The Commonwealth of Massachusetts Department of Education

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The Commonwealth of Massachusetts
Department of Education
350 Main Street, Malden, Massachusetts 02148-5023
Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
June 8, 2005
Dr. James D. Collins
Superintendent
Wareham Public Schools
54 Marion Ave.
Wareham, MA 02571
Re: Onsite Follow-up Monitoring Report: Coordinated Program Review
Corrective Action Plan Verification and Special Education Mid-cycle Review
Dear Superintendent Collins:
Enclosed is the Department's Coordinated Program Review Follow-up Monitoring Report
together with findings regarding your district’s Coordinated Program Review Mid-cycle Review.
This report contains the Department's findings based on the onsite activities conducted in your
school district to verify the implementation status and effectiveness of corrective steps taken in
response to your Coordinated Program Review Report issued on September 11, 2002.
While the Department of Education found certain noncompliance issues to be resolved, others
were partially corrected, not addressed at all and/or the Department’s onsite team identified new
issues. In areas where the district has failed to implement fully its approved Corrective Action
Plan, the Department views these findings to be serious.
As stated in the enclosed Mid-Cycle Review Report, the Department continues to document
areas of serious noncompliance with state and federal law, particularly in special education and
civil rights. In 2002, the district proposed corrective action to remedy all areas of
noncompliance identified by the Department at that time. The Department approved these
corrective action plans, and since that time the district has provided the Department with written
progress reports describing implementation of these approved plans. However, as a result of the
verification activities in March 2005, which consisted of staff interviews, student record reviews,
documentation review and classroom observations, the Department found that the approved
corrective action plans have either; (1) not been implemented as approved by the Department; (2)
been determined to be very unevenly implemented at the building level; (3) or been documented
to be implemented but have been found to be ineffective in addressing the identified
noncompliance. This is in direct contrast to the written assurances submitted by the district in
progress reports and other statements of assurance filed with the Department as condition for
receiving state and federal funds.
The Department documented 18 findings of special education noncompliance by the district in
2002, and the enclosed Mid-Cycle Report documents 23 findings of noncompliance in the
Wareham Public Schools special education programs, 13 of which are areas of continuing
noncompliance. This is not acceptable after three years of reported corrective action effort.
As the Department previously informed you, in cases where a district fails to fully and
effectively implement a Corrective Action Plan, which was proposed by your district and
approved by the Department, the Department must then prepare a Corrective Action Plan for the
district, which must be implemented without further delay. You will find these requirements for
corrective action and further progress reporting included in the attached report together with any
steps that must be taken by the district to fully implement new special education requirements.
Please provide the Department with your written assurance that the Department's requirements
for corrective action will be implemented by your school district within the timelines specified.
Your statement of assurance must be submitted to the Department's Onsite Chairperson by June
24, 2005.
Your staff's cooperation throughout these Follow-up Monitoring activities is appreciated.
Should you require additional clarification of information included in our report, please do not
hesitate to contact the Onsite Team Chairperson at 781-338-3715.
Sincerely,
Joan Brinckerhoff, Ph.D., Coordinated Program Review Follow-up Chairperson
Program Quality Assurance Services
John D. Stager, Administrator
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
William P. Doherty, School Committee Chairperson
Susan Lynch, District Program Review Follow-up Coordinator
Encl.: Follow-up Monitoring Report
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
COORDINATED PROGRAM REVIEW
WAREHAM
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION
Action Plan Submitted on October 29, 2002
Progress Reports Submitted on May 21, 2003, September 29, 2003, March 6, 2004, August 31, 2004, and January 10, 2005.
Onsite Visit Conducted on March 28-30, 2005
Date of this Report June 8, 2005
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Special
Education
Requirements
SE 3
Special
requirements
for
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

Documentation,
Student
Records and
Interviews
The documentation included
procedures for the observation
by someone other than the
Partial
When the district was
making a determination
of a specific learning
disability (SLD), the
Amend procedures for the
determination of a specific
learning disability to include
meeting participants, the
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
determination
of specific
learning
disabilities
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Team did not always
include a regular
education classroom
teacher. The procedures
for staff did not include
information on the
specific learning
disability determination
form or a copy of the
form. Student records
indicated that the SLD
forms were not always
fully completed and in
some cases not part of the
student record.
required observation by
someone other than the
classroom teacher and the use
of the SLD form. Provide
training to all special
education staff and submit
agendas and sign-in sheets
with name, role and signature.
Submit amended procedures,
evidence of training, and a
monitoring plan to ensure
meeting attendance and
completed documentation filed
in the student record by
September 30, 2005. A record
review will also be scheduled
in March of 2006.

student’s classroom teacher.
2
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 6
Determination
of transition
services
(Emphasis on
practices in
determining
needed
transition
planning and
services and
consideration
of courses of
study related to
needed
transition)
SE 13
Progress
Reports and
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
District specific
procedures and forms for
transition were not
included in the
documentation. The
vision statement on the
IEP was not always
supported by the IEP with
goals and services.
Course of study was not
documented in IEPs. IEP
services did not promote
movement for students to
post-school activities.
While guidance
counselors were present
at the Team meetings,
they did not provide
information for the vision
statement or for goals.
Student records did not
include progress reports
for each goal at each
Provide training to high school
special education staff and
guidance counselors on the
requirements for transition.
Submit procedures and forms
to document transition services
for students 14 years of age
and older. Submit training
agenda, handouts and sign-in
sheet with name, role and
signature by September 30,
2005. A record review will
also be scheduled in March of
2006.

Partial
Documentation,
Student
Records and
Interviews
Documentation included
information from the federal
regulations with all required
elements. Chapter 688 forms
are typically completed early
and are maintained in the
student record. Team meetings
included representatives from
outside agencies.
Partial
Documentation,
Student
Records and
Interviews
District procedures contain
information on timelines,
content requirements and
Partial
Partial
3
Submit procedures for writing
progress reports, evidence of
training (sign-in sheet with
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
content
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

provide a sample form.
reporting period. Content
did not include progress
toward the specific goal
or benchmarks. When a
lack of progress was
documented, further
actions were not noted.
Progress reports did not
always indicate whether
the progress was
sufficient to accomplish
the goal by the end of the
IEP period. Team
meetings were used as a
means to report progress,
however no written report
was included as a
progress report.
4
name, role, signature and
date), and a monitoring plan
for each building by
September 30, 2005.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 15
Outreach by the
School District
(Child Find)
SE 17
Initiation of
services at age
three and Early
Intervention
transition
procedures
SE 18A
IEP
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation


Partial
Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The district did not
conduct transition
activities in the natural
environment. Some
assessments were
conducted after the initial
IEP meeting that were
documented on the initial
consent form. Referral
information was not acted
on in a timely manner.
Submit procedures to ensure
the consent form is provided
within five school working
days after a referral is made.
Submit transition plan
procedures for preschool staff
to observe children in their
natural environment. Submit
procedures to monitor
administration of assessments
consented to by parents by
September 30, 2005.
Specially designed
instruction was not fully
Conduct training for all
Chairpersons on the

Documentation
and Interviews
Documentation,
Student
Records and
Interviews
Documentation,
Student
The district annually conducts
outreach to a variety of
agencies, professionals and
programs including: homeless
shelters, day care facilities,
private schools, early
intervention programs, and
other agencies.
The district maintains a
relationship with the early
intervention program. The
district facilitated the National
Association for the Education
of Young Children (NAEYC)
accreditation for several
community preschools serving
children from birth to five.
IEPs are written in generally
understandable language. Each
5
Partial
Partial
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
development
and content
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
described. Content
modifications did not
indicate how content was
modified. Goals were not
measurable. The present
level of educational
performance (PLEP) did
not identify how a
student’s disability
affected their
performance in the
general education
curriculum. Service grids
did not always reflect all
goals in the IEP. Other
sections of the IEP such
as transportation and
extended school year
were not always
completed.
development of IEPs. Develop
and submit procedures for
monitoring IEPs for content
within each school building by
September 30, 2005.

Records and
Interviews
Team included a member with
the authority to commit district
resources.
6
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 18B
Determination
of placement;
immediate
provision of
IEP to parent
SE 20
Least restrictive
program
selected
SE 22
IEP
implementation
and availability
(Emphasis on
provision of
IEP services
without delay;
provision of the
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Some records did not
include the placement
page (PL 1) in the student
record.
Submit monitoring procedures
to ensure that placement pages
are part of the IEP filed in the
student record by September
30, 2005.
The justification for
removal from the regular
education classroom
documented in the IEP
was not individualized.
Submit agendas to train all
staff (special educators and
related service providers) to
write individualized
justifications for removal from
the regular education
classroom by September 30,
2005.
Develop and submit
procedures to ensure:
Current IEPs are in effect at
the beginning of each year;
Staff sign off on
responsibilities for
implementation of each IEP;
and, Inform parents
immediately of any staff

Partial
Documentation,
Student
Records and
Interviews
The Team regularly documents
consideration of the least
restrictive environment.
Partial
Documentation,
Student
Records and
Interviews
The district documentation
contained a local description for
least restrictive setting with the
continuum of educational
placements.
Partial
Documentation,
Student
Records and
Interviews
The district developed a Team
Process Checklist to assist in
tracking all documentation and
timelines. The Team Process
Checklist is signed by the Team
chairperson and the Student
Services Office to monitor
district procedures.
7
Partial
Partial
Partial
The district did not
submit procedures for
starting the year with
current IEPs.
Documentation of how
teachers were informed of
their responsibilities to
implement portions of an
IEP was not submitted.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

IEP at the
beginning of
the school year;
and, alternative
methods of
service delivery
where there is a
lack of space
and/or
personnel))
District documentation
includes procedures to
inform parents of an
interruption of service
two weeks after the
service is interrupted.
8
shortages resulting in
interrupted services by
September 30, 2005.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 26
Parent
participation in
meetings
(Emphasis on
district’s
attempts to
ensure parent
participation at
IEP Team
meetings)
SE 28
Parent provided
the IEP or
notice of no
eligibility
together with
notification of
procedural
safeguards and
parents' rights
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The Notice forms (N 1
and N 2) did not always
include the guiding
questions. The narrative
on the notices was not
always sufficient to
address the required
content. In a few
instances the records did
not include the notice
form.
Submit evidence that the
software prints out the Notice
forms with the guiding
questions for all buildings.
Submit evidence of training on
the content required for notice
forms (agenda, sign-in sheet
with name, role, and
signature). Submit a plan to
monitor that notice forms are
sent to parents and a copy is
maintained in the student


Documentation,
Student
Records and
Interviews
Partial
Documentation,
Student
Records and
Interviews
The district submitted the
required data for parent
participation in Team meetings.
A relatively high rate of
participation is reported and
student records reviewed
documented efforts to
reschedule and obtain parental
input for Team meetings.
Most parents signed the IEP at
the meeting. Staff reported the
explanation used at Team
meetings including the option to
take the Team copy with them
for review and discussion over
the next 30 days. Parents were
provided with a copy of
procedural safeguards.
9
Partial
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

record by September 30, 2005.
10
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 29
Communications are in
English and
primary
language of
home
SE 32
Parent advisory
council for
special
education
SE 50
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Partial
Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The district did not
document procedures for
staff to secure interpreters
familiar with special
education procedures,
programs and services.
The requirements to
document any oral or
alternative
communications that are
not written were not
submitted.
The PAC officers
unanimously resigned as
of March 4, 2005,
resulting in an inactive
PAC.
The PAC by-laws from
10-17-00 were submitted.
Submit procedures for staff to
secure interpreters familiar
with special education
procedures. Submit
procedures to document any
communications that are not
written by September 30,
2005.
Procedures for the
Submit written procedures for

Documentation,
Student
Records and
Interviews
The district reports numerous
resources within district and
from other districts that can
fulfill the need for translation
when needed.
Documentation
and Interviews
The district in collaboration
with the PAC conducted a
Parent’s rights workshop in
November 2004.
The school committee provides
the PAC assistance without
charge when reasonable notice
is provided subject to
availability of staff and
resources.
The procedures for providing
Documentation,
11
Partial
Partial
Submit an officer roster for the
PAC and a set of by-laws that
have been adopted by the new
PAC by July 6, 2005.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Responsibilities
of the School
Principal and
Administrator
of Special
Education
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
provision of instructional
support and forms were
not submitted. The
resources available within
each building were not
identified.
the provision of instructional
support that delineate the
resources available within each
building by September 30,
2005.

Student
Records and
Interviews
educational services in the
home or hospital were
submitted. The job description
for the administrator of special
education was included with the
documentation. Administrators
meet on a regular basis to
coordinate services within each
building. Each building has a
Child Study Team for
instructional support.
12
Partial
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 54
Professional
development
regarding
special
education
SE 56
Special
education
programs and
services are
evaluated
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Partial
Partial
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The district did not
provide evidence of
training on the
confidentiality of student
records. Although staff
are required to sign a
sheet that they are
familiar with the written
material provided, student
files contained
information for other
students and assessments
were kept in a teacher’s
desk that should have
been in the student
record.
Provide training to review the
requirements for
confidentiality and the student
record regulations with staff at
the beginning of the school
year. Submit evidence of this
training (agenda, handouts and
sign-in sheet with name, role
and signature) by September
30, 2005.
The district did not use
the information gathered
from IEPs, assessment
results, drop out rates and
graduation rates to
determine the
Submit a plan for the next
program evaluation that
includes the use of data from
IEPs, WCAS, MCAS, drop out
rates, and graduation rates for
students receiving special

Documentation
and Interviews
The district offered and
evaluated the workshops during
the 2004-2005 year. Numerous
required topics were provided
including a collaborative
workshop with the PAC on
parent and student rights.
Documentation
and Interviews
The district provided a written
program evaluation for 20032004 designed to examine
staffing of federal projects, outof-district placements,
transition activities and
13
Partial
Partial
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

paraprofessional support
systems.
effectiveness of special
education programs and
services.
education services by
September 30, 2005.
Educational assessments
were not always found in
the record. Some
educational assessments
were incomplete. Not all
Conduct training for all staff
that administers educational
assessments, preschool
assessments and
social/emotional assessments.
Other
Requirements
SE 2
Required &
Optional
Assessments
Partial
Documentation,
Student
Records and
Interviews
Assessments for students were
completed by appropriately
trained and credentialed
specialists. The district
employs school psychologists at
14
Partial
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Partial
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
areas of suspected
disability were assessed,
specifically the area of
emotional impairment.
For a child being assessed
to determine eligibility
for services at age three,
observations in the
natural environment were
not found in the student
records.
The selected option for
age of majority consent
was not consistently
documented on the IEPs
and some records did not
contain a record of the
selected option.
Submit the agendas and signin sheets (date, name, role and
signature). Submit a list of
assessment instruments used
for determining emotional
impairment. Submit
procedures for preschoolers to
be observed in the natural
environment as part of
transition procedures by
September 30, 2005.
Submit a procedure to monitor
student records of eligible
students at age 17 to ensure the
discussion occurred at the
Team meeting and was
documented on the IEP.
Develop and submit
procedures to monitor that the
selected option for consent at
age 18 is documented on the
IEP and the appropriate form
with signatures of the student,

each level to conduct
psychological evaluations.
SE 7
Transfer of
Parental Rights
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Documentation,
Student
Records and
Interviews
Some student records contained
information regarding the
transfer of parental rights.
15
Partial
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

parent and where required the
witness is filed in the student
record by September 30, 2005.
SE 8
Evaluation
Team
Composition
SE 9
Eligibility
Timelines
SE 11
Independent
Educational
Evaluation
Partial
Documentation,
Student
Records and
Interviews

Documentation,
Student
Records and
Interviews

Documentation,
Student
Records and
Interviews
Team meetings regularly
include a representative with
the authority to commit district
resources, parents, guidance
representatives and students
who are 14 years of age or
older.
The district provides
evaluations to determine
eligibility or refers ineligible
students to other programs to
support their instructional
needs.
The district responds to requests
for Independent Educational
Evaluations using state
regulations during the first 16
months and federal regulations
thereafter.
16
Partial
Team meetings did not
always include a regular
education teacher.
Submit procedures for each
building to ensure that regular
education representatives are
included in Team meetings by
September 30, 2005
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
SE 12
Re-evaluation
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Comments Regarding
Corrective Action Plan
Implementation

Partial
Partial
SE 24
Parent Notice
Method(s) of
Verifica-tion
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The district allows
parents to waive services
and removes students
from special education
without considering
whether a reevaluation is
warranted.
Not all reevaluations
were completed within a
three-year timeline.
Submit monitoring procedures
to ensure that reevaluations are
conducted at least every three
years. Submit a Memo to all
special education staff and
related services staff that
parents cannot remove
students from special
education without the district
considering an evaluation by
September 30, 2005.
Submit evidence of training
(agenda, handouts, and sign-in
sheet with name, role and
signature) on how to complete
the notice forms that contain
guiding questions by
September 30, 2005. Submit a
plan for monitoring each
building’s records for the
completion of notice forms
and placement of forms in the
student record by September

Documentation,
Student
Records and
Interviews
The district piloted and is
implementing a Team Process
Checklist to track timelines for
reevaluations.
Documentation,
Student
Records and
Interviews
The district provides parents
with the opportunity to consult
the school psychologist to
discuss the reasons for referral
and the nature of the proposed
evaluation consistently.
17
Partial
Partial
Notice forms were not
always found in the
record for each activity
proposed or refused.
Frequently, the notice
forms did not include the
guiding questions on page
two of the mandated
form. The notices
frequently were not
individualized.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Comments Regarding
Corrective Action Plan
Implementation

Partial
Some records indicated that the
district obtained consent for
services before initiating the
services.

Documentation,
Student
Records and
Interviews
Partial
Documentation
and Interviews
The district routinely provided
parents with notice of a Team
meeting that included the
purpose, time and location of
the meeting as well as who was
to be in attendance.
The age span requirements were
met for sub-separate classes in
the high school, Minot and
East.
SE 27
Team meeting
Notice
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

Documentation,
Student
Records and
Interviews
SE 25
Parent Consent
SE 41
Age Span
Method(s) of
Verifica-tion
18
Partial
Not all student records
reviewed contained the
consent for evaluation
form. Not all evaluations
that a parent consented to
were provided.
Partial
The age span was
exceeded in the Decas
Elementary School
adjustment class. An
approved waiver was not
submitted.
30, 2005.
Submit a monitoring plan for
evaluations to ensure that all
evaluations consented to were
provided, that evaluations
were completed within 30
school working days from the
date consent was received by
the district and that consent
forms are placed in the student
record by September 30, 2005.
Submit procedures for when
and how to request an age span
waiver from the Department of
Education by September 30,
2005.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Comments Regarding
Corrective Action Plan
Implementation

Documentation,
Student
Records and
Interviews
The district provides the full
array of related services.

Documentation
and Interviews
The district assisted staff
through professional
development plans to secure
and update licenses.

Documentation
and Interviews
The district does not allow
paraprofessionals to design
instruction and has provided
extensive professional
development in order to meet
SE 52
Licensure
Related
Services
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

Partial
SE 49
Related
Services
SE 53
Paraprofessionals
Method(s) of
Verifica-tion
19
Partial
The student records and
staff interviews indicated
that counseling at the
middle school is provided
as a regular education
service delivered by a
guidance counselor, a
social worker and a
school psychologist.
Review of student records
indicated that only one
IEP had counseling on the
service delivery grid.
Submit a self-study of
counseling needs and train
Team chairs to address
individual counseling needs
that should be represented on
the service delivery grid by
September 30, 2005.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The district did not
provide any signed
statements of assurance
from prospective
employers of students
stating that the employer
will not discriminate
based on sex, race, color,
ethnicity, sexual
orientation, religion or
disability.
Develop and submit sample
statements for any prospective
employer to sign by July 6,
2005.

the highly qualified standard for
Title I and NCLB.
MOA 9
Employment
Practices of
Prospective
Employers of
Students

Documentation
and Interviews
20
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Submit a copy of handbooks
(student and faculty) for all
buildings and samples of other
publications that contain the
complete nondiscrimination
statement and the listing of
coordinators for Title IX and
Section 504 with contact
information by September 30,
2005.
See MOA 12 A above.

New MOA 12A
MOA 10
Notice Nondiscrimination
Partial
Documentation,
Student
Records and
Interviews
Some of the published nondiscrimination statements
contain required elements.
Partial
Published notices did not
include the names, office
addresses and phone
numbers of the Title IX
and Section 504
coordinators.
New MOA 12A
MOA 11
Nondiscrimination
Statement
New MOA 11A
MOA 12
Grievance
Procedures
Partial
Documentation,
Student
Records and
Interviews
Some of the published nondiscrimination statements
contain required elements.
Partial
The high school
handbook does not
include color or national
origin.

The high school
handbook published
complaint procedures for
harassment under sexual
harassment. There were
no grievance procedures
for discrimination based
on sex or disability. The
Documentation
and Interviews
21
Submit handbooks with
procedures for all complaints
of harassment and
discrimination and the correct
contact information for
persons to manage the
complaints by September 30,
2005.
Criterion
Number
and
Topic
(Refer to full
text of
requirements
in 2004-2005
Special
Education
Information
Package)
New MOA 10A
MOA 17
Code of
Conduct
MOA 22
Access
Mobility
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substan-tially
Implemented
Method(s) of
Verifica-tion
Comments Regarding
Corrective Action Plan
Implementation

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting

Partial
Documentation
and Interviews
Some handbooks have
appropriate information
regarding code of conduct.

Documentation
and Interviews
The middle school was
reconstructed and is fully
accessible.
Partial
22
contacts noted in this
year’s high school
handbook both retired last
year.
Several handbooks were
missing procedures for
the investigation and
resolution of complaints
regarding discrimination.
The section on discipline
for students with special
needs is not complete.
The code of conduct does
not reference M.G.L. c.
76, s 5.
Submit all faculty and student
handbooks with current
information for codes of
conduct by September 30,
2005.
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