ACTION AND OF CERTAIN NEW REQUIREMENTS
Date of Coordinated Program Review (CPR): February 23-27, 2004
Date of Coordinated Program Review Corrective Action Plan Approval: March 18, 2005
Dates of Corrective Action Plan Progress Reports: June 7, 2005; November 17, 2005; March 24, 2006; June 30, 2006
Dates of this Mid-cycle Review Onsite Visit: June 6, 7, 8, 2007; June 18, 2007
Date of this Report: February 21, 2008
PLEASE NOTE THAT THIS REPORT IS IN SEVERAL SECTIONS.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 1 of 57
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

MOA 4
Disproportionality
(if Cited in
the CPR
Report)
Special Ed.
Criteria Cited
in CPR
Report and
Monitored in
Mid-cycle
N/A
Partial
SE 2
Required &
Optional
Assessments
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
Partial
The mandated educational
assessments (Part A and B)
were not consistently
found in student records,
although listed on
evaluation consent forms
and consented to by the
parent/guardian. In several
cases, consented to
assessments in other areas
of disability were not
completed. This is an
area of continuing
noncompliance.
Develop an internal oversight
and tracking system to ensure
timely completion of all
consented-to assessments,
including the mandated
educational assessments.
Review a sample of initial
evaluations and re-evaluations
from each building and report
the following:
 Description of the
internal oversight and
tracking system,
including person(s)
responsible for the
oversight;
 Total number of
This criterion was not monitored as
part of the mid-cycle review, as the
criterion was rated as implemented
in the most recent Coordinated
Program Review.
Record
review
Interviews
Record review indicates that most,
but not all, assessments consented
to by parents are completed.
Documentation
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 2 of 57
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
or Not
Effective
Or
New Issues
Identified

Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
records reviewed;
 Schools from which
records were selected;
 Number of records
which contained
educational
assessments (part A
and B);
 Number of records in
which all consented-to
assessments were
completed;
 Specific actions taken
by the district to
remedy any continuing
non-compliance.
Submit the above information
to the Department by March
29, 2008.
Conduct an internal review of
initial evaluations and reevaluations from the schools
in which areas of
noncompliance were found for
the March 2008 progress
reporting period. Report on the
following:
 Total number of
records reviewed;
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 3 of 57
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
or Not
Effective
Or
New Issues
Identified

Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting

Schools from which
records were selected;
 Number of records
which contained
educational
assessments (part A
and B);
 Number of records in
which all consented-to
assessments were
completed;
 Specific actions taken
by the district to
remedy any continuing
non-compliance.
Submit this report to the
Department by June 30, 2008.
SE 3
Specific
Learning
Disabilities
SE 7
Age of
Majority
Partial
Because statutory requirements for
the determination of specific
learning disabilities had been
recently revised under IDEA 2004
and its regulations, at the time of
this MCR the Department was not
making findings related to school
district practices under SE 3.
Documentation The district created forms for
implementation of the age of
Interviews
majority requirements. In addition,
the special education director
Record
issued a memo to staff clarifying
Partial
Documentation of the
discussion of the transfer
of rights of students at the
age of majority was not
always found in IEPs for
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 4 of 57
Create a tracking and oversight
system for ensuring that one
year prior to the student
reaching age 18, the district
informs the student of his/her
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
review
that the district must inform
students of the transfer of rights
one year prior to the 18th birthday.

Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
students one year prior to
their 18th birthdays. At
times, the form that
indicates the student’s
decision at 18 with regard
to educational decisionmaking is signed at the
home (rather than in the
presence of the Team or in
the presence of one witness
from the district and one
other witness, as required).
In addition, the district
seeks the student’s
decision with regard to age
of majority prior to the age
of 18. Please refer to 603
CMR 28.07(5) for further
information about
requirements. This is an
area of continuing
noncompliance.
right to make all decisions in
relation to special education
programs and services, and
ensuring that options other than
the student assuming decisionmaking authority at age 18 are
appropriately documented.
Provide the following
information:
 Description of the
internal tracking and
oversight system,
including person(s)
responsible for the
oversight;
 Total number of
records reviewed;
 Number of records
including information
indicating that students
were informed one
year prior to turning 18
of his/her right at 18 to
make all decisions in
relation to special
education;
 Number of records
including appropriately
documented
information pertaining
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 5 of 57
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

SE 9/9A
Eligibility
Determination
Timelines
Partial
Record review
Interviews
Documentation
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Record review indicates that at
times, the district meets the 30 and
45-day timelines for completion of
assessments and convening the IEP
Team.
Partial
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Record review indicates
that the district
inconsistently meets 30
and 45-day timelines for
completion of evaluations
and Team meetings
(respectively). This is an
area of continuing
noncompliance.
Staff interviews indicate
that there are several
factors contributing to
delays. Currently, the
district processes
evaluations through the
central office, which
causes delays. In addition,
interviews indicate that
psychologists are
backlogged with
assessments. Finally, staff
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 6 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
to decision-making;
 Specific actions taken
by the district to
remedy any continuing
non-compliance.
Submit this report to the
Department by March 29,
2008.
Develop a plan to address the
reasons for continuing noncompliance in meeting 30 and
45-day timelines for
completion of evaluations and
Team meetings. Provide a
description of the plan as well
as the name and role of the
staff person responsible for
conducting oversight of this
plan by March 29, 2008.
Provide training to Team
chairpersons at the high school
on eligibility determinations
under Section 504. Submit the
agenda, attendance sheet and
training materials by March
29, 2008.
Submit the results of an
internal review of special
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
or Not
Effective
Or
New Issues
Identified

Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
hold multiple
responsibilities – teaching,
liaison, assessment, as well
as completion of
paperwork, including
evaluations.
education records (of students
for whom initial or reevaluations were conducted
after the district has
implemented the above plan)
selected from each school in
the district. Review records for
compliance with meeting
eligibility determination
timelines. Submit the following
information:
 Name and role of staff
conducting the review;
 Number of records
reviewed;
 Schools from which
records were selected;
 Number of records
found in compliance
with this criterion;
 Corrective action taken
to remedy any areas of
non-compliance, if
required.
Submit this report by March
29, 2008.
Interviews indicate that
Section 504 is not always
considered where
appropriate at the high
school, and that staff
require additional Section
504 training.
Submit the results of an
internal review of special
education records selected
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 7 of 57
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
or Not
Effective
Or
New Issues
Identified

Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
from schools requiring
corrective action as a result of
the March 2008 progress
reporting. Review records for
compliance with meeting
eligibility determination
timelines. Submit the following
information:
 Name and role of staff
conducting the review;
 Number of records
reviewed;
 Schools from which
records were selected;
 Number of records
found in compliance
with this criterion;
 Corrective action taken
to remedy any areas of
non-compliance, if
required.
Submit this report by June 30,
2008.
SE 15
Child Find
√
The district provided a sample
child find letter and a list of
agencies and preschools to which
Documentation the letter is sent. According to this
list and staff interviews, the
district’s child find efforts in the
community are broad and varied.
Interviews
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 8 of 57
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

SE 16
√
Screening
SE 18A
IEP
Development
and Content
Partial
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Interviews and documentation
indicate that the district
implements screening periodically
Documentation as well as at regularly scheduled
times.
IEP vision statements were
Interviews
generally well-written, containing
information concerning strengths
Record
and areas of weakness.
review
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
Record review indicates
that goals are at times
repeated from year to year,
and that IEPs do not
indicate how progress
toward meeting goals is to
be measured.
Develop a system of oversight
of the appropriate completion
of IEPs in each building.
Submit a description of the
system of oversight including
person(s) responsible. Review
a sample of IEPs from each
building and report the
following:
 Total number of
records reviewed;
 Schools from which
records were selected;
 Number of IEPs that
include all of the
required information;
 Specific corrective
action taken when
noncompliance was
found.
Submit the above information
by March 29, 2008.
Interviews
Partial
PLEP B was at times blank
when student records
indicate that students had
behavioral difficulties. See
also SE 43.
Non-participation
justification statements in
IEPs did not focus on the
individual students to
whom they pertained. See
SE 20.
See SE 8 concerning the
authority to commit
resources and changing
IEPs.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 9 of 57
For specific schools in which
noncompliance was found for
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

SE 18B
Determination
of Placement
and Provision
of IEP
Partial
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

The district submitted a recent
memo from the assistant director of
special education reminding staff
Documentation of the December 2006 Department
guidance memo concerning the
Interviews
interpretation of the immediate
provision of the IEP. The district
is reminded that, per the advisory,
the parent must agree to wait two
weeks for the provision of the IEP,
and that even when parents do
Record review
Partial
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Placement pages (PL1) do
not always correspond
appropriately with service
delivery grids, particularly
for students whose
placement pages read
partial or full inclusion. In
several cases, placement
pages were not found in
the student record.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 10 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
the March 2008 progress
reporting period, conduct an
internal review of IEPs
developed since implementing
the corrective action. Report
the following:
 Total number of
records reviewed;
 Schools from which
records were selected;
 Number of IEPs that
include all of the
required information;
 Specific corrective
action taken when
noncompliance was
found.
Submit the above information
by June 30, 2008.
Provide training for all special
education staff responsible for
completing IEPs and
Placement pages (PL1 and
PL2) on the appropriate
completion of these pages.
Provide evidence of this
training, including agenda,
training materials and signed
attendance sheets by March
29, 2008.
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
or Not
Effective
Or
New Issues
Identified

agree to wait, a summary must be
provided at the end of the Team
meeting.
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Though interviews and
some records indicate that
at times parents are
immediately provided with
summaries of the
agreements reached in
Team meetings, records
did not consistently contain
evidence of these summary
sheets or any other
evidence that parents left
Team meetings with either
the IEP or with a summary
of the agreements reached
in the meeting. See also
SE 9. This is an area of
continuing
noncompliance.
The “Project Reach”
program “Rules and
Regulations” and
interviews indicate that the
program has a referral
process under which a
“team” that includes
Project Reach staff have
the final determination as
to whether the program is
appropriate for a student
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 11 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
Complete a review of a random
sample of IEPs and placement
pages for students placed in
partial and full inclusion
placements, where IEPs were
created after the training.
Ensure that the review includes
IEPs and placement pages from
all schools. Report to the
Department on the number of
IEPs and placement pages
reviewed, the number of
placement pages that have been
appropriately completed, and
actions taken to remedy any
areas of non-compliance.
Provide the report to the
Department by March 29,
2008.
Ensure that all students placed
in the Project Reach program
have IEPs and are placed in the
program in accordance with
regulations. Provide a report
on the progress of this
determination, and any actions
taken to remedy any
inappropriate placements of
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
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
referred to it. If Project
Reach staff determine that
the student is appropriate,
then the student’s liaison
convenes a meeting to
formalize the change in
placement and develop an
IEP, without the student’s
IEP Team. This process
contradicts the IEP Team
determination of placement
process required by law
and regulation. In
addition, the Project Reach
program is described as an
alternative education
program; however, other
documentation and
interviews indicate that it
is a special education
program; the majority of
students in the program (21
out of 26) have IEPs and
some have this program
listed in IEPs as a special
education/substantially
separate placement. There
are three special education
teachers and one school
adjustment counselor in the
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 12 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
students in the program by
March 29, 2008.
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
or Not
Effective
Or
New Issues
Identified

Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
program, along with a
program liaison. Regular
education students placed
in Project Reach, then, are
placed there
inappropriately without
IEPs.
SE 21
Extended
School
Day and
School Year
√
Documentation
Interviews
The district submitted a list of
students who received 30 hours
weekly for six weeks of ESY from
GWARC Vocational Training; as
well as a list of out of district
students and copies of summer
2007 transportation arrangements.
Interviews indicate that extended
school day and school year services
are provided when the Team
recommends them for students.
Interviews indicate that extended
school year programs are available
in-district at the middle and
elementary levels, and that indistrict high school students
receive one to one services, if
needed. Interviews indicate that
extended school day services are
provided either before or after
school when Teams determine they
are needed.
The district submitted information
Record review indicates
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 13 of 57
Review all of the IEPs for
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

SE 22
IEP
implementation and
availability
Partial
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Interviews
about the procedures in place to
ensure that Waltham High School
Documentation service providers are aware of IEP
responsibilities. This is
accomplished via email (list) or
written notice (copy of portions of
IEPs). Interviews indicate that
there are similar procedures in
place at the elementary and middle
school for ensuring that service
providers are made aware of their
responsibilities under students’
IEPs.
Partial
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
that IEPs are at times
implemented before
acceptance by the
parent/guardian.
Record review indicates
that at the high school, the
district does not always
have a current IEP in effect
for each eligible student.
At times, records contained
no IEPs since 2004 or
2005.
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
students at the high school
level. Immediately establish
Team meeting dates for all
students on “expired” IEPs,
and provide Consent to
Evaluate forms to each
parent/guardian or adult
student where re-evaluations
are appropriate. Submit this
report to the Department by
March 29, 2008.
Develop a system of oversight
for the revision and
implementation of IEPs, and
receipt of consent from the
parent/guardian or student.
Submit a description of the
oversight system with the name
of the person(s) responsible for
monitoring this system to the
Department by March 29,
2008.
Submit the following report to
the Department:
 Total number of
records reviewed;
 Number of records in
which current IEPs
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 14 of 57
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

SE 24
Notice to
Parent
Partial
Interviews
Record
review
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Interviews indicate that high school
staff are now permitted to make
special education referrals.
Partial
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Record review indicates
that notices are not always
issued at required
junctures. At times, the
district did not respond to
referrals for special
education evaluations
within five school working
days. This is an area of
continuing
noncompliance.
Record review indicates
that when notices are
issued, the content is not
always compliant with
federal regulations. See 34
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 15 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
were found;
 Number of records in
which staff were
appropriately informed
that they can
implement new IEPs;
 A description of
immediate actions
taken by the district to
remedy any continuing
non-compliance.
Provide the report by June 30,
2008.
Provide training for key
personnel on responding to
referrals within five school
days of receipt (both written
and verbal referrals) and the
requirements of prior written
notice, including the
procedures for ensuring that
notices are issued at required
junctures, and the requirement
that notices meet the content
requirements of 34 CFR
300.503. Provide evidence of
the training, including agenda,
training materials and signed
attendance sheets by March
29, 2008.
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
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
CFR 300.503. This is an
area of continuing
noncompliance.
Record review and
interviews indicate that the
district employs a process
under which parents are
required to put referrals for
special education in
writing. This is not
required. In addition, all
referrals are processed
through the central office,
where a letter is generated
that the district has
received the referral, and
that consent forms will
follow. This is an
unnecessary step, and
according to record review
and interviews, delays
responses to referrals.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 16 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
Submit the report of an internal
review of a sample of student
records selected from all
schools to determine
compliance with ensuring that
referrals are responded to
within five days, the
requirement of prior written
notice and the content of the
notice. Submit the number of
records reviewed, the number
in compliance with this
criterion and corrective action
taken to remedy any
noncompliance found. Submit
this report by March 29, 2008.
For schools which had areas of
noncompliance with this
criterion for the March 2008
progress reporting period,
submit the report of an internal
review of a sample of student
records to determine
compliance with ensuring that
referrals are responded to
within five days, the
requirement of prior written
notice and the content of the
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

SE 28
See SE 18B
and SE 24
See SE 18B
and SE 24
See SE 18B and SE 24
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

See SE 18B
and SE 24
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
See SE 18B and SE 24
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
notice. Submit the number of
records reviewed, the number
in compliance with this
criterion and corrective action
taken to remedy any
noncompliance found. Submit
this report by June 30, 2008
See SE 18B and SE 24
Parent
provided the
IEP or notice
of no
eligibility
together with
notification of
procedural
safeguards
and parents'
rights
Partial
SE 29
Communications in
English and
Primary
Language
Interviews
Interviews indicate that the district
provides interpreters at meetings
Record
where required. In addition, some
review
forms are being provided in
Spanish and the district has hired a
Documentation
translator.
Partial
Student record review and
interviews indicate that
written communications,
including IEPs and
accompanying notices, are
not always in both English
and the primary language
of the home. This is an
area of continuing
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 17 of 57
Submit a list of resources for
providing translated IEPs and
accompanying notices to
parents/guardians. Submit this
list by March 29, 2008.
Develop procedures for
obtaining translated IEPs,
notices and other special
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
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
noncompliance.
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
education documentation.
Ensure that these procedures
are disseminated and reviewed
with key personnel, such as
Team chairpersons. Provide a
description of these procedures
and evidence of the
dissemination and review of
these procedures with key
personnel by March 29, 2008.
Submit a report on the review
of a sample of student records
selected from all schools to
ensure that IEPs and
accompanying notices, as well
as other special education
documentation, are provided in
English and the primary
language of the home. Report
on the number of records
reviewed in which parents
require translated materials, the
number of records in which
IEPs, notices and other special
education documents were
translated, and report on
corrective action taken to
remedy any noncompliance
found. Submit the above
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 18 of 57
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

SE 34
Partial
Continuum of
alternative
services and
placements
SE 35
√
Specialized
materials and
assistive
technology
The district provides a continuum
Documentation of services for meeting the needs of
students with disabilities.
Record
Interviews indicate that counseling
review
is now available for all students.
Record review indicates that
Interviews
counseling was noted in service
delivery grids, and counseling
goals were seen in IEPs.
The district provided a list of
Documentation recent purchase orders for assistive
technology. Interviews and record
Interviews
review indicate that assistive
technology is considered by IEP
Record review
Teams, recorded in IEPs and
implemented when needed.
Documentation
SE 36
Partial
Interviews
IEP
implementation,
accountability
and financial
responsibility
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Record
review
Interviews indicate that oversight
of IEPs is generally assigned to the
liaisons responsible for
implementing services. While this
seems to be working with regard to
some requirements, such as reevaluation, child find, and
extended school year services, the
district still struggles with
oversight and monitoring of the
implementation of all
Partial
Partial
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
See SE 43 concerning
students with behavioral
issues.
Student record review and
interviews indicate that the
district continues to fail to
oversee in an ongoing
manner the full
implementation of IEP
services, particularly at the
high school level. This is
an area of continuing
noncompliance.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 19 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
information by June 30, 2008.
See SE 43.
See corrective action in SE 13,
SE 18A, SE 22, SE 40, SE 41,
SE 43, SE 44, 45, 46 and 47.
Provide a plan for ensuring that
the district oversees in an
ongoing manner the
implementation of all IEPs,
particularly at the high school
level. Ensure that the plan is
descriptive of the means by
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
or Not
Effective
Or
New Issues
Identified

requirements.
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
Examples of this failure
are in the implementation
of incorrect IEP goals, lack
of progress reports, lack of
compliance with age span
and class size regulations
and lack of compliance
with disciplinary
requirements.
which the district will monitor
the areas of non-compliance
cited in this report. Indicate
the role of staff responsible for
implementation of this plan;
however, since the use of
liaisons has not been effective,
please ensure that the plan
provided by the district is not
the same as that used in the
past. Provide this plan by
March 29, 2008, and evidence
of its implementation by June
30, 2008.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 20 of 57
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
Documentation
The district submitted
documentation of the dates of birth
and instructional groupings for
most special education teachers
and some related service providers.

SE 40
Instructional
grouping
requirements
for students
aged five and
older
Partial
Interviews
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Partial
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Several instructional
groupings throughout all
levels exceeded the class
size standards of
regulations. This is an
area of continued
noncompliance.
Please see Attachment A
for a list of specific
instructional groupings
where class size standards
exceed regulatory
requirements.
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
Develop procedures for
principals to follow for
monitoring instructional
grouping and age span
requirements. The procedures
should include notification to
the special education director
when instructional groupings
and age spans exceed
regulatory requirements.
Submit a copy of these
procedures to the Department
by March 29, 2008.
Submit evidence of any
notifications of increased class
size by March 29, 2008.
Conduct an internal review of
the special education classes
throughout all schools. Report
on the following:
 Number of classes
reviewed;
 Number of classes in
which the instructional
group size is within
regulatory
requirements;
 Corrective action taken
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 21 of 57
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

SE 41
Age span
requirements
Partial
Partial
SE 43
Behavioral
interventions
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Documentation The district submitted
documentation of the dates of birth
and instructional groupings for
Interviews
most special education teachers
and some related service providers.
Interviews
The district provided available
training materials from Class
Documentation Measures training, as required by
previous progress report reviews.
Record
Interviews indicate that all special
Partial
Partial
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
According to
documentation submitted
by the district, age span
requirements are exceeded
in different instructional
groups of almost all special
educators at the high
school, including a number
of study and organizational
skills classes taught by
different special education
staff, many life skills
classes, and other special
education classes assigned
to other special educators
at the high school
(identified as special
education classes on the
documentation with no
specific teacher or class
name stated).
Student record review
indicates that at the high
school and middle school,
functional behavioral
assessments are not always
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 22 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
to remedy any
noncompliance found.
Submit the results of this report
by June 30, 2008.
Submit requests for age span
waivers to the Department for
any instructional groupings in
which the age spans exceed 48
months. Submit the above by
March 29, 2008.
Provide training for all Team
chairpersons at the middle and
high school on requirements
that Teams consider including
positive behavioral
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
review
education staff at the elementary,
middle and high school levels
attended this training.

Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Evidence of behavioral
interventions was seen in student
records from the elementary level.
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
completed when required
due to disciplinary
proceedings, or when
consented to.
Positive behavioral
interventions were not
found always found in
IEPs for students with
behaviors that interfere
with their learning or that
of others, and behavior
intervention plans were not
always found in IEPs
where required due to
disciplinary proceedings.
This is an area of
continued
noncompliance.
When completed, FBAs at
times led to conclusions
for the student and parent
to work on, without
addressing behaviors in
school. When behavioral
goals were found in IEPs,
they often placed the onus
on the student simply
reaching a goal without the
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 23 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
interventions and the possible
need for a functional
behavioral assessment for
students whose behavior
impedes their learning or that
of other students. Include in
this training discussion by the
Team of the student’s ability to
follow the school’s discipline
code. Provide evidence of the
training, including agenda,
training materials and
attendance sheets by March
29, 2008.
Submit a report of an internal
review of student records at the
middle and high school levels
for compliance with this
criterion post-training,
including developing
behavioral interventions and
conducting functional
behavioral assessments.
Include in the report the
following:
 Number of records
reviewed,
 Number in compliance
with this criterion, and
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
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
provision of a service
related to reaching the
goal.
Interviews and student
record review indicate that
Teams do not consider the
ability of special education
students to follow school
discipline codes.
See also SE 18A.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 24 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting

Corrective action for
any noncompliance
found. Submit this
report by June 30,
2008.
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
Documentation
Documentation and interviews
indicate that the district has a
procedure for documenting
suspensions of special education
and regular education students.

SE 44
Procedure for
recording
suspensions
Partial
Interviews
Record
review
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
Partial
Project Reach’s program
manual inappropriately
contains a provision under
which special education
students may be removed
from their classes to the
Project Reach room, where
they may or may not be
permitted to do their class
work. This should be
counted as a suspension
when students are removed
from special education
programs and are not
permitted to complete class
work. This is an area of
continued
noncompliance.
Revise the Project Reach
manual so that students who
are removed for disciplinary
purposes from classes are
either permitted to complete
the work from the class, with
appropriate teacher support, or
that the removal is counted as
an in-house suspension.
Provide evidence of this
revision by March 29, 2008.
Record review indicates
that internal suspensions at
the high school are not
always included in
calculation of the number
of days removed from
program, in determining
when a manifestation
determination should be
scheduled. Consequently,
manifestation
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 25 of 57
See requirements of SE 45
below.
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
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
determination meetings are
not always held when
required. This is an area
of continued
noncompliance.
See SE 45.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 26 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
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

SE 45
Procedures
for
suspension up
to 10 days
and after 10
days:
General
requirements
Partial
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
Partial
Record review indicates
that manifestation
determination meetings are
not always held when
required at the middle and
high school levels. In
addition, when
manifestation
determination meetings are
held, interviews and
documentation indicate
that parents and students
are not always provided
appropriate notice of the
purpose of the meeting,
and evidence of such
meetings was not found in
records. Functional
behavioral assessments and
behavior intervention plans
were not found where
required.
Provide training to all middle
and high school special
education staff and all
principals and housemasters
concerning the IDEA 2004
requirements related to
discipline, including those set
forth in SE 44, 45, 46 and 47,
and the requirement to include
all internal suspensions in
calculating the number of days
of removal from the program.
Provide evidence of the
training, including agenda,
training materials, signed
attendance sheets, indicating
staff role. Provide all of the
above by March 29, 2008.
Interviews
Interviews indicate that the district
has provided training on
Record
appropriate procedures under
review
IDEA 2004 for suspension of
students with disabilities.
Documentation
Handbooks contain information
about discipline of students with
disabilities. See SE 47 and MOA
10A.
The district did not submit
a revised policy as required
by previous progress report
reviews, or evidence that it
has been provided to all
staff responsible for Team
meetings and disciplinary
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 27 of 57
Submit a report of an internal
review of student records posttraining to determine
compliance with ensuring that
manifestation determination
meetings are held when
required, functional behavioral
assessments are conducted and
that notice is sent to parents.
Submit the following
information:
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
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
exclusions at the high
school.
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting


The district did not submit
a memo clarifying the
manifestation
determination process to
the above personnel, as
required by previous
progress report reviews.
SE 47
Procedural
requirements
applied to
students not
yet
determined to
be eligible for
special
education
SE 48
FAPE
Documentation
√
Student handbooks now contain
mention of protections for students
who are not yet determined
eligible, where the district knew or
should have known that the student
was a student with a disability.
Interviews
√
The district submitted a description
of vocational options for special
Record
education students, a listing of
review
course selection booklet pages, and
a statement regarding counseling.
Documentation
Interviews indicate that the district
provides FAPE to students with
disabilities. Counseling is
available to all students.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 28 of 57


Name and role of staff
completing review;
Number of records
reviewed,
Number of records
found in compliance;
Corrective action taken
as required.
Submit this report by June
30, 2008.
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
Documentation
The district submitted a list of
related services provided by both
in-district and contracted providers.
The list is extensive, and includes
such services as music therapy, art
therapy, home training, APE, ASL
interpreting, ABA, behavior
consulting, and SIOT.

SE 49
Related
Services
√
Interviews
Record
review
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
Partial
The district did not submit
administrator licensure and
the administrator was not
available for an interview,
due to a leave of absence.
The administrator has since
left the district.
Submit evidence of the
qualifications of the current
special education administrator
by March 29, 2008.
Interviews and record review
indicate that the district provides
related services as recommended
by IEP Teams.
SE 50
(Some of the
issues raised
and
components
of former SE
50 are
addressed
under current
MOA 18 will
be monitored
under both
criteria)
Partial
Documentation
See SE 34.
The district submitted a job
description for the special
education administrator.
At the time of the review, the
school district had an appointed
person to be its administrator of
special education.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 29 of 57
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
√
Documentation
The district submitted appropriate
special education teacher
certifications for most staff.
√
Documentation

SE 51
Appropriate
special
education
teacher
certification
SE 52
Appropriate
certifications
or other
credentials -related
service
providers
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Partial
SE 54
Professional
development
regarding
Partial
Partial
Documentation training topics and attendance
Interviews
Use of
paraprofessionals
sheets, with the names of
paraprofessionals in attendance
highlighted. Interviews indicate
that paraprofessionals must attend
some trainings.
Documentation The district submitted a list of eight
Interviews
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
The district submitted appropriate
related service provider
certifications.
The district submitted a list of
SE 53
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
trainings for transportation
providers, including attendance
sheets. In addition, interviews
indicate that individual
Partial
Interviews indicate that
paraprofessionals are not
supervised in an ongoing
manner.
Interviews indicate that
general education staff,
counseling staff, and
special education staff
inconsistently receive all of
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 30 of 57
Provide evidence of
paraprofessional supervision,
including names of
supervisors, and a description
of the content and frequency of
supervision.
Provide the above by March
29, 2008.
Conduct a review to determine
which staff in the district have
not received the training
mandated by this criterion.
Provide a report of this review
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

special
education
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

transportation providers are trained
on the specific needs of the
students they transport.
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
the required trainings listed
in this criterion. Some
staff indicated that they
had received training on
special education laws and
regulations and meeting
the diverse learning needs
of students; however,
acknowledgement of
training was inconsistent
and interviews indicate that
these trainings are not
mandatory for all staff.
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
by March 29, 2008.
The district must provide
training to all staff who have
not received training on the
following:
a. state and federal special
education requirements
and related local special
education policies and
procedures;
b. analyzing and
accommodating diverse
learning styles of all
students in order to achieve
an objective of inclusion in
the regular classroom of
students with diverse
learning styles;
c. methods of collaboration
among teachers,
paraprofessionals and
teacher assistants to
accommodate diverse
learning styles of all
students in the regular
classroom.
Provide agendas, training
materials, and signed
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 31 of 57
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

Partial
Interviews
SE 55
Observation
Special
Education
Facilities and
classrooms
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Building tour and interviews
indicate that the special education
students assigned to the only nonscience lab classroom have access
to the lab twice weekly.
Partial
Basis of Determination that
Implementation of
Corrective Action was
Incomplete or Ineffective
Or
Basis of Finding of New
Noncompliance
The special education
Project Reach classrooms
are clustered together in
the basement. While there
are vocational classrooms
in another part of the
basement, interviews and
observations indicate that
Project Reach students do
not integrate with other
students in these
classrooms. The location
of these classes does not
maximize the inclusion of
such students into the life
of the school, and does not
demonstrate that this
program is given the same
priority as general
education programs in the
allocation of instructional
and other space in public
schools in order to
minimize the separation or
stigmatization of eligible
students.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 32 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
attendance sheets (including
identification of staff role)
above by June 30, 2008.
Submit a statement indicating
that the signage at the high
school has been removed.
Submit this statement by
March 29, 2008.
Submit a plan for remedying
the issues with the placement
of Project Reach classes, so
that the location of this
program maximizes the
inclusion of such students into
the life of the school, and so
that the program is given the
same priority as general
education programs in the
allocation of instructional and
other space in public schools in
order to minimize the
separation or stigmatization of
eligible students. Provide this
plan June 30, 2008.
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
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
Classes and offices in the
high school are
inappropriately labeled
with signs identifying them
as “Project Reach” or
“SAC/school adjustment
counselor.”
SE 56
√
Interviews
Special
education
programs and
services are
evaluated
SE 57
Special
education
child count
Documentation
√
Documentation
Interviews
Record
review
The district submitted the 20052007 district improvement plan,
and a June 2006 special education
program evaluation.
Interviews indicate that the special
education program is regularly
evaluated, along with other
programs.
The district submitted its current
list of special education students.
The child count includes students
with in-district and out of district
IEPs, as well as students with
disabilities determined eligible for
special education who are
attending private schools at private
expense and are receiving publicly
funded services according to IEPs
developed by the district.
See SE 14 concerning current IEPs.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 33 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
Criterion
Number
and
Topic
Criterion
Implemented

Method(s) of
Verification
Basis of Determination that
Criterion was Implemented
Record review
Documentation and
interviews indicate that the
district uses the required
transition planning form, and
that the district has had
training on transition
planning.
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
The transition planning
form was not found in the
records of students of
transition age. Transition
goals or documentation
that transition goals were
not needed was frequently
not found in the IEPs
reviewed during student
record review.
Require all special education
staff at the high school to
complete a review of the
records of students on their
caseloads to identify which
students’ records do not have
the required transition planning
form. Ensure that Team
meetings are scheduled for the
purpose of discussing
transition planning or ensure
that upcoming meetings
include transition planning.
Submit to the Department the
following:
 Number of records
reviewed;
 Number of
appropriately
completed transition
planning forms;
 Number of IEPs with
transition goals or with
documentation that the
Team believed that
Special
Education
Criteria
created or
revised in
response to
IDEA-2004
SE 6 ##1 - 3
Determination
of Transition
Services
Partial
Documentation
Interviews
Partial
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 34 of 57
transition goals were
not needed;
 Actions taken to
schedule Team
meetings immediately
to address transition
planning.
Provide the report by March
29, 2008.
SE 8
IEP Team
composition
and attendance
Partial
Record review
Interviews
Record review indicates that
Team composition at the
elementary and middle
school levels are generally in
compliance with regulatory
requirements. However,
Team meeting invitations
and attendance sheets were
missing from a number of
files, so full compliance
could not be determined.
The district submitted a
statement of practices for
compliance with the new
regulations concerning Team
attendance.
Partial
Interviews indicate that
the persons designated as
Team chairpersons in the
district do not have the
authority to commit the
resources of the district.
While they can commit
existing resources within
their school buildings,
they are not permitted to
commit to resources
outside of the building,
such as district-wide
special education
programs, out-of-district
programs, or one-to-one
aides. This is an area of
continuing
noncompliance.
The district’s statement of
practices does not address
“attendance not
necessary.” The district
must ensure that staff are
knowledgeable about the
two separate provisions
for excusing Team
members from Team
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 35 of 57
Submit a copy of the memo
sent to all special education
staff and principals identifying
all persons in the district who
have the authority to commit
the district’s resources. Such
individual must be present at
all Team meetings, including
re-evaluations and annual
reviews. Provide evidence of
this memo and a list of staff to
whom it has been distributed
by March 29, 2008.
Revise the district’s statement
of practices for implementing
new provisions of IDEA 2004
concerning excusal of Team
members from Team meetings.
Provide training for all Team
chairpersons and principals on
this new procedure. Also
provide training on the
requirements related to Team
meeting invitations and
documentation of Team
meeting attendance. Provide
evidence of the training,
including agenda, training
meetings.
Record review indicates
that the district is not
implementing appropriate
procedures for excusing
Team members from
Team meetings. At times,
parents sign Team
meeting attendance
sheets, indicating that
they have permitted a
Team member not to
attend, but there is no
indication as to whether
the individual’s
attendance was
determined to be not
required or whether the
individual is being
excused. In the case of
the latter, written input
would be required; no
evidence of written input
was seen.
Record review indicates
that regular education
teachers are not always at
Team meetings at the high
school. This is an area
of continuing
noncompliance.
√
Record review
SE 12
Interviews
Re-evaluation
Record review and
interviews indicate that reevaluations are conducted in
a timely manner, and as
appropriate, including before
finding a student is no longer
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 36 of 57
materials and attendance sheets
by March 29, 2008.
Conduct an internal review of
all special education Team
meeting attendance sheets at
the high school level for which
Team meetings have been held
since the training. Provide a
report to the Department,
including the name of
person(s) completing the
review, the number of records
reviewed, number found in
compliance and actions taken
to remedy any non-compliance
by March 29, 2008.
Record review
SE 13
Partial
Progress
Reports
Documentation
eligible for special education.
The district submitted a
recent memo from the
assistant director of special
education reminding all
special education staff that
annual review meetings are
not to be used in place of a
written progress report, and
reminding staff of the new
Department advisory and
progress report forms.
Partial
Record review indicates
that progress reports are
not issued at least as often
as parents are informed of
the progress of nondisabled students. This is
an area of continuing
noncompliance.
At times, student records
contained only one
progress report or no
progress reports since
2005. Progress reports do
not always address all
goals, and at times are
written concerning goals
from IEPs that were not
yet signed.
Record review and
interviews indicate that
Teams do not provide a
summary of academic
achievement for students
who are aging out of
services or graduating.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 37 of 57
Develop an internal oversight
and tracking system to ensure
that progress reports are issued
as often as parents are
informed of the progress of
nondisabled students, as well
as ensuring that progress
reports address all goals.
Submit the following
information:
 Description of the
internal oversight and
tracking system,
including person(s)
responsible for the
oversight;
 Total number of
records reviewed;
 Schools from which
records were selected;
 Number of records in
which progress reports
were issued as often as
parents were informed
of the progress of
nondisabled students;
 Number of records in
which progress reports
address all goals;
 Specific actions taken
by the district to
remedy any continuing
non-compliance.
Submit this report by March
29, 2008.
Provide training for high
school liaisons and out of
district coordinator(s)
concerning the requirement of
completion of a summary of
academic achievement and
performance when a student
ages out of services or
graduates with a diploma.
Provide evidence of this
training, including agenda,
training materials and signed
attendance sheets by March
29, 2008.
Develop an internal oversight
and tracking system to ensure
that the district provides the
student with a summary of
his/her academic achievement
and functional performance.
Submit a description of the
internal oversight and tracking
system with the person(s)
responsible for the oversight.
Also submit a report of an
internal review to include:
 Number of records
reviewed;
 Number of records in
compliance with this
matter;
 Any corrective action
taken for
noncompliance found.
Submit the above report by
June 29, 2008.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 38 of 57
Criterion
Number
and
Topic
SE 14
Review and
revision of
IEPs
SE 20
Criterion
Implement
ed

Record review
Partial
Partial
SE 33
Involvement in
the General
Curriculum
Record review
Documentation
Least
Restrictive
Program
Selected
SE 25B
Resolution of
disputes
Method(s) of
Verification
Interviews
√
Interviews
√
Record review
Interviews
Basis of Determination that
Criterion was Implemented
Records reviewed at the
elementary and middle school
level indicate that annual review
meetings are held in a timely
manner at these levels.
Criterion
Determined
to be
Partially
Implemented
or Not
Implemented

Partial
Interviews indicate that staff are
familiar with new requirements
concerning amendments.
The district submitted two
statements regarding the
district’s compliance with the
least restrictive environment
requirements of the law.
Partial
Basis of Determination
that Criterion was
Partially Implemented
or Not Implemented
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
A number of records
reviewed at the high
school level indicate that
annual reviews are not
always held in a timely
manner. In some cases,
students had not had
current IEPs in several
years.
See SE 18A regarding
nonparticipation
justification statements
and SE 18B regarding
Project Reach.
See SE 22 above.
Interviews indicate that
appropriate administrators are
aware of the requirements of
this criterion.
Interviews indicate that district
personnel understand the
connection between the
Massachusetts 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
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 39 of 57
See SE 18A and SE 18B.
SE 39A
Procedures for
services to
eligible private
school students
whose parents
reside in the
district
(SE 39A does
not apply to
charter schools
or vocational
schools)
Partial
Interviews
Record review
Documentation
curriculum. The district has
taken steps to provide students
(including all students with
disabilities) with essential
learning opportunities that
prepare the students to reach the
state graduation standards. In
addition, interviews and record
review indicate that at least one
member of all IEP Teams is
familiar with the general
curriculum and is able to discuss
an eligible student’s appropriate
access to the general
curriculum. Record review
indicates that the district
documents the student’s
participation in the general
curriculum in IEPs.
The district provided evidence
of child find efforts made at
private schools. Records and
interviews indicate that the
district conducts evaluations and
provides services to students
placed in private schools at
private expense. Interviews and
records indicate that private
school staff are invited to Team
meetings for students placed in
private schools at private
expense.
Partial
The district did not submit
evidence of calculation of
the proportionate share.
Interviews indicate that
administrators are aware of the
requirements to calculate
proportionate share.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 40 of 57
Provide evidence that the
district calculates the
proportionate share of Federal
Special Education Entitlement
funds (Fund Code 240)
required to be spent on eligible
private school students
(including both eligible
students whose parents reside
in the district and eligible
students attending private
school in the district whose
parents reside out of state) and
documents the spending of at
least this amount of federal
entitlement funds (Fund Code
240) on one or more of the
eligible private school students.
Provide this evidence by
March 29, 2008.
SE 39B
Procedures for
services to
eligible
students in
private schools
in the district
whose parents
reside out of
state
SE 46
√
Documentation
Interviews
The district conducts child find
activities for all students
enrolled at private expense in
private schools in the district.
(See SE 15.)
Interviews indicate that
administrators are aware of the
requirements to calculate
proportionate share.
See SE 44
and SE 45
See SE 44 and
SE 45
See SE 44 and SE 45
See SE 44
and SE 45
Procedures for
Suspension of
Students with
Disabilities
See SE 44 and SE 45,
concerning manifestation
determination meetings.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 41 of 57
See SE 44 and SE 45
Criterion
Number/Topic
(Refer to full
text of 20062007 CPR
requirements)
Approved
Corrective
Action
Implement
ed and
Effective

Method(s) of
Verification
Basis of Determination that
Corrective Action was
Implemented and has been
Effective
Corrective
Action Not
Implemented
or Not
Effective
Or
New Issues
Identified

Basis of Determination
that Implementation of
Corrective Action was
Incomplete or
Ineffective
Or
Basis of Finding of New
Noncompliance
Required Corrective Action,
Timelines for
Implementation, and
Progress Reporting
Requirements
See review of
ELE selfassessment.
See review of ELE selfassessment.
See review of ELE selfassessment.
Civil Rights
(MOA) and
Other General
Education
Requirements
MOA 2
Programs
Modifications
and Support
Services for
LEP students
MOA 3
Access to a
full range of
education
programs
See review
of ELE
selfassessment.
√
See review of
ELE selfassessment.
Documentation
Interviews
Although PQA currently does
not monitor for MOA 2,
compliance with these
requirements are monitored
below as part of the ELE selfassessment.
Interviews indicate that all
students, regardless of race,
color, sex, religion, national
origin, sexual orientation,
disability, or homelessness,
have equal access to the general
education program and the full
range of occupational/
vocational programs offered in
the district.
The district submitted a copy of
the District Curriculum
Accommodation Plan, as well as
a statement from the high school
principal that guidance
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 42 of 57
counselors, including bilingual
guidance counselors, review and
explain the programs offered at
the high school to students. In
addition, the district provided
copies of the district’s
handbooks and the course
selection book, translated into
several languages. Interviews
indicate that the district has
hired a full time interpreter to
ensure that students have equal
access.
See MOA 18.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 43 of 57
Documentation
MOA 7
Partial
Interviews
Information to
be translated
into languages
other than
English
The district has translated the
high school course selection
booklet into French and
Spanish, and provided copies.
The district also provided copies
of the student handbook, as
translated into several
languages.
Interviews indicate that the
district has hired a full time
interpreter, who works 12
months and is assigned to the
parent information center. The
district has a number of native
speakers of languages other than
English on staff that other staff
can access for assistance in
interpretation. The district also
uses Catholic Charities for lowincidence languages. In
addition, one elementary
principal purchased translation
software to assist in
implementation of these
requirements.
Partial
The district did not submit
the following:
 Copies of
announcements
and notices
published in
English and in
translation

Copies of school
or program
recruitment and
promotional
materials in
English and in
translation

Description of
distribution,
dissemination
methods.
The district did not submit
evidence of the translation of
general announcements;
however, interviews indicate
that this is completed when
needed.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 44 of 57
Submit a description of the
means by which the district
determines whether parents
and families require translation
of general announcements.
Submit examples of these
translated general
announcements. Provide this
information by March 29,
2008.
MOA 9
Hiring and
employment
practices of
prospective
employers of
students
√
MOA 10A
Handbooks
and codes of
conduct
√
Interviews
Documentation
Interviews
Documentation
Interviews and documentation
indicate that the district has
implemented a system under
which it requires employers
recruiting at the school to sign a
statement that they comply with
applicable state and federal laws
prohibiting discrimination in
hiring and employment
practices. The district provided
a sample of these signed
statements from employers.
The district submitted copies of
student handbooks, in English
and translated into several
languages.
The district also submitted a
teacher code of conduct.
MOA 12A
Annual and
continuous
notification
concerning
nondiscrimination and
coordinators
Partial
Documentation
Interviews
In general, codes of conduct
contain appropriate content.
Please note, however, that the
“exceptional offenses” cited in
the handbook as being required
by M.G.L. ch. 71, § 37H are not
all listed in this section of the
general laws.
The district submitted copies of
brochures and the application
for its Career and Technical
Education programs. The
application was submitted in
English and translation. The
district also submitted a list of
CVTE courses translated into
two other languages.
Partial
Documentation submitted
concerning CVTE
programs contains nondiscrimination statements
that do not include the
protected category of
sexual orientation.
Elementary, middle and high
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 45 of 57
Revise the district’s CVTE
documentation so that nondiscrimination statements
cover all protected categories,
including sexual orientation.
Provide revised documentation
by March 29, 2008.
school handbooks contain
appropriate non-discrimination
statements, and identify
coordinators for ensuring
compliance with Title IX and
Section 504.
MOA 14
Counseling
and counseling
materials free
from bias and
stereotypes
√
Documentation
Interviews
Documentation indicates that
based on the results of language
proficiency assessments,
students are assigned to a
bilingual guidance counselor.
In addition, documentation
indicates that the district
counselors review counseling
materials used in guidance
seminars to ensure that they are
free from bias/stereotypes.
Documentation also indicated
that students can be
administered a career decisionmaking survey in Spanish and
English. Additionally,
interviews indicate that
counseling is available to
students in other languages, if
necessary.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 46 of 57
MOA 15
Nondiscriminatory
administration
of
scholarships,
prizes and
awards
√
MOA 17A
Use of physical
restraint on
any student
enrolled in a
publiclyfunded
education
program
Partial
Interviews
Documentation
Interviews
Documentation
The district submitted a
statement from the high school
principal indicating that
scholarships and award criteria
are established by the awarding
agency/organization.
The district provided a list of
available scholarships and
awards along with criteria to
determine recipients. While
documentation indicates that the
district posts or prints
information regarding private
restricted scholarships, there is
no indication that preferential
treatment is given to any
particular scholarship offered,
or that the district endorses or
recommends any such
scholarship.
The district submitted
statements from principals that
no restraints occurred in their
schools or restraint logs for
some schools.
The elementary, middle and
high school handbooks contain
an overview of the restraint
policy, and include the citation
to the Department’s restraint
regulations.
The district submitted agendas,
signed attendance sheets and
training materials for the
mandatory restraint training,
held at all elementary and
Partial
Interviews indicate that
staff at the high school
did not consistently
receive written
information on the
restraint policies and
procedures. In addition,
interviews and
documentation indicate
that it is not clear that
preschool staff attended
mandated trainings, or
that the mandated training
is provided for employees
hired after the school year
begins, within a month of
their employment. This
is a continuing area of
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 47 of 57
Provide evidence that written
information concerning
physical restraint was provided
to high school staff. Provide
evidence of mandated training
for preschool staff. Provide
evidence that training was
provided for any employees
hired after the beginning of the
school year. Provide this
evidence, including attendance
sheets, agendas and training
materials by March 29, 2008.
MOA 18
Responsibilities of the
school
principal
(SE 50 was
found partially
implemented in
the last CPR;
some of the
responsibilities
of SE 50 have
been transferred
to this
criterion.)
Partial
Documentation
middle schools during the first
month of school. The high
school principal submitted a
statement that the mandated
training had occurred in
September 2006.
Home hospital procedures are
listed in handbooks that were
submitted for review under
other criteria.
Documentation indicates that
the district has in place a district
curriculum accommodation plan
and that individual schools are
to include curriculum
accommodation plans within
their school improvement plans.
Interviews indicate that there
was training on some
components of the DCAP,
specifically, on differentiated
instruction, offered in the fall of
2006.
non-compliance.
Partial
Home hospital procedures
in district handbooks are
outdated. Please see the
first part of
Administrative Advisory
SPED 2003-1: Changes
to Massachusetts Special
Education Law, found at
http://www.doe.mass.edu/
sped/advisories/03_1.html
and Question and Answer
Guide on Home/Hospital
Programs, found at
http://www.doe.mass.edu/
pqa/ta/hhep_qa.html.
Interviews indicate that there is
an informal prereferral team in
place at the high school. In
addition, high school teachers
were informed of the prereferral
process in a memo from the
high school principal sent in
September 2006.
Record review, interviews and
documentation indicate that
information about prereferral
efforts is provided to the special
education team.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 48 of 57
Revise the district’s home
hospital procedures consistent
with requirements. Provide
evidence of the revision by
March 29, 2008.
See comments to ELE selfassessment below concerning
instructional supports for LEP
students.
MOA 21
Staff training
regarding civil
rights
responsibilities
√
Documentation
MOA 24
Partial
Documentation
Curriculum
review process
The district submitted agendas,
signed attendance sheets and
training materials for the
mandatory civil rights training
held at all elementary and
middle schools during the first
month of school. The high
school principal submitted a
statement that the mandated
training had occurred.
The district submitted a
statement concerning the
requirement that, as part of any
new textbook adoption process,
a curriculum review form must
be completed by the respective
curriculum director and
submitted to the assistant
superintendent. The statement
further indicates that curriculum
directors are aware that
purchasing any additional
information requires the use of
the form. The district submitted
a copy of the form.
Partial
The district did not clarify
how it ensures that
individual teachers in the
district review all
educational materials,
including those that are
not textbooks or
additional materials that
are purchased through the
textbook adoption
process. Individual
teachers must review all
educational materials for
simplistic and demeaning
generalizations, lacking
intellectual merit, on the
basis of race, color, sex,
religion, national origin
and sexual orientation.
Appropriate activities,
discussions and/or
supplementary materials
must be used to provide
balance and context for
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 49 of 57
Develop a mechanism for
individual teachers to review
all educational materials.
Ensure that all teachers are
aware of their individual
obligations under these
requirements. Provide
evidence of the above by
March 29, 2008.
Provide examples of such
individual teacher review from
each level by June 30, 2008.
any such stereotypes
depicted in such
materials.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 50 of 57
WALTHAM PUBLIC SCHOOLS
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

ELE 1
Annual
Assessment
√
ELE 2
MCAS
Participation
√
ELE 3
Initial
Identification
√
ELE 4
Waiver
Procedures
√
ELE 5
Program
Placement
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
Though the Department finds this criterion to be substantially
implemented, the district states in its self-assessment that students
who speak low incidence languages who register immediately before
or during MCAS testing are difficult to accommodate (with bilingual
dictionaries). Note that the district must ensure that all students are
accommodated appropriately during MCAS.
See ELE 10.
See ELE 10.
The district submitted a statement of practices concerning program
placement and structure, including information about the recent
restructuring of the high school SEI program. Currently at the high
The district must continue to train teachers at all
levels, especially at the middle and high school
levels, in SEI so that teachers at all levels and
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 51 of 57
ELE
Criterion
Number
and
Topic
and Structure
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
school, the district offers only a limited number of ELL courses, in
which content is sheltered for students learning English. Specifically,
students that wish to take a science class with a teacher who is trained
in sheltering techniques must take “SEI Science,” “SEI Chemistry I”
or “SEI Chemistry 2”; history is limited to three courses, and math is
limited to two algebra courses. The teachers of the SEI science,
history and math courses are dual certified and most are multilingual.
None of these are honors or advanced placement courses. Additional
documentation indicates that ELL students take either ELL
Composition or MCAS Preparation in grades 11 and 12 class at the
high school. Students can elect other courses only if they refuse the
ELL program, or if they have sufficient English skills.
teachers of all courses can teach limited English
proficient students with English-speaking peers.
The district must provide training in supporting
LEP and FLEP students in the general curriculum.
In addition, professional development should
include training to prevent the inappropriate
referral of LEP students for special education when
a disability is not suspected. Provide evidence of
the district’s professional development plan in this
regard by March 29, 2008, and evidence of the
implementation of the plan by June 30, 2008.
While the district may offer its “ELL” and “SEI” courses to ELL
students, by requiring ELL students to take certain courses offered by
certain teachers, the district denies ELL students equal access to the
full range of courses.
It is not clear whether teachers in the CVTE programs at the high
school have been trained in sheltering content, or how the district
otherwise ensures equal access to these programs.
It is not clear whether teachers of “specials” at all levels have been
trained in sheltering content, or how the district otherwise ensures
equal access to these classes.
Documentation indicates that students have been inappropriately
referred for special education when mainstreamed, reportedly
according to a use of objective measures or classroom measures
applied in isolation, including MEPA or MCAS scores, or class
grades.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 52 of 57
Please also provide the district’s plan to ensure that
all ELL students have full access to all courses.
Provide this plan by March 29, 2008, and
evidence of its implementation by June 30, 2008.
ELE
Criterion
Number
and
Topic
ELE 6
Program Exit
and
Readiness
ELE 7
Parent
Involvement
ELE 8
Declining
Entry to a
Program
Criterion
Determined to be
Implemented
Based on Review
of Local ELE
Self-Assessment

Partial
Partial
Partial
Findings of Noncompliance Based on Department’s
Review of Local ELE Self-Assessment
(Criterion Determined to be Partially Implemented or Not
Implemented)
See ELE 14 and 15, concerning licensure and professional
development.
The district currently requires parent consent for exiting students from
the ELL program. In addition, the letter to parents concerning the exit
of their students from the ELL program states that the student will be
classified as FLEP at the end of the school year. The district should
re-classify the student as FLEP as soon as the decision is made, and
not wait until the end of the school year.
The district submitted evidence of outreach to parents of ELL students
at the elementary, but not the middle and high school levels.
The district submitted a copy of its parent notification form. The
notification form requires consent for participation in the ELL
program to begin, which is not appropriate. (See ELE 10.)
The district submitted a copy of a notice that urges parents to
reconsider their decisions to decline entry, and notes that “[r]efusal to
accept services may have a negative impact on your child’s academic
progress and English language learning.” The district is reminded
that federal law establishes a district’s obligation to provide LEP
students with meaningful access to the educational program. When a
parent declines participation in a formal language instruction
program, the district must continue monitoring the educational
progress of the student to ensure that the student has an equal
opportunity to have his or her English language and academic needs
met. According to Department guidance, districts can meet this
obligation in a variety of ways, for example, by providing adequate
training to classroom teachers on second language acquisition and
English language development and by offering English language
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 53 of 57
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
Revise the notification of student exit from LEP as
per the previous column. Submit the new letter
and procedures by March 29, 2008.
Submit evidence of parent outreach at the middle
and high school levels, including a description of
the means of including parents or guardians of LEP
students in matters pertaining to their children’s
education. Provide this description, including
evidence of the above, by March 29, 2008.
The district should revise the letters noted in the
previous column, and must ensure that parents are
informed that even if they choose to decline
services, the district remains obligated to ensure
that the student has an equal opportunity to have
his or her English language and academic needs
met. Provide the revised letter by March 29,
2008.
ELE
Criterion
Number
and
Topic
Criterion
Determined to be
Implemented
Based on Review
of Local ELE
Self-Assessment

ELE 9
Instructional
Grouping
Partial
ELE 10
Parental
Notification
Partial
Findings of Noncompliance Based on Department’s
Review of Local ELE Self-Assessment
(Criterion Determined to be Partially Implemented or Not
Implemented)
support to the student.
See ELE 5.
Required Corrective Action,
Timelines for Implementation,
and Progress Reporting
See ELE 5.
The SEI program is first explained verbally to parents. A letter
entitled “Understanding SEI” encourages parents to accept
recommendations for SEI, but does not explain alternatives, such as
waiver and opt out. This letter only addresses the requirement that the
parent be informed of the program placement and/or the method of
instruction used in the program. Additionally, the notice seeks
consent for ELL services to begin. This is not necessary and can
delay the implementation of appropriate instruction.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 54 of 57
The district must create a notice that meets all
requirements of this criterion. Specifically, the
following is required for parental notification:
(a) the reasons for identification of the
student as Limited English
Proficient (LEP);
(b) the child’s level of English
proficiency;
(c) program placement and/or the
method of instruction used in the
program;
(d) how the program will meet the
educational strengths and needs of
the student;
(e) how the program will specifically
help the child learn English;
(f) the specific exit requirements; and
(g) the parents’ right to apply for a
waiver (see ELE 4), or to decline
to enroll their child in the
program (see ELE 8).
(All districts need to comply with a-c and g. Title
III districts must comply with a-g. Title III
districts must send parental notification no later
than 30 days after the beginning of the school
year, and annually thereafter.)
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
Provide a copy of this notice by March 29, 2008.
ELE 11
Equal Access
to Academic
Programs
and Services
Partial
See ELE 5.
According to documentation submitted with ELE 12, staff work
directly with parent information liaisons, parents and students to
inform students about extracurricular activities, using the district
translator as necessary. In addition, the district has translated its high
school course selection booklet into two other languages.
Provide a description of the means by which the
district ensures that LEP students have equal
access to academic programs and services.
Provide this description, and evidence of its
implementation by March 29, 2008.
However, it is not clear how the district ensures that students have
equal access to all academic programs and services.
ELE 12
Equal Access
to
Nonacademic
and
Extracurricular
Programs
ELE 13
Follow-up
Support
ELE 14
Licensure
Requirements
√
Partial
Partial
The district’s self-assessment indicates that it has created a FLEP
monitoring form for compliance with these requirements, but does not
state whether this monitoring will continue for two years and whether
the district would provide language support services to those students,
if needed
The district did not submit a self-assessment of the implementation of
this criterion. The documentation submitted by the district includes a
statement by the Director of ELL and Foreign Language that she can
attest that all departmental teachers are licensed.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 55 of 57
Ensure that the FLEP procedures are consistent
with requirements, and that monitoring occurs for
two years following a student’s exit from the ELL
program. Provide evidence of the above by March
29, 2008.
Submit the staff roster for staff teaching LEP
students and submit copies of licensure for these
staff members. On this roster include staff
providing English language instruction (ESL).
Submit this roster by March 29, 2008.
ELE
Criterion
Number
and
Topic
Criterion
Determined to be
Implemented
Based on Review
of Local ELE
Self-Assessment

ELE 15
Professional
Development
Requirements
Partial
ELE 16
Equitable
Facilities
Partial
ELE 17
Program
Evaluation
Partial
ELE 18
Records of
LEP
Students(To be
reviewed
during next
CPR visit.)
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 did not submit a self-assessment of the implementation of
this criterion. However, other documentation indicates that some staff
have received professional development in sheltering content
instruction. Specifically, training in different categories is noted for
some staff. Interviews indicate that the district is currently
conducting a self-evaluation of its ELE program.
The district did not submit a self-assessment of the implementation of
this criterion. Interviews indicate that the district is currently
conducting a self-evaluation of its ELE program.
Submit the roster of staff taking part in SEI
training. On the roster include the names, grade
levels and ELE training topics that staff have taken
part in or are scheduled to participate in. Submit
this information by March 29, 2008.
The district did not submit a self-assessment on the implementation of
this criterion. Interviews indicate that the district is currently
conducting a self-evaluation of its ELE program, and that recent
changes have been made due to informal evaluation activities.
To be reviewed during next CPR visit.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 56 of 57
Complete a self-assessment of the implementation
of this criterion. Provide a report of this selfassessment and a written description of the
district’s actions taken in response to the
assessment by March 29, 2008.
Submit the report of the ELE program evaluation
by June 30, 2008.
Waltham Public Schools Mid-cycle Review Report
February 21, 2008
Attachment A – SE 40
Instructional grouping requirements for students ages five and older
The district submitted schedules of special education instructional groups. District documentation
indicates that the following instructional groupings exceed the class size standards of
regulations:


















A speech and language group at the Stanley Elementary School.
A grade five language-based resource room at the Whittemore Elementary School.
Two learning center classes at the Kennedy Middle School.
A grade six learning center at the McDevitt Middle School.
A grade seven/eight learning center at the McDevitt Middle School.
Several classes taught by the Piantedosi House special educator at the high school.
The Project Reach math class at the high school.
Several classes taught by the Gavin House special educator at the high school.
A language based resource room reading class at the high school.
A language based resource room English class at the high school.
At least ten periods of study and organizational skills classes at the high school.
An algebra class, Math 9-1, assigned to a special educator at the high school.
An English/ELA class assigned to a special educator at the high school.
An English 12 class taught by the special education English teacher.
World History and US. History classes taught by the special education history teacher at the
high school.
Four periods of life skills classes at the high school.
English 9 and English 11 classes taught by the special education English teacher at the high
school.
A special education class at the high school; list submitted by the district does not identify
teacher or subject.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 57 of 57
Waltham Public Schools Coordinated Program Review Mid-cycle Report
February 21, 2008
Page 58 of 57