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 July 20, 2005 Dr. James A. Caradonio Superintendent of Schools Worcester Public Schools 20 Irving Street Worcester, MA. 01609 Re: Onsite Follow-up Monitoring Report: Coordinated Program Review Corrective Action Plan Verification and Special Education Mid-cycle Review Dear Superintendent Caradonio: 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 26, 2002. While the Department of Education found certain noncompliance issues to be resolved, others were partially corrected, not addressed at all and/or new issues were identified by the Department’s onsite team. 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 August 17, 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 781-338-3731. Sincerely, Donna Feinberg, 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 Mayor Timothy P. Murray, School Committee Chairperson Sherrill McKeon, District Program Review Follow-up Coordinator Encl.: Follow-up Monitoring Report 3 MASSACHUSETTS DEPARTMENT OF EDUCATION COORDINATED PROGRAM REVIEW Worcester Public Schools ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Action Plan Submitted on 12/6/02 Progress Reports Submitted on 7/1/03 Onsite Visit Conducted on 4/11-14/2005 Date of this Report July 20, 2005 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented 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 evaluation consent form does not always identify the specific type of assessment(s) to be provided. General terms are used such as inclusion testing, LD testing and TMSN testing to refer to proposed assessments. In some cases, the Student Support Team initially selects Submit the revised process for the selection of assessments for initial evaluations. Provide evidence of the dissemination of the above procedures to Team Chairpersons, principals and Student Support Teams system-wide. Submit evidence of training provided to regular education staff system-wide regarding the appropriate completion Special Education Requirements SE 1/SE 2 Assessments Partial Student Records Interviews The district has developed a manual for Team Chairs that outlines the procedures for initial and reevaluation assessments. The district has bilingual and bicultural school psychologists to provide evaluations and Partial Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented 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 interpretation for parents, students and staff. assessments, rather than the Special Education Department. of the teacher assessment forms. IEP Teams use information from the Student Support Teams, observations, students’ current teachers, parents and formal assessments to determine the best services and placement for eligible students in the least restrictive environment In addition, initial evaluations do not always address the full spectrum of a student’s presenting issues. The district is in process of revamping procedures to ensure that clinicians are responsible for the selection of assessments after the student is referred for a special education evaluation. Provide a description of the monitoring process regarding the completion of the teacher assessment forms for initial evaluations and reevaluations -Submit a plan for provision of the necessary updated information regarding the primary language of parents/guardians. -Submit a revised evaluation consent form for requesting completed assessments in the primary language of the parents/guardians. Above due by November 18, 2005. The district has established an assessment subcommittee to focus on developing guidelines for the selection of assessments. Regular education teacher assessments do not always include specific and sufficient information regarding the student’s current performance level, progress and presenting issues. 3 Submit the following by 3/20/06: 1.Completed teacher assessment forms from each quadrant, including two from each level, elementarymiddle -high school , and the alternative and vocational schools. 2. Six proposed Evaluation Consent Forms for initial evaluations from each quadrant, including a sampling from the elementary, middle and high school levels. Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance The district has a statement on the Evaluation Consent Form where the parent/guardian documents the option to receive the completed assessments two days prior to the Team meeting. However, the statement is only in Spanish. In addition, there is not a process in place for the special education department to know, upon referral of a student, the primary language for the purposes of translation assistance for parents/guardians. SE 3 Special Requirements for Determination of Specific Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Student Records Document s Documentation and student records showed that the IEP Teams complete the required observation and provide a written statement to document the Team’s determination regarding the The review of student records showed that the written statement is not always completed. The determination of the specific learning disability form does not always provide written justification of 4 3. Results of an administrative review of the appropriate completion of Teacher Assessments and Evaluation Consent Forms system-wide. Indicate the # of records reviewed by quadrant, the # of records with the above completed forms and indicate any further steps taken by the district to address incomplete record information. Above due by March 20, 2006. On-site student record review will be scheduled for August 2006. Statutory requirements for the determination of specific learning disabilities have been revised under the recently reauthorized IDEA 2004. Therefore, until final implementing regulations have been adopted, the Department is not making findings Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Learning Disabilities existence of a specific learning disability. Partial 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 Team’s determination. In addition, this information is not always linked to the Team member’s written findings regarding the required observation of the student and the assessment results. related to school district practices under Coordinated Program Review Criterion SE 3. For districts seeking to resolve a previous finding in this area, the Department will extend the date required for final actions on the part of the school district to June 2006 and will consider resolution at any time following promulgation of final federal regulations. SE 4 Reports of Assessment Results Correctiv e Action Plan Student Records The completed assessments for initial and re-evaluations at the preschool and elementary levels, in most cases, include the required information regarding procedures employed, the results, the diagnostic impressions, student’s behavior, student’s educational/therapeutic needs and educationally relevant findings and recommendations. Partial At the secondary level, in many cases, there is limited inclusion of educationally relevant findings and recommendations in completed assessments. A high number of assessments only cite scores attained and a description of the tests. The district must conduct training with Team Chairpersons, and key special education and related service personnel responsible for evaluations, regarding the inclusion of educationally relevant findings and recommendations in assessment reports. Submit the agenda, handouts and signed attendance sheet from the training, by November 18, 2005. Submit the results of a sample of student records drawn from each quadrant regarding the completion of assessments (indicate the # of records reviewed from each quadrant, the # of records with appropriately completed assessments and indicate any further steps taken by the district to address assessment information, by March 20, 2006. Completed assessments are available to parents at least 5 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented 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 two days in advance of the Team meeting. On-site student record review will be scheduled for August 2006. 6 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented SE 6 Determination of Transition Services (Emphasis on practices in determining needed transition planning and services and Student Records Document s Interviews consideration of courses of study related to needed transition) SE 7 Correctiv e Action Plan Student Records The district has a wide range of program options available to secondary students, to promote awareness, exploration and direct involvement in occupational and vocational pursuits that are based upon the individual student’s needs and interests. IEP Teams consistently incorporate transition planning and participation in career pathways and relevant courses of study into the development of the IEP. The district offers vocational training, community-based, supported and summer employment, career pathways, community service and community college programs. IEP Teams implement Chapter 688 referrals for students, when appropriate. The district implements the requirements regarding the 7 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Age of Majority Correctiv e Action Plan Document s transfer of parental rights at the age of majority and the securing of student consent to determine person(s) who have decision-making authority. 8 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Evaluation Team Composition Partial 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 SE 8 Correctiv e Action Plan Student Records IEP Team meetings at the preschool, elementary and middle school levels regularly include the required Team members, with a representative of the district present to commit the district’s resources. At the high school level, students, age fourteen and older and representatives from adult human service agencies participate at Team meetings and in the IEP process. There is a high level of participation of parents at IEP meetings from the preschool to the high school level. Partial Regular education teachers at the high school level and vocational teachers at the vocational school do not regularly attend IEP Team meetings. In addition, regular education teachers are not always aware of their responsibility to participate in the Team meeting process. Submit a plan to ensure: -High School regular education teacher participation in Team meetings, for the discussion regarding student’s participation in the general curriculum and necessary accommodations. -Vocational teacher participation in Team meetings for the discussion regarding the student’s participation in the vocational/technical curriculum and necessary accommodations. Submit evidence of training provided to regular education personnel and vocational personnel regarding the requirements for Team participation. Above due by November 18, 2005 Provide the results of the review of a sample of Team meeting attendance sheets at the high school level and at the vocational school. Indicate the # of Team meeting attendance sheets 9 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e 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 reviewed, by quadrant, the # of Team meetings where a regular education teacher at the high school or a vocational teacher at the vocational school participated, and indicate any further steps taken by the district to address inconsistent regular education or vocational teacher attendance. Above due by March 20, 2006. On-site student record review will be scheduled for August 2006. 10 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Student Records The district regularly adheres to the mandated 45-day timeline for the conducting of evaluations, convening of Team meetings and the provision of the proposed IEP and placement. Referrals to special education are immediately placed into a database where the special education administration and Team Chairpersons track and monitor the IEP process and adherence to the mandated timelines. Student Records In most cases, progress reports are documented in the student records and sent to parents/guardians consistent with the report card cycle. Eligibility Determination SE 13 Progress Reports and Content Partial 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 progress reports do not always address the student’s individual IEP goals and benchmarks and do not always respond to the required question regarding the student’s expected progress towards achievement of the annual IEP goals. The district must provide training to special education personnel on the content of progress reports, to ensure greater consistency in addressing student’s IEP goals and benchmarks. Submit agenda and signed attendance sheets from the training, by November 18, 2005 SE 9 Correctiv e Action Plan Partial 11 Submit the results of an administrative review of a sample of progress reports from each quadrant for appropriate content (indicate the # of records, the # of Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e 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 records with appropriate reporting of content and indicate any further steps taken by the district to address progress reports lacking appropriate content) by March 20, 2006. On-site student record review will be scheduled for August 2006. 12 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented SE 17 Initiation of Services at Age Three and Early Intervention Transition Procedures Partial 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 SE 15 Outreach by the School District (Child Find) Correctiv e Action Plan Document s The district implements city wide K-12 child find and various outreach efforts to private and parochial schools and community organizations and agencies to identify students in need of special education. Student Records The district meets with Early Intervention teams on a quarterly basis throughout the year. Procedures are in place to implement transitions of children from the Early Intervention programs. The district, upon receipt of referral and parent consent, provides an evaluation, conducts a Team meeting, develops an IEP and determines placement for children transitioning from Early Intervention programs. Document s Interviews Partial The 45-day timeline for the provision of an initial evaluation, conducting of a Team meeting and the proposal of an IEP and placement does not always occur in sufficient time to ensure the implementation of the proposed services and program upon the eligible child’s third birthday. Submit revised procedures regarding the referral process and timeline for implementation of procedures for children transitioning from Early Intervention programs. Above due by November 18, 2005. Provide the results of an administrative review, from each quadrant, regarding the implementation of services and programs for eligible children transitioning from Early Intervention programs by the date of the child’s third birthday, from October 2005February 2006. On-site student record review will be scheduled for August 2006. 13 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented 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 Indicate the # of records and the # of records with services and programs begun by the child’s third birthday. Indicate any further steps taken by the district to address issues regarding compliance with the initiation of services. Above due by March 20, 2006. On-site student record review will be scheduled for August 2006. SE 18A IEP Developmen t and Content Partial Student Records Interviews The district implements the mandated IEP procedures system-wide regarding the development of the IEP, and considers all areas on the current IEP format. The district has adopted a web-based IEP system and is actively working on Partial 14 Goals and objectives on IEPs, are not always written in measurable terms, specific to the student’s disability and need for specialized instruction. The IEP Team does not always fully describe the reasons why the student is being removed from the general education Submit the agendas, handout material and signed attendance sheets from staff training regarding the development of measureable annual IEP goals and the nonparticipation justification Above due November 18, 2005. Provide the results of an Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented 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 program. IEPs from the alternative school do not include academic goals, and IEPs from the vocational school do not contain vocational goals, when appropriate and necessary. Individualized goals are not always included for students with social-emotional and behavioral needs. administrative review of proposed IEPs, K-12 by quadrant, including the alternative and vocational programs. (indicate the # of IEPs reviewed, the # of IEPs with annual measureable goals, specific to the student’s academic/vocational and therapeutic need for specialized instruction, and # of IEPs with detailed nonparticipation justifications.) Indicate any further steps taken by the district to address incomplete development of goals and insufficient nonparticipation justification for the2005-06 school year. Above due by March 20, 2006. increasing the training provided to special education and related service staff regarding the development of annual IEP goals. The district has established a regular meeting schedule for elementary special education staff and is currently planning a schedule for secondary special education staff in the 2005-06 school year to address system-wide issues. On-site student record review will be scheduled for August 2006. 15 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented SE 18B Student Records The district implements the required procedures to determine placement at initial/reevaluations and annual review meetings. Partial Student Records The district considers the least restrictive environment and opportunities for inclusion for students through Team discussion at IEP meetings. The district submitted a description of the wide range of services and programs offered to students to promote inclusionary experiences and placement in the learning environment best suited to the student’s academic and therapeutic need for instruction and intervention. of Placement; Immediate Provision of IEP to Parent SE 20 Least Restrictive Program Selected 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 student records and interviews showed a lack of adequate supports for students placed at the vocational school to allow full and equal access to the vocational/technical curriculum. The district and the vocational staff must conduct a review of students on IEPs and 504s, placed at the vocational school for the 2005-06 school year, to determine the appropriate supports required to ensure full access and support in the vocational/technical curriculum. Submit a copy of the review, indicating the name of the student, the student’s vocational shop(s) and the types of supports/accommodations being provided to the student. Above due by November 18, 2005. Determination Correctiv e Action Plan Interviews Partial On-site student record review will be scheduled for August 2006. 16 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) SE 22 IEP Implementation and Availability (Emphasis on provision of IEP services without delay; provision of the IEP at the beginning of the school year; and, alternative methods of service delivery where there is a lack of space and/or personnel)) SE 24 Notice to Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Partial 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 Student Records Interviews Partial Correctiv e Action Plan Student Records The district has a system in place to ensure the implementation of a student’s services and program upon receipt of written parental consent. The building principal is responsible for the oversight of the provision of the services and program at the building level. The principal and the ETL review students’ IEPs quarterly, regarding the ongoing provision of appropriate services and programs. When there is an interruption of service due to a lack of personnel and/or space, the district implements the required regulatory procedures to notify parents and provide an alternative plan to deliver services. Partial The district provides the mandated written notices to parents regarding the Partial Regular education teachers, especially at the high school level, are not always informed of their specific responsibilities regarding a student’s IEP goals, services and accommodations, or Section 504 plan. There is not always effective oversight at the high school level regarding the ongoing implementation of the student’s agreed to IEP within the general education curriculum. Submit a plan to ensure that general education teachers are informed of their responsibilities regarding students’ IEPs or Section 504 plans at the beginning of the school year. Submit a plan to ensure oversight at the building- level and at the administrative level regarding the ongoing implementation of students’ goals and accommodation s on IEPs or Section 504 plans within the general education classroom. Above due by November 18, 2005. Submit an administrative review regarding the implementation of the district’s above plan by quadrant and indicate any further steps taken by the district to address issues regarding the ongoing monitoring and implementation of students’ IEPs or 504 Plans. Above due by March 20, 2006. 17 The student record review indicated that the N1/N2 notices do not always sufficiently The district must provide training to chairpersons and key special education personnel regarding the appropriate completion of the written Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented 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 /Guardian Correctiv e Action Plan Document s district’s proposal or refusal to act in regards to the identification, evaluation or educational services/ placement of the child. address the required questions. Team meeting notices are inconsistently documented in the student records. Team meeting notices do not always indicate the purpose of the Team meeting. notice(N1/N2 form). Submit agenda and signed attendance sheet from training. Submit a plan regarding the consistent documentation of Team meeting notices in the student records. Provide evidence of dissemination of the plan to Team Chairpersons. Above due by November 18, 2005. Submit the results of an administrative review of a sample of students’ IEPs from each quadrant for appropriate completion of written notices and inclusion in student records. Indicate the # of records, the # of records with appropriate completion of the written notices, in student records, and indicate any further steps taken by the district to address notices lacking appropriate content and inconsistent inclusion in student records. Above due by March 20, 2006. On-site student record review will be scheduled for August 2006. 18 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented 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 Correctiv e Action Plan Student Records Document s Student Records Interviews The district has a high level of participation of parents at IEP meetings. The Team meeting invitations are typically sent out to parents/guardians in sufficient time to provide parents with the opportunity to attend. The personnel reschedule meetings and make multiple attempts to accommodate parents in order to encourage parents’/guardians’ attendance at the Team meetings. Team Chairpersons typically document the efforts made to facilitate parent participation/ attendance at the Team meetings. The district provides the proposed IEP and placement, or the finding of no eligibility, within the mandated timelines. 19 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Eligibility together with Notification of Procedural Safeguards and parents' rights Correctiv e Action Plan In addition, parents/guardians are provided with notification of procedural safeguards and parents’ rights. 20 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented SE 32 Parent Advisory Council for Special Education SE 37 Student Records Document s Partial Document s Interviews Partial 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 PAC meeting announcements are not translated into languages other than English for parents who require translation into the primary language of the home. The district indicated that there is a plan in place to translate the PAC materials and meeting announcements into the major languages of the district. Submit a plan to provide translated documents regarding Parent Advisory Council information and activities, throughout the school year, to parents/guardians who require documents translated into the primary language of the home, by November 18, 2005. The student records do not show Submit a plan to provide ongoing SE 29 Communications are in English and Primary Language of Home Correctiv e Action Plan Student The district provides interpreters and translated materials relevant to the IEP process and procedures when requested and necessary for parents/guardians whose primary language is other than English. The district’s efforts are documented in the student records. The district has a wellestablished Parent Advisory Group that meets regularly on the second Wednesday of the month. Contact information regarding the cochairpersons, the by-laws, a schedule of meetings and agendas were submitted. In addition, the PAC has representation at School Committee meetings. Partial The district implements the Partial 21 Submit the PAC materials and announcements that were translated for parents/guardians in the 2005-06 school year, by March 20, 2006. Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented 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 Procedures for Approved and Unapproved Out-ofDistrict Placements Correctiv e Action Plan Records Interviews mandated IEP process and procedures for students placed in out-of-district programs. evidence of the on-going monitoring of students in outof-district placements. Document s monitoring of students in out-ofdistrict placements. Indicate the key personnel responsible for the oversight, monitoring and documentation of the students’ IEPs and placement. Above due by November 18, 2005. Submit the results of an administrative review of student records for students placed in out-of-district programs for the 2005-06 school year. Indicate the # of records reviewed and the # of records with completed monitoring reports. Indicate any further steps taken by the district to address incomplete or inconsistent documentation of monitoring, by March 20, 2006. On-site student record review will be scheduled for August 2006. 22 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Partial 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 life skills programs and resource rooms at the secondary level do not always adhere to the age span requirements. Submit classroom rosters for students in life skills programs and resource rooms at the high school level for the 2005-06 school year, by November 18, 2005. SE 41 Age Span Correctiv e Action Plan Document s Requirements Interviews The district adheres to the age span requirements within instructional classes and programs at the elementary and middle school levels. Partial Submit the classroom rosters for the above classes or programs if there have been any changes in the population of students since the fall submission of the roster. Due by March 20, 2006. SE 42 Programs for Young Children Three and Four Years of Age Document s The district adheres to the general requirements regarding the age span of the children, teacher-child ratios and instructional grouping size for its early childhood programs. SE 44 Procedures for Recording Suspensions Document s The district appropriately records and tracks in-school and out-of-school suspensions through the SAGE database. Interviews Student 23 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Records 24 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Partial 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 When a student is close to reaching the 10-day suspension mark, the Team Chairpersons convene a meeting and propose an IEP Amendment that states what will occur in regard to tutoring for the student when the suspensions exceed 10 days. The above practice is predetermining what will occur and what will be the outcome of the manifestation determination if and when the student’s suspensions exceed 10 days. In addition, the IEP Amendments propose a set amount of tutoring for students when their suspensions exceed 10 days. Submit revised procedures regarding the implementation of a full manifestation determination prior to any suspensions beyond ten days, and implementation of additional suspensions and tutoring only if the behavior is not a manifestation of the disability. Include consideration of an IEP Amendment to increase supports, instead of suspension, when supports have not been adequate to address behaviors, and the consideration of the required amount of tutoring (to ensure provision of IEP services and progress in the general curriculum) only when the behavior is not a manifestation and will result in suspension beyond ten days. Include the key personnel who will be responsible for monitoring compliance with the federal requirements for the above procedures. Submit evidence that Team Chairpersons have been informed of the revised procedures. Above due by November 18, 2005. SE 46 Procedures for Suspension of Students with Disabilities when Suspensions Exceed 10 Days Correctiv e Action Plan Student Records Interviews The district implements the required procedures regarding the convening of a manifestation determination meeting and the review of a Functional Behavioral Assessment for students with disabilities whose suspensions have exceeded 10 consecutive days or accumulated to 10 days or over. Partial On-site student record review will be scheduled for August 2006. 25 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 26 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Partial Student Records Interviews Document s SE 49A Special 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 Interviews indicated that counseling is a service provided at the vocational school. However, students’ IEPs at the vocational high school do not always document that the student is being provided with counseling services. The district must conduct a review of the IEPs for students at the vocational school who are receiving counseling services. In those cases where students’ IEPs do not reflect counseling services, delivered in or out of the classroom , the IEP Team should review the existing service delivery grid to see if it adequately reflects services being provided. Submit the results of the review and indicate the # of IEPs which were amended. Include a copy of amended service delivery grid, proposed goal(s) signed Team meeting attendance sheet and written notice(N1) accompanying the proposed IEP Amendment for each student, by November 18, 2005. SE 49 Related Services Correctiv e Action Plan Student Records Transportation Document s The district submitted a list regarding the range of related services offered and the personnel responsible for the provision of the services. This included personnel responsible for the provision of in-school counseling services. Partial The district adheres to the state regulations and federal requirements regarding the provision of special transportation to students who require special transport as determined by the IEP Team. The district provides 27 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented in-service training to transportation providers regarding the needs of students being transported in special transportation vehicles. 28 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Partial Responsibility Student Records of the School Principal and Document s Administrator of Special Education 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 SE 50 Correctiv e Action Plan Interviews The district revamped the building-based Student (SSP) Support Process in the 200405 school year. Principals received training in the implementation of the SSP procedures in OctoberNovember 2004. Partial The district has designated a Department Head for Home/Hospital who is responsible for the implementation of the requirements upon receipt of a phone call or E-mail from a principal, the student’s eligibility for home-hospital services, the documentation and monitoring of physicians’ orders and the provision of the necessary amount of tutoring services. 29 The student record review showed that the building –based participants in the former Student Support Team Process did not always refer students for a special education evaluation upon written and/or oral parental request. The practice of the former SST, in a number of cases, was to gather information and assess students regarding eligibility for a disability and special education services under the SST process, rather than refer students for a comprehensive special education evaluation. The Department’s review of the SSP procedures indicates that under Section D, step # 4 for the second or subsequent SSP meeting, the SSP Team may request formal assessment if there are continuing concerns regarding a student’s performance and/or progress in particular area(s). Form G, used to document the Submit the revised procedures and Form G, including notice to parents/guardians regarding the right to refer the student for a special education evaluation and the deletion of psychological assessment from the list of optional assessments. Submit evidence that the principals and key personnel participating in the Student Support Process have been informed of the change in procedures and the revised Form G. Above due by November 18, 2005. Submit an administrative review of the revamped SSP building-based procedures for the 05-06 school year. Provide the following information by building from Nov.2005-Feb.2006: (1)# of students referred by parents for special education evaluation, include date of referral. (2) # of parents who chose to postpone referral for a special education evaluation On-site student record review will be scheduled for August 2006. Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e 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 SSP Team’s request and the parent’s consent to an assessment, must be revised to be consistent with federal and state requirements. At this juncture, the parents/guardians need to be informed of their due process rights to refer the student for a special education evaluation, if desired. The district Form G’s list of assessments includes a psychological assessment,that inherently addresses different areas of suspected disability. The psychological assessment needs to be part of a comprehensive initial evaluation for special education eligibility. The district must revise Form G to include information regarding the parents’ right to refer for a special education evaluation and to eliminate psychological as an optional assessment under the SSP procedures 30 (3) # of parents who chose to continue to referral process for special education evaluation and the date of the written notice(N1) proposing the school district’s action was sent to each individual parent/guardian. Above due by March 20, 2006. Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented SE 55 Special Education Facilities and Classrooms Partial 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 Life Skills programs at the Doherty High Schools and South High Community School need to be reviewed regarding full accessibility to the life of the school, opportunities for integration, and comparability Submit the results of the review regarding the Life Skills programs, the level of accessibility and integration into the school’s programs, and the comparability of the instructional spaces to that provided in regular education classrooms. Indicate SE 54 Professional Developmen t regarding Special Education Correctiv e Action Plan Document s The district has a wide variety of professional development offerings regarding curriculum, differentiated instruction and special education, for regular, special education and paraprofessional staff. The district solicits input from teaching personnel and the special education department works in conjunction with the office of Staff Development and Curriculum to create and develop training and inservice opportunities throughout the school year and the summer. On-site The special education spaces at the Forest Grove and Sullivan Middle Schools and the Burncoat High School are currently complying with the requirements regarding comparability and verification Partial 31 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented accessibility. MOA 23 Comparability of Facilities and Programs Partial Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting SE 56 Special Education Programs and Services are Evaluated Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Interviews Document s The district initiates the evaluation of special education programs and services on a regular basis, utilizing a variety of approaches, collaboration with regular education personnel and administration, self-study, and independent evaluators. The district is in the process of evaluating programming in the areas of vision, occupational and physical therapy. In addition, the life skills programs K-12 are involved in evaluating curriculum planning and students’ Partial 32 of spaces regarding instructional usage. In addition, the district must assess the use of the lower level entry -way for students in the Life Skills program at the South High Community School, rather than the entry way utilized by the majority of the student population. changes made to the location of the program/instructional spaces and/or daily program schedule. Above due by November 18, 2005. The district demonstrates oversight and monitoring of its special education programs and services. However, interviews and student record reviews indicated that Team Chairpersons have high caseloads and numerous and varied responsibilities connected to the individual students in their caseload that do not always allow for effective oversight and monitoring regarding the ongoing implementation of the agreed to services on students’ IEPs. Submit the results of a review regarding the caseloads of the Team Chairpersons. Include an evaluation of the responsibilities of each Chairperson for the 2005-06 school year, considering the number of students in each caseload, the level of need of the students, the types of services and programs that the students are receiving, the program placements, the number of assessments being tracked. Indicate any changes regarding the restructuring of the Team Chairpersons’ caseload and/or responsibilities that resulted from the district’s review. Above due by March 20, 2006. Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented transition to the community. The special education administration is currently working with quadrant managers, principals and behavioral specialists to evaluate the possible reorganization of systemwide behavioral programs. 33 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance A comprehensive evaluation of the district’s assistive technology resources, services and program was submitted from August 2004. The district works closely with the special education administration, quadrant and building based administrative personnel and school-based special education and regular education department heads to review and analyze the improvement of student performance and the maximization of teaching and teacher quality. Other Requirements MOA 3 MOA 22 Accessibility Interviews Student The district submitted the vocational school status reports from the Department However, See findings under SE 49, above. 34 Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented of District Programs and Services Correctiv e Action Plan Records Document s of Code Enforcement that indicate compliance with ADA accessibility guidelines and a projected date regarding the opening of the vocational school in Fall 2006. Interviews indicated that IEP Teams consider the needs of individual students with disabilities, who are enrolled in the vocational school, regarding accessibility to programs and to classroom and shop spaces and the appropriate accommodations to be implemented to ensure access to the full complement of the school’s program and services. 35 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented MOA 5 Placement of Disabled Students in Occupationa l/ Vocational Education Programs MOA 9 Hiring and Employment Practices of Prospective Employers of Students Document s The Cooperative Education Coordinator qualifies all employers that provide cooperative employment opportunities and positions to students. A sample of the employer statement was submitted. MOA 10A Handbooks and Codes of Conduct Document s Student or district handbooks contain the required nondiscrimination policy MOA 11A Document In the beginning of the new Interviews Student Records Refer to MOA 3 and comments regarding the implementation of the corrective action. Document s 36 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Designation of Liaison/ Coordinators Grievance Procedures Correctiv e Action Plan s school year, building-based administrative personnel review the policies and procedures and the personnel designated to respond to grievances under Section 504 and Title IX and Title 11. 37 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented MOA 16 Notice to Students 16 or Over Leaving School Document s The district submitted copies of completed notices and letters sent to parents and students regarding the student’s right to return to school and the options available for continuing their education. A brochure listing the programs available to student who reside in Worcester and are 16-21 years of age was submitted in conjunction with descriptions of the available alternative education programs. MOA 21 Staff Training regarding Civil Rights Document s In the beginning of the new school year, building-based administrative personnel review civil rights policies and procedures and the code of conduct with buildingbased staff. Interviews Reading, writing, speaking and listening skills of all Responsibilities ELE 1 Annual Correctiv e Action Plan 38 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Assessment Document s Student Records ELE 2 MCAS Correctiv e Action Plan Interviews Document s Student Records limited English proficient students are annually assessed using MEPA and MELA-O, by qualified raters. Limited English proficient students participate in the annual administration of the MCAS and are provided with word-to-word bilingual dictionaries. 39 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Partial 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 Interviews indicated that at the secondary level, parents are not always given home language surveys to complete. In some cases, only parents who require a translator are given surveys. In addition, students are sometimes placed in the bilingual Spanish program or an SEI classroom without being provided with the initial language proficiency assessment. The student record review showed evidence that not all limited English proficient students at the elementary and secondary levels had been properly identified and subsequently assessed to determine the need for English language support. Submit a detailed plan and protocol for the provision of home language surveys to all parents upon enrollment of students, for the initial identification and assessment of students whose home language is other than English, and for the oversight and monitoring of the process and procedures. Include the procedures to be implemented at the Parent Information Center and at each quadrant secondary school. Designate the personnel to be responsible for the identification and assessment of students at each site and the personnel responsible for the oversight and monitoring. Submit evidence that key personnel have been provided with the plan and protocol for the implementation of the requirements at their site. ELE 3 Initial Identificatio n Correctiv e Action Plan Interviews Document s Student Records Documentation shows that students, preschool-grade 6, enroll at the Parent Information Center. Parents complete the home language surveys and students are assessed for English language proficiency if the home language is other than English. Students in grades 7-12 register at the secondary school in their quadrant. Parents complete the home language survey and students are assessed for English language proficiency if the home language is other than English. Partial Above Due by November 18, 2005 Submit the results of the review of the home language surveys completed at the beginning of the 2005-06 school 40 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e 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 year from the Parent Information Center and from the quadrant secondary school sites regarding compliance with the requirements for initial identification and assessment. Due by Nov 18, 2005 The building-based administration must determine whether parents whose students were enrolled prior to the 2005-06 school year, have completed home language surveys. If there is not a home language survey in the student record, the school must ensure that a home language survey is completed and, if necessary, the students are assessed for English language proficiency. Submit the results from each building: # of families completing surveys and # of students assessed for English language proficiency. Above due by November 18, 2005. 41 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented 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 currently does not offer limited English proficient students whose language is other than Spanish and Vietnamese the opportunity to apply for waivers for enrollment in a bilingual or other type of language support program. Submit waiver letters and forms translated and provided to all families of non-Hispanic limited English proficient students. Submit a list of students at each school, for whom waivers have been granted and the type of language support program that has been developed to meet the students’ educational need for an alternative program. Interviews ELE 4 Waiver Procedures Correctiv e Action Plan Document s Student Records Under a consent decree, the district provides a transitional bilingual program to its Spanishspeaking students without requiring a signed waiver. That program was not examined under this criterion. Above due by November 18, 2005. ELE 5 Program Placement and Structure Partial Interviews Document s Student The district offers a wide spectrum of services and programs for limited English proficient students, including TBE programs, SEI classrooms, in-class support Partial 42 Not all limited English proficient students are being adequately served regarding the provision of appropriate and necessary English language instruction, to ensure full and Submit the results of a quadrant-based review regarding the provision of ESL instruction to limited English proficient students who are mainstreamed in general education classes for the 2005-06 school year. Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Records by native language aides and pull-out language instruction by ESL teachers. All the district’s teachers have been trained in the provision of sheltered English instruction. The district offers a transitional bilingual program for its Spanishspeaking students. The district is to be commended for its implementation of the Newcomer program. Interviews Documentation shows that the teachers of the English language learners review their students in the spring of each school year to determine the individual student’s readiness for transitioning into a general Modifications and Support Services for Limited English Proficient Students ELE 6 Program Exit and Readiness Partial 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 continued access to the general curriculum, through either additional tutorial support and/or additional ESL classes. In addition, limited English proficient enrolled at the vocational school, do not have access to safety manuals translated into the student’s primary language of instruction, when necessary and appropriate. There is not a system in place to track students mainstreamed in the general curriculum who are in need of increased academic support through additional ESL instruction. Include students placed in the vocational school and alternative programs within the review. Provide the criteria used to determine the student’s need for continuing English language instruction, the # of students receiving ESL instruction in each school and the # of qualified personnel providing the ESL instruction for each school. Submit a plan to ensure ongoing monitoring regarding the provision of English language instruction to limited English proficient students, when necessary and appropriate. Include a description of the types of ESL services being provided in the 2005-06 school year. Above due by November 18, 2005. The district has not established formal criteria system-wide for exiting students form ELL programs. The student record review showed students scoring fluent in English in the MELA-O and LAS-R/W with no indication The district must develop written guidelines and program exit criteria to determine that students K-12 are ready to be designated as Formerly Limited English Proficient(FLEP). Submit the written guidelines, program exit criteria and forms to be used to re-designate a student from MOA 2 Program Correctiv e Action Plan Student Records Partial 43 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e Action Plan Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented 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 education classroom. The teachers review the student’s classroom work and standardized test scores. regarding the provision of English language instruction in the file. The above student files did not have clear evidence of the student being exited, the transition meeting and the criteria used to exit the student. 44 Limited English Proficient(LEP) to Formerly English Proficient(FLEP). Submit evidence that principals, TBE and ELE teachers have received the above guidelines and criteria. Indicate the personnel responsible for the oversight and monitoring regarding the ongoing implementation and the manner to be used to track the re-designation of students. Above due by November 18, 2005. Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented ELE 7 Parent Involvement Correctiv e Action Plan Interviews Document s The district is to be commended for its system of involving the parents of limited English proficient students in the education of their children. The district, through the use of parent liaisons, has developed a network of involved LEP parents who participate in extensive outreach efforts, to encourage the involvement of new LEP parents entering the system. This practice has provided an effective means for all parents of LEP students to have ongoing involvement in matters affecting their children’s education. 45 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented ELE 8 Declining Entry to a Program ELE 9 Instructional Grouping Interviews Document s Correctiv e Action Plan Interviews Student Records The district has committed extensive resources to ensure that a high number of its staff is trained in sheltering content. There appears to be adequate support available for students whose parents have opted-out of ELE programs. The district indicated that if those students failed to perform up to classroom standards, the teacher would promptly meet with the parent to discuss the parent’s decision to decline the student’s participation in an ELE program. Interviews indicated that all teachers in the district have been trained in providing sheltered instruction. Students are grouped in ageappropriate classrooms. 46 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Partial 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 ELE 10 Parental Notification Correctiv e Action Plan Interviews Document s Student Records The district notifies parents of student placement in the ELE program upon enrollment in the district. The documentation submitted contain parent notification letters, progress reports and report cards translated into Spanish and Vietnamese. Partial 47 The district does not have procedures in place to notify parents when a student is placed in an ELE program at any other juncture. Parent notification letters were not found in many of the student records. The parent notification letter does not contain the following required elements: -The child’s level of proficiency -the right of non-Spanish speaking parents to apply for a waiver -the manner in which the program will help the student learn English -exit requirements -the parent’s right to opt-out Also, the letter was not available to parents in their native language, except for Spanish and Vietnamese. Report cards and progress reports of non-Spanish speaking parents were not translated, even when parents requested it. Submit the following documentation: -a parent notification letter containing all the required elements. -samples of the parent notification letter, progress reports and report cards translated into languages other than Spanish and Vietnamese. -A plan for the oversight and monitoring of the placement and notification process and the provision of translated materials upon parent request. Include the key personnel responsible for the implementation of the procedures by building. Above due by November 18, 2005. Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Partial 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 ELE 11 Equal Access to Academic Programs and Services Correctiv e Action Plan Interviews Document s Student Records The district has trained most of its teachers in the provision of sheltered English instruction. The district has bilingual/bicultural psychologists and counselors who speak Spanish, Portuguese, Albanian and Vietnamese. Limited English proficient students have access to counseling in their native language. Interviews indicated that the district’s practice of providing common planning time to staff has afforded LEP students continuous and increased access to the curriculum. In addition, the ELE handbook provided to content teachers is comprehensive and contains invaluable tools for teaching and learning. Partial 48 Refer to ELE 3 and ELE 5 for findings regarding implementation of the criterion. Refer to ELE 3 and ELE 5 for the corrective action and progress reporting. Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented ELE 12 Equal Access to Nonacademic and Extracurricular Programs Correctiv e Action Plan Interviews Document s The district’s extensive parent outreach ensures that LEP students are informed and have complete access to extracurricular activities. Student Records 49 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented 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 Interviews indicated that staff are unaware of the follow-up monitoring activities for exited LEP students. There are no follow-up monitoring forms documented in the student records. Teachers are not informed which students in their classroom are LEP or FLEP. The ELE Director does monitor the student’s report card, but this practice is limited in its scope and does not fully address the student’s performance and educational progress as a FLEP student in the general curriculum. Submit written procedures for the provision of follow-up support to students having exited an ELE program, and the methods for tracking the provision of follow-up support to students. Indicate the personnel responsible for the monitoring, the timelines and/or junctures established for the monitoring, types of interventions to be implemented when the student is not progressing, and the manner in which the classroom teacher(s) will be informed of the LEP or FLEP status for students enrolled in their classes. Provide evidence of the building-based dissemination of the written procedures. Above due by November 18, 2005. Interviews ELE 13 Follow-up Support Correctiv e Action Plan Document s Student Records Submit the results of the administrative review regarding the implementation of the above procedures system-wide K-12 and evidence that students are being tracked and monitored on a buildingbased level, by March 20, 2006. ELE 14 Interviews The district is to be 50 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Licensure and Fluency Requirements Correctiv e Action Plan Document s commended for the intensive training initiative of all its teachers in the provision of SEL. Staff are appropriately licensed. However, it was noted that there are not enough ESL teachers, which may be alleviated by instituting effective exiting procedures as referenced in ELE 5 and ELE 6. 51 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 Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Determined to be Not Fully Implemented or Additional Issues Identified or Corrective Action Plan Determined to be Substantially Implemented Interviews Document s Requirements ELE 16 Equitable Facilities ELE 17 DOE Data Submission Requirements Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting Interviews On-site classroom visits Interviews Interviews indicated that there is not a mechanism in place to monitor the tracking of LEP students and to evaluate the ELE program. Interviews indicated that a high number of students were reported to the Department as Develop and submit a plan to track and monitor the accurate submission of designated LEP and FLEP students to the Department. There are extensive professional development course offerings available to instructional staff and paraprofessionals. As referenced in prior comments, the district’s intensive TELL training initiative of all its teachers is commendable. The instructional spaces provided to LEP students are comparable to those provided to non-LEP students. There was evidence of ample instructional materials and books. Student Records and Program Evaluation Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance ELE 15 Professional Developmen t Correctiv e Action Plan Document s 52 Develop and submit a plan to evaluate the ELE programs and activities system-wide PK/ K-12. Criterion Number And Topic (Refer to full text of requirements in 2004-2005 Special Education Information Package) Implementa -tion Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented ELE 18 Records of LEP Students Student Records Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Correctiv e 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 LEP, who were no longer LEP or who did not have firm criteria documented to establish the accurate status of LEP students. Above due by November 18, 2005. The student records do not always contain the following required elements: log of access, exiting information, initial assessment information, parent notification letters, and evidence of follow-up monitoring. Conduct a review of all ELE student records regarding the inclusion of the required information. Submit the results of the review and the changes made to ensure that all ELE student records will contain the required information. Indicate the personnel responsible for monitoring the documentation of the required information in the ELE student records and the plan for the monitoring. Submit evidence that the responsible personnel have been informed of the monitoring procedures. Submit the status regarding the implementation of the evaluation plan by March 20, 2006. Above due by November 18, 2005. On-site student record review will be scheduled for August 2006. 53 54