Massachusetts Department of
Elementary and Secondary Education
75 Pleasant Street, Malden, Massachusetts 02148-4096
Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
June 10, 2013
Susan M. Nicholson, Superintendent
Waltham Public Schools
617 Lexington Street
Waltham MA 02452
Re: Mid-cycle Report
Dear Superintendent Nicholson:
Enclosed is the Department of Elementary and Secondary Education's Mid-cycle Report based on the
onsite visit conducted in your district in March of 2013. During the Mid-cycle Review the Department
monitored selected special education criteria to determine your district’s compliance with special
education laws and regulations. The review consisted of information gathered from one or more of the
following activities: staff interviews, review of student records, examination of documentation, and/or
classroom observation.
We are pleased to tell you that the Department has found your district to be in compliance with all of the
criteria monitored in your district during the Mid-cycle Review. The findings of the Department are
included in the enclosed report. You and your entire staff are to be congratulated for your success in
implementing the requirements included in these criteria.
The Department will notify you of your district's next regularly scheduled Coordinated Program Review
(CPR) several months before it is to occur. At this time we anticipate that this CPR will occur sometime
during the 2015-2016 school year unless the Department determines that there is some reason to schedule
this visit earlier.
1
Your staff's cooperation throughout this Mid-cycle Review is appreciated. If you have questions about
this letter or the enclosed report, please do not hesitate to contact Nathan Lemmon at 781-338-3720.
Sincerely,
Nathan Lemmon, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene A. Lynch, Director
Program Quality Assurance Services
cc:
Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education
Jane Ewing, Supervisor, Program Quality Assurance Services
Jeannette McCarthy, Mayor, School Committee Chairperson
Valerie Ardie Flynn, Local Program Review Coordinator
Enc:
Mid-cycle Report
2
MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION
MID-CYCLE REPORT
WALTHAM PUBLIC SCHOOLS
Dates of the Mid-cycle Review Onsite: March 13-14, 2013
Date of this Report: June 10, 2013
PLEASE NOTE THAT THIS REPORT IS IN TWO SECTIONS.
Required Special Education Criteria Monitored in this Mid-cycle Review
Current special education criteria available by scrolling down to the special education instrument at
http://www.doe.mass.edu/pqa/review/cpr/default.html
Criterion
SE 7
Transfer of
Parental Rights
and Student
Participation and
Consent at Age of
Majority
Criterion
Implemented


Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
Document
Review
Document review, interviews
and student record review
demonstrated that the district
consistently notifies parents and
students of the transfer of
educational decision-making
rights one year prior to students
Interviews
Student Record
Review
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and
Timelines for
Implementation
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 1 of 22
(b)
Progress
Report
Due
Date(s)
and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and
Timelines for
Implementation
reaching the age of 18.
Student records demonstrated
that IEP Teams put a statement
in the IEP that parents and
students are informed of the
transfer of rights from the
parent/guardian to the student
upon the student's 18th birthday.
When a student decides to share
or delegate educational
decision-making rights,
documentation indicating the
student’s choice is found in the
student record as required.
Student records also
demonstrated that the district
consistently obtains consent
from students to continue IEP
services when they have reached
the age of majority.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 2 of 22
(b)
Progress
Report
Due
Date(s)
and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation

Interviews
Student Record
Review
SE 8
IEP Team
composition and
attendance
Basis of Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and
Timelines for
Implementation
Student record review and
interviews indicated that the
district has a process to ensure
that required IEP Team
members attend IEP meetings.
When a required IEP Team
member can’t attend, the district
obtains the parent’s written
permission before the meeting to
excuse the Team member.
The district also demonstrated
that required excused Team
members provide written input
for IEP development in advance
of the meeting.
The district has a policy for
excusing Team members who
are not necessary because their
area of the curriculum or
services is not being modified or
discussed.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 3 of 22
(b)
Progress
Report
Due
Date(s)
and
Required
Elements
Criterion
Criterion
Implemented


Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
Document
Review
Document review and student
record review indicated that
when a student’s evaluation data
indicates that his/her disability
affects social skills development
or makes them susceptible to
bullying, harassment, or teasing,
the IEP Team addresses the
skills and proficiencies needed
to avoid and respond to
bullying, harassment, or teasing.
Student Record
Review
SE 18A
IEP Development
and content
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and
Timelines for
Implementation
The IEP Team specifically
addresses the skills needed to
respond to bullying, harassment,
or teasing for students on the
autism spectrum in the student’s
IEP.
Record review demonstrated
that the IEP Team documents its
consideration of a student’s
need for skills and proficiencies
to avoid and respond to
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 4 of 22
(b)
Progress
Report
Due
Date(s)
and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and
Timelines for
Implementation
bullying, harassment, or teasing
in the Meeting Summary, in the
district’s Notice of Proposed
District Action accompanying
the IEP, and as an
accommodation or as a social
skill, self-advocacy or adaptive
behavior goal in the IEP.

Document
Review
Interviews
SE 25
Parental consent
Document review and staff
interviews indicated that when
parents revoke consent for
special education services in
writing, the district acts
promptly to provide notice to
discontinue services within a
reasonable timeframe and attach
a copy of the parent’s
procedural safeguards.
Additionally, an interview with
the Special Education Director
verified that the school will not
use mediation or request a due
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 5 of 22
(b)
Progress
Report
Due
Date(s)
and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and
Timelines for
Implementation
process hearing to obtain
agreement or a ruling requiring
the continuation of services,
consistent with federal
regulation.
The district did not have any
current records for revocation of
consent at the time of the midcycle review.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 6 of 22
(b)
Progress
Report
Due
Date(s)
and
Required
Elements
Additional Special Education Criteria Monitored in this Mid-cycle Review
Current special education criteria available by scrolling down to the special education instrument at
http://www.doe.mass.edu/pqa/review/cpr/default.html
Criterion
SE 3
Special
Requirements for
Determination
Specific Learning
Disability
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation

Interviews
Student Record
Review
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
Student record review
and interviews
demonstrated that the
district’s IEP Teams
consistently complete
all required
documentation when
determining eligibility
for a Specific Learning
Disability for both
initial evaluations and
re-evaluations.
The district’s
Instructional Support
Team documents prereferral general
education support for
students, including
specific instructional
accommodations,
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 7 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
classroom assessments,
behavioral strategies,
and observations,
which are consistently
present in the files.
SE 4
Reports of
Assessment Results

Interviews
Student Record
Review
Student record review
and interviews
demonstrated that
assessment reports are
consistently completed
before IEP meetings,
with assessment
summaries available
two days prior should
parents request them.
Assessment summaries
consistently contain the
evaluators’
recommendations for
specifically meeting the
students’ needs.
SE 6
Determination of
Transition Services

Student Record
Review
Student record review
indicated that out-ofdistrict students who
are 14 years old and
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 8 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
older consistently have
completed and annually
updated transition plans
in their files.

Student Record
Review
SE 9
Determination of
Eligibility and
Provision of
Documentation to
Parent
SE 9A
Elements of
Eligibility
Determination

Interviews
Student Record
Review
Student record review
demonstrated that the
district consistently
meets the 45-day
timeline for
determining eligibility
and developing IEPs
following the receipt of
the parent’s written
consent.
Student record review
and interviews
demonstrated that when
students are found not
eligible for special
education services, the
district’s Notice of
School District Refusal
to Act (N2) includes
information about next
steps to take, including
general education
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 9 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
support or a 504 plan
consideration if
appropriate.
SE 11
School District
Response to
Parental Request
for Independent
Educational
Evaluation

Document
Review
Interviews
Student Record
Review
Document review and
student record review
demonstrated that the
district’s response to a
parent’s request for
independent
evaluations includes
1) a statement
acknowledging that the
unique circumstances
of a child may justify
an individual
assessment rate higher
than that normally
allowed; 2) a reference
to the federal law that
enables parents to
obtain an independent
evaluation; and 3) a
description of the state
and federal provisions
entitling parents to an
independent evaluation
in an area not assessed
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 10 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
by the district.
No references to Ch.
766 (now Ch. 71B)
were found in the
district’s documents or
student records.
SE 12
Frequency of Reevaluation

SE 13
Progress Reports
and Content

Student Record
Review
Interviews
Student Record
Review
The student record
review indicated that
re-evaluations are
completed every three
years unless the parent
and district agree that it
is unnecessary.
According to staff
interviews and student
records, the district
translates all required
special education
documentation,
including the IEP and
progress reports when
the parent’s primary
language is not
English.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 11 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
Student record review
also demonstrated that
when students graduate
or age out of school,
their records contain
the summary of
academic achievement
and performance.
SE 14
Review and
Revision of IEPs

Student Record
Review
Student record review
demonstrated that
annual reviews of
student IEPs
consistently occur on or
before the anniversary
date of the previous
IEP to review, revise,
develop a new IEP or
refer the student for reevaluation.
Student record review
also indicated that the
amendment process is
not used to change a
student’s placement.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 12 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
SE 15
Outreach by School
District
Criterion
Implemented


Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
Document
Review
Document review and
interviews
demonstrated that the
district actively
conducts child-find for
students in the
community and does
not limit its activities to
pre-school aged
children only. The
district’s activities
include multiple forms
of outreach to homeless
shelters and other relief
agencies in the
community.
Interviews
SE 18A
IEP Development
and Content

Student Record
Review
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
Student record review
demonstrated that IEP
Teams consistently
complete the Present
Level of Education
Performance for other
educational needs
(PLEP B) section of the
IEP for students with
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 13 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
age-related
considerations or
behavioral issues.
SE 19
Extended
Evaluation

SE 22
IEP
Implementation
and Availability

Student Record
Review
Document
Review
Interviews
Student Record
Review
Student record review
demonstrated that IEP
Teams complete the
ESE’s extended
evaluation form (EE1EE2) to document
additional evaluations
when a Team finds a
student eligible for
special education but
finds the evaluation
information insufficient
to develop a full or
partial IEP.
Record reviews,
interviews and
documents provided by
the district indicated
school adjustment
counseling services are
scheduled during
appropriate school
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 14 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
hours (e.g., not during
student lunch periods)
and appropriately
included in IEP Service
Delivery Grids and
with goals and
benchmarks as
determined by the IEP
Teams.
SE 24

Student Record
Review
Notice
Requirements
SE 29
Communications
are in English and
Primary
Language of the
Home

Student Record
Review
According to student
record review, the
district consistently
responds to parental
requests for evaluations
within five days of the
receipt of the parental
request for an
evaluation.
Student record review
indicated that when the
primary language of the
home is other than
English, the district
translates all parts of
the student record.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 15 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

SE 36
IEP
Implementation,
Accountability, and
Financial
Responsibility

SE 37
Procedures for
Approved and
Unapproved Outof-District
Placements

SE 40
Instructional
Grouping
Requirements
Students Aged
Five and Older

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Student Record
Review
Student Record
Review
Document
Review
Interviews
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
Please see the ESE’s
comments for SE 22.
Student record review
demonstrated that
monitoring plans are
maintained in out-ofdistrict student files as
required.
Document review and
interviews
demonstrated that none
of the district’s special
education classes
exceed instructional
group size.
The district has
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 16 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
developed a
comprehensive system
for all three levels,
elementary, middle and
high school, to ensure
that special education
classes do not exceed
the required
instructional grouping
ratios of staff to
students as follows:
1. The Special
Education
Office is
notified
whenever any
changes are
proposed to
class size at
any school.
2. If a new
student is
introduced to a
class causing it
to go over the
allowed limits,
the district will
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 17 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
respond by
reassigning
staff members
to maintain
appropriate
class size and
staff to student
ratios.
3. Evaluation
Team Leaders
and
Administrators
are informed
by the
Guidance
Department of
schedule
changes.
4. Finally, all
liaisons meet
regularly with
the Evaluation
Team Leader to
discuss class
size.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 18 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
SE 43
Behavioral
Interventions
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation

Interviews
Student Record
Review
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
Interviews and student
record review indicated
increased provision of
behavioral supports for
all students at all levels
of the school district.
Student record review
demonstrated a variety
of behavioral supports.
Examples include
students at all levels
receiving counseling,
when indicated on their
IEP Service Delivery
Grid.
Interviews indicated
that there are now six
(6) full time school
adjustment counselors
working at the
elementary level; one
full time and one and
one half time (1.5)
school adjustment
counselors at the
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 19 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
middle school level;
and four (4) full time
school adjustment
counselors working at
the High School.
There are also two and
a half (2.5) BCBAs
(Board Certified
Behavior Analyst)
available to conduct
functional behavioral
assessments.
SE 46
Procedures for
Suspensions of
Students with
Disabilities

Document
Review
Student Record
Review
Document and student
record review
demonstrated that the
district’s student/parent
handbook contains a
description of the
procedures and the due
process rights for
students in
circumstances
involving drugs,
weapons, controlled
substances, or bodily
assault.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 20 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
SE 48
Equal Opportunity
to Participate
Criterion
Implemented


Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Document
Review
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
Please see the ESE’s
comments for SE 22.
Interviews
Student Record
Review
SE 49
Related Services

Document
Review
Please see the ESE’s
comments for SE 22.
Interviews
Student Record
Review
SE 55
Special Education
Facilities and
Classrooms

Facility Review
Facility review verified
that the Plympton
Elementary School’s
special education
Learning Center is no
longer labeled as such
and the John F.
Kennedy Middle
School Life Skills
program has been
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 21 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements
Criterion
Criterion
Implemented

Criterion
Partially
Implemented
(PI) or Not
Implemented
(NI)
Method(s) of
Investigation
Basis of
Determination
about Criterion
If Partially Implemented or
Not Implemented:
(a) Required Corrective
Action and Timelines for
Implementation
moved from an isolated
corridor to a classroom
in a corridor with other
general education
classrooms.
Waltham Public Schools Coordinated Program Review Mid-cycle Report
June 10, 2013
Page 22 of 22
(b) Progress
Report Due
Date(s) and
Required
Elements