Massachusetts Department of
Elementary and Secondary Education
350 Main Street, Malden, Massachusetts 02148-5023
Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
February 7, 2007
Andrew Pollock
Executive Director
New Directions School
Cutchins Programs for Children and Families
78 Pomeroy Terrace
Northampton, MA 01060
Re: Onsite Follow-up Monitoring Report: Program Review
Corrective Action Plan Verification and Mid-cycle Review
Dear Mr. Pollock:
Enclosed is the Department's Program Review Follow-up Monitoring Report together with
findings regarding your private school’s Mid-Cycle Program Review. This report contains the
Department's findings based on the onsite activities conducted in your school to verify the
implementation status and effectiveness of corrective steps taken in response to your Program
Review Report issued on July 14, 2003. This report also includes a report on the status of
implementation for new state or federal special education requirements enacted since your
school’s last Program Review.
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. Therefore, the Department is issuing a “Provisional Approval” status
effective from the date of this letter and indicated on your approval certificate. Your “Provisional
Approval” will expire on (DATE). The reasons for the “Provisional Approval” are clearly
indicated on the attached Corrective Action Plan Implementation Checklist. In areas where the
private school has failed to implement fully its approved Corrective Action Plan, the Department
views these findings to be serious.
As the Department previously informed you, in cases where a private school fails to fully and
effectively implement a Corrective Action Plan which was proposed by your school and
approved by the Department, the Department must then prepare a Corrective Action Plan for the
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Page 1 of 2
school 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 school 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 private school within the timelines specified.
Your statement of assurance must be submitted to the Department's Onsite Chairperson by
February 26, 2007.
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 413- 858-4591.
Sincerely,
Sandra K. Hanig, Educational Specialist
Program Quality Assurance Services
Darlene Lynch, Director
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Elementary and Secondary Education
Benjamin Barnes, Chairperson, Board of Directors
Encl.: Follow-up Monitoring Report
Provisional Private School Approval Certificate, Expiration Date: July 25, 2007
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
PRIVATE SCHOOL MID-CYCLE PROGRAM REVIEW
Cutchins Programs for Children and Families
New Directions Day School
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION
Action Plan Submitted on July 14, 2003
Progress Reports Submitted on November 6, 2003
Onsite Visit Conducted on July 18 & 19, 2006
Date of this Report February 7, 2007
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


2.2
Approvals,
Licenses,
Certificates of
Inspection
28.09 (2)(b)4-5
28.09(5)
28.09(6)
18.04(1)
2.3
OCCS Licensure
(Not Applicable

Documentation
review
The Department found this
criterion to be implemented at the
time of the 2003 Program Review.
The Department found during the
July 2006 Mid-cycle Review that
this criterion continues to be fully
implemented.
Not
Applicable
New Directions School is a Day
Program.
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Page 1 of 41
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


to Day Schools)
3.1
Policies and
Procedures
Manuals
Documentation
review

28.09(11)(b)
(formerly 3.1,
3.2, 3.3)
The concern at the time of the
2003 Program Review was that
the school had not consistently
notified parents of enrolled
students in writing of their right
to review the school’s policies
and procedures.
During the July 2006 Mid-cycle
Review, the Department found
that the letter notifying parents
of their right to request a copy
of policies and procedures states
that admissions policies and
procedures are available to
parents, but does not indicate
that other special education
policies and procedures in the
school’s Policies and
Procedures Manual are
available for review at any time.
New Directions School’s
Policies and Procedures Manual
is not clearly labeled.
2
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Copy of letter sent to
parents informing them of
their right to review the
Policy and Procedures
Manual
 Statement of assurance
that the Policies and
Procedures Manual is
clearly labeled
 List of locations where
Policy and Procedure
Manual is available for
public view
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


3.2
Health Care
Manual
18.05 (9)(d)
Documentation
review

(formerly 3.1,
3.2, 3.3)
The concern at the time of the
2003 Program Review was that
the school had not consistently
notified parents of enrolled
students in writing of their right
to request copies of the school’s
policies and procedures.
See comment under 3.1
regarding notification letter to
parents of right to review all
policies and procedures,
including health care policies
and procedures.
Submit the following
documents to the Department
of Education by April 2, 2007:
 Copy of letter sent to
parents informing them of
their right to review the
Health Care Manual at any
time
 Statement of assurance
that the Health Care
Manual is clearly labeled
 List of locations where
Health Care Manual is
available for public view
New Directions School’s Health
Care Manual is not clearly
labeled.
4.4
Advanced Notice
of Program/
Facility Change
28.09(5)(c)
4.5
Immediate
Notification

Documentation
review
The Department found this
criterion implemented at the time
of the 2003 Program Review.
During the July 2006 Mid-cycle
Review, the Department found that
the school has a written policy on
advanced notice of program or
facility change that includes all
required elements.
Documentation
review

The concern at the time of the
2003 Program Review was that
the school had not notified the
3
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


18.03(10)
18.05(7)
28.09(12)
5.1
Student
Admissions
28.09(11)
Documentation
review and
interview

18.05 (1) and (2)
Department of a student injury,
resulting from a restraint, which
required medical attention.

A review of the school’s policy
on immediate notification of
critical incidents does not
indicate that the school will also
notify other state agencies if
applicable and parents or
guardian. A review of incident
reports submitted to the
Department of Education
indicates that these reports do
not always document that the
school notified the sending
public school district of the
incident.
Incident reports submitted to
the DOE will indicate that the
public school was notified of
each incident.
The concern at the time of the
2003 Program Review was that
the school’s admissions policy
did not included information on
how copies of the school’s
policies and procedures are
distributed to students, parents
and public school districts.
Submit the following
documents to the Department
of Education by April 2, 2007:
 Revised admissions policy
that clearly states the role
of the private school when
it believes an IEP Team
meeting may need to be
held.
A review of the school’s
admissions policy during the
July 2006 Mid-cycle review
includes a statement that seems
to imply that the private special
4
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Revised policy on
immediate notification of
critical incidents
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


education school rather than the
sending school district is
organizing IEP Team meetings,
as required. Interview indicates
that the private special
education school understands its
responsibility to notify the
public school if staff members
believe an IEP Team meeting
may need to be called by the
sending school district.
5.2
Policies and
Procedures for
Coordination/
Collaboration
with Public
School Districts
& Content
requirements
policies/
procedures for
Coordination/
Collaboration
with Public
Student record
review

In addition, the school’s policy
does not state that students, if
appropriate, and public school
districts will be notified of their
right to review the school’s
Policies and Procedures
Manual.
The concern at the time of the
2003 Program Review was that
the school had not executed
contracts with placing school
districts that included mandated
components.
Student record review at the
time of the July 2006 Mid-cycle
Review indicates that contracts
between New Directions and
sending school districts do not
contain all information the
Department requires. See 603
5
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Copy of 5 contracts
between New Directions
School and 5 different
sending school districts
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


School Districts
28.06(2-3)
28.09(9)(c)&(d)
28.09(2)(b)7
Federal
Regulations:
300.349 and
300.400-.401
CMR 28.09 for details on
required elements.
(Formerly 5.3
and 5.4)
6.1
Daily
Instructional
Hours
603 C.M.R.
27.00
Review of
documentation,
student record
and
observation

The Department found this
criterion implemented at the
time of the 2003 Program
Review.
Review of the block schedule at
the time of the July 2006 Midcycle review indicates that the
class schedule does not contain
sufficient detail outlining which
subject is taught at each hour of
the day.
Interview and observation
indicate that the schedule of
class offerings in the summer
months is quite different from
the academic year schedule and
does not contain adequate
instructional hours in core
subjects in order to enable
students to meet IEP goals.
6
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Block schedule for 20062007 academic year
 Block schedule for
summer 2007
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


Many students have a
“vocational” or work-study
program in summer months but
review of student records did
not document the need for a
vocational course of study.
The concern based on
observation at the time of the
July 2006 program review is
that students were not arriving
to school on time.
See comment under criterion
6.2 regarding documenting the
need for work-study on the IEP
with specific vocational goals
and objectives.
Observations during the July
2006 Mid-cycle Review was
that work-study opportunities in
the summer are not well
structured with concrete goals
and students who have work
study do not receive instruction
in all academic subjects.
6.1A
Physical
Education and
Health
Curriculum
Documentation
review

Compliance with this regulation
was not monitored at the time of
the 2003 Program Review.
During the July 2006 Mid-cycle
7
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Health curriculum
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


review, the Department found
that New Directions School has
no written health curriculum.
6.2
School-to-work
(Instructional
hours)
603 CMR 27.02,
27.04
6.3
Kindergarten
(Instructional
hours)
603 CMR
27.03(5)
6.4
School Days per
Year
28.09(9)
Documentation
review

Compliance with this regulation
was not monitored at the time of
the 2003 Program Review.
The Department found during
the July 2006 Mid-cycle
Review that New Directions
School has not developed welldefined guidelines detailing
supervision of students enrolled
in school-to-work classes or
how work study opportunities
are structured to meet specific
individual IEP goals and
objectives.
Submit the following
documents to the Department
of Education by April 2, 2007:
 List of students who
participate in vocational
programs with name of the
type of vocational
program
 Copy of IEP vocational
goal and service delivery
grid for 5 students who
participate in a vocational
program
 Curriculum for each
vocational area
New Directions School does not
serve young students in
Kindergarten.
Not Applicable
Documentation
review

This criterion was implemented
at the time of the 2003 Program
Review.
8
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Copy of revised school
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


(Formerly 6.2)
Documentation review at the
time of the July 2006 Mid-cycle
review indicates that the school
calendar does not include 5
additional emergency days.
6.5
Early Release of
High School
Seniors

Documentation
review
Compliance with this regulation
was not monitored at the time of
the 2003 Program Review.
The Department found during the
July 2006 Mid-cycle Review that
this criterion is fully implemented.
603 CMR 27.05
7.1
Curriculum
28.09(9)(b)
(formerly 1.3)
calendar that indicates 5
additional days class will
be held in the case that
some class days need to be
canceled due to
emergency.
Documentation
review

The Department found this
criterion implemented at the
time of the 2003 Program
Review.
A review of New Direction’s
curriculum during the July 2006
Mid-cycle review indicates that
the school has not developed a
comprehensive curriculum for
all subjects at each grade level
to be utilized by New Directions
School.
9
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Curriculum for 6th grade
mathematics,
 Curriculum for 7th grade
English language arts,
 Curriculum for 8th grade
science and
 Curriculum for 9th grade
social studies as
representative examples of
a fully developed
curriculum.
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


7.3
State/District
Wide
Assessments
28.09(9)(d)
8.3
Implementation –
Supplementary
Aids/Services

Documentation
and student
record review
The Department found this
criterion to be implemented at the
time of the 2003 Program Review.
The Department found during the
July 2006 Mid-cycle Review that
this criterion continues to be fully
implemented.

Documentation
review
34 CFR 300.28
The concern at the time of the 2003
Program Review was that the
school did not provide
documentation to indicate the kinds
of supplementary aids and services
that are available for students in the
program.
During the July 2006 Mid-cycle
review, the school submitted a list
of supplementary aids and services
it provides to students. It also
submitted a copy of the “Assistive
Technology Guide for
Massachusetts Schools” that
describes types of assistive
technology tools any school could
make available to students.
8.5
Current IEP &
Student Roster
28.09
Documentation
and student
record review

The concern at the time of the
2003 Program Review was that
the school had not documented
its efforts to work with sending
public school districts to obtain
10
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 List of IEP pages and
related documents that
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


(Formerly 8.4)
current, signed IEPs.
8.6
Education Case
Manager
28.09
Documentation
and student
record review

(Formerly 8.5)
Review of the student records at
the time of the July 2006 Midcycle indicate that New
Directions School does not have
a complete IEP on file for each
student and not all IEPs are
signed, but the school’s efforts
to document attempts to obtain
signed IEPs were documented
in student records.

The concern at the time of the
2003 Program Review was that
the school had assigned an
educational case manager to
each student, but staff members
did not always know who that
individual was.
Submit the following
documents to the Department
of Education by April 2, 2007:
 Student roster that
indicates the case manager
assigned to each student
During the July 2006 Mid-cycle
review the school submitted a
11
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Cutchins expects to have
on file for each student.
Report on your review of
student files.
Submit a copy of the
student roster that
indicates the dates of each
IEP and whether is has
been signed by the parent
and sending district.
For students that do not
have a current signed IEP
on file, submit
documentation of your
repeated efforts to contact
the sending district to
obtain a current signed
IEP. This documentation
may include copies of
letters, emails and/or
phone logs.


Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


blank copy of an “Intake Face
Sheet” that contains a line for
someone to fill in the name of
the student’s case manager, but
a student roster with each case
manager assigned was not
provided to the Department.
8.8
IEP- Progress
Reports
Documentation
and student
record review

28.07(3)
20 U.S.C.
Chapter 33,
Section
1414(d)(1)(A)
(viii)
34 CFR 300.347
The concern at the time of the
2003 Program Review was that
progress reports did not
consistently include written
information on student progress
toward annual goals in the IEP
or includes information on the
extent to which progress is
sufficient to enable the student
to achieve the goals by the end
of the IEP period.
Review of the student records
and policies and procedures
manual indicates that, although
the written policy meets
requirements, progress reports
are not being issued four times a
year per the school’s policy.
(Formerly 8.7)
12
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Copy of memo sent to all
staff members who
complete progress reports
that informs staff
members of dates progress
reports are due and
procedures outlining
expectations regarding the
content of progress reports
and persons responsible
for ensuring progress
reports are mailed and a
copy is filed in the student
record.
 Report on your review of
10 randomly selected
student records. Indicate
the dates that IEPs were
mailed out for each of
these students from June
1, 2006 – April 2, 2007.
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


8.9
IEP- Revisions
and Changes
Documentation
review and
interview

34 CFR 300
(Formerly 8.8)
The concern at the time of the
2003 Program Review was that
the private school had
revised/amended students’ IEPs
without the authorization and
presence of an administrative
representative of the responsible
school district.
Review of the school’s policy
on IEP revisions and changes
during the July 2006 Mid-cycle
Review indicates that the school
continues to have an incorrect
understanding of the private
special education school’s
responsibility regarding IEP
revisions and changes. The
school’s policy states that either
the private special education
school or public school
representative will contact
parents and reconvene the IEP
Team. This is clearly the
responsibility of the sending
public school district.
Interviews indicate that it is the
private special education
school’s practice to contact the
sending public school if there
are concerns about the
appropriateness of an IEP.
13
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Revised policy on IEP
revisions and changes that
more clearly states the
private special education
school’s role when there is
a concern that changes
may need to be made to an
IEP or an IEP Team
meeting may need to be
held.
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


8.10
IEP- Less
Restrictive
Placement
28.09(9(c)
(Formerly 8.9)

Documentation
and student
record review
The Department found this
criterion to be implemented at the
time of the 2003 Program Review.
Documentation review during the
July 2006 Mid-cycle Review
indicates that this criterion
continues to be implemented.
8.11

IEP- Transition
Planning
34 CFR
300.347(b)(1)
34 CFR
300.347(b)(2)
The concern at the time of the
2003 Program Review was that
neither a vision statement nor a
statement of needed transition
services was consistently being
developed as part of the IEP.
For the July 2006 Mid-cyle
Review, the school submitted a
policy on transition planning
that meets requirements.
(Formerly 8.10)
Submit the following
documents to the Department
of Education by April 2, 2007:
 Copy of pages from 10
IEPs that contain the
vision statement and
documentation of
transition planning.
Review of student records
indicates that not all IEPs were
complete so the Department of
Education was not able to verify
consistent documentation of
vision statements and transition
planning.
8.12

IEP- Transition
The concern at the time of the
2003 Program Review was that
the IEP Team was not
14
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


Services
determining student needs for
continuing services from adult
human services agencies nor
working with the responsible
school district to make
necessary referrals to the
Bureau of Transitional
Planning.
28.05(4)(c)
(Formerly 8.11)

List the names of students
and indicate which
students have a 688
referral and if a copy is
filed in the student record.
In July 2006, the Department of
Education did not find copies of
688 referrals in the student
records randomly chosen for
review.
9.1

Policies and
Procedures
18.05(5)
The concern at the time of the
2003 Program Review was that
staff members did not
consistently understand the
school’s restraint policies or
state and federal requirements
pertaining to the use of restraint.
Review of the In-Service
Training calendar during the
July 2006 Mid-cycle Review
indicates that the school offered
refresher restraint training
during the last 12 months.
Review of staff training log
indicates that not all staff
members have participated in
15
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Agenda and handouts for
restraint training
 Name and qualifications
of presenter
 Sign-in sheet for restraint
training with name, title
and signature of all staff
members in attendance
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


this mandated training.
9.3

Runaway
Students
The concern at the time of the
2003 Program Review was that
staff members did not
consistently understand the
school’s runaway policy.
18.03(10)
Review of the In-Service
Training calendar at the time of
the July 2006 Mid-cycle
Review indicates that the school
offered refresher training on its
runaway policy during the last
12 months.
Submit the following
documents to the Department
of Education by April 2, 2007:
 Agenda and handouts for
training on runaway
policy
 Name and qualifications
of presenter
 Sign-in sheet for runaway
policy training with name,
title and signature of all
staff members in
attendance
Review of staff training log
indicates that not all staff
members have participated in
this training.
9.4

Restraints
18.05 (5)(h)
603 CMR 46.00
The concern at the time of the
2003 Program Review was that
the school had not developed a
policy on the use of physical
restraint in accordance with the
requirements of 603 CMR
46.00.
A review of the school’s
restraint policy during the July
2006 Mid-cycle Review does
16
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Copy of revised restraint
policy
 Agenda and handouts for
training on restraint policy
 Name and qualifications
of presenter
 Sign-in sheet for restraint
training with name, title
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


not state that the school notifies
parents in writing within 3
school working days of
restraints that are over 5
minutes. The school’s policy
states that it notifies parents
verbally of restraints that last
between 6-19 minutes.
and signature of all staff
members in attendance
Review of personnel records in
July 2006 indicate that the
school is not documenting
current staff training in restraint
policy for all staff members.
The Department found this
criterion implemented at the time
of the 2003 Program Review.
10.1
Student:Teacher
Ratios
28.06(6)(d)&(g)
28.09(7)(e)
10.2
Age Range
28.06(6)(f)
Documentation review during the
July 2006 Mid-cycle Review
indicates that the staff to student
ratio falls within guidelines set
forth under 603 CMR 28.00
regulations.
Documentation
review and
observation

The concern at the time of the
2003 Program Review was that
instructional grouping in the
summer school program
exceeds forty-eight months and
the school had not obtained a
17
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Block schedule for all
classes with birth date of
each student in the class
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


waiver from the Department.
indicated
Review of block schedules
during the July 2006 Mid-cycle
Review indicates that
instructional groupings during
the academic year exceed fortyeight months. Observation in
July 2006 indicates that
instructional groups exceed the
forty-eight month age span and
the school had not obtained a
waiver from the Department.
10.4
Student: Child
Care Ratios
28.09(7)
18.01(2)
11.1
Personnel
Policies
28.09(7)
28.09(11)(a)
18.05(11)
New Directions School is a day
program.
Not Applicable
Documentation
and personnel
record review

The Department found this
criterion to be implemented at
the time of the 2003 Program
Review.
Review of personnel records at
the time of the July 2006 Midcycle Review indicates that
New Directions School is not
always following its policy
regarding conducting staff
evaluations. Not all employees
had an annual evaluation and
18
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Policy on CORI checks
 Revised policy on
reporting abuse and
neglect
 List of all staff members,
the date of their last and
next scheduled evaluation
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


new employees did not have an
evaluation after 90 days. There
is no written policy on CORI
checks and the policy on
reporting abuse and neglect
incorrectly states that staff
members must report possible
abuse or neglect to a supervisor.
11.3
Educational
Administrator
Qualifications
28.09(7)(a)
603 CMR
44.00 and 44.04
11.4
Teachers
Special
Education
Teachers and
Regular
Education
Teachers
28.09(7)(b)(c)
18.05(11)(f)

Documentation
review
The Department found this
criterion to be implemented at the
time of the 2003 Program Review.
The Department found during the
July 2006 Mid-cycle Review that
this criterion continues to be fully
implemented.
Documentation
and personnel
record review

The concern at the time of the
2003 Program Review was that
one teacher was not licensed by
the Massachusetts Department
of Education.
Review of teacher licenses
during the Mid-cycle Review in
July 2006 indicates that all
teachers hold a current
Massachusetts Department of
Education license or approved
waiver.
19
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Report on your review of
personnel records for all
persons who are required
to have a Massachusetts
teaching license or
approved waiver,
including teachers, special
education administrator
and speech and language
pathologists. Indicate
whether a copy of the
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


11.4(a)
Professional
Development
Plans
28.09(7)(b)(c)
Documentation
and personnel
record review

Review of personnel records
indicates that a copy of teaching
licenses are not filed in
personnel records.
DOE license is in each
personnel record.
Compliance with this regulation
was not monitored at the time of
the 2003 Program Review.
Submit the following
documents to the Department
of Education by April 2, 2007:
 Report on your review of
personnel records for all
persons who are required
to have a professional
development plan,
including professional
level teachers, special
education administrator
and speech and language
pathologists. Indicate
whether a copy of the
professional development
plan is in each personnel
record.
Review of professional
development plans for
professional level licensed
teachers during the Mid-cycle
Review in July 2006 indicates
that professional development
plans contain all required
information.
18.05(11)(f)
Review of personnel records
indicates that a copy of
professional development plans
are not filed in personnel
records.
11.5
Related Services
Staff
28.09(7)(d)
Not
Applicable
Documentation
review and
interview
This criterion was found to be “not
applicable” at the time of the 2003
Program Review because New
Directions was not providing
related services as part of its rate.
Interview during the July 2006
Mid-cycle Review indicates that
the school now hires medical and
20
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


clinical staff who are partially
funded through the Operational
Services Division, which sets the
tuition rate for the school program.
11.6
Master Staff
Roster
28.09(7)
Documentation
review

The Department found this
criterion to be implemented at
the time of the 2003 Program
Review.
The Department found during
the July 2006 Mid-cycle
Review that the private special
education school did not have a
master staff roster that
contained all the information
requested by the Department of
Education.
11.7
Job Descriptions
18.05(11)(d)
Documentation
and personnel
review

The Department found this
criterion to be implemented at
the time of the 2003 Program
Review.
For the July 2006 Mid-cycle
Review, New Directions School
only submitted job descriptions
for teachers, teacher assistants
and instructors. Job
descriptions were not found in
21
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Master Staff Roster
containing all information
requested by the
Department of Education
in the Department’s
publication, “Application
Procedures for
Department of Education
Approval of a
Massachusetts Public or
Private Day or Residential
Special Education School
Program”.
Submit the following
documents to the Department
of Education by April 2, 2007:
 Report on your review of
personnel records for all
staff members. Indicate
whether a copy of the job
description is in each
personnel record.
 Submit a copy of the
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


personnel records.
11.8
Salary Ranges
18.05(11)(e)
Documentation
review

The Department found this
criterion to be implemented at
the time of the 2003 Program
Review.
memo sent to each staff
member with a copy of his
or her job description as
evidence that each staff
member understands his
or her job duties.
Submit the following
documents to the Department
of Education by April 2, 2007:
 Salary ranges for all staff
positions
For the July 2006 Mid-cycle
Review, New Directions School
submitted information on salary
ranges for teaching staff but not
administrators.
11.9
Organizational
Structure
28.09(7)
28.07(c)

Documentation
review
The Department found this
criterion to be implemented at the
time of the 2003 Program Review.
For the July 2006 Mid-cycle
Review, New Directions School
submitted a copy of its
organizational structure. The
Department found that the private
special education school continues
to be in compliance with this
criterion.
The Department found this
11.11
22
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit a copy of the policy on
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


Supervision of
Students
28.09(7)

Documentation
review
criterion to be implemented at
the time of the 2003 Program
Review.
New Directions School did not
submit information to address
this criterion at the time of the
July 2006 Mid-cycle Review.
See comment under criterion
10.1 regarding student to staff
ratios during academic classes
and field trips.
11.12
Accessibility of
Extracurricular
Activities
Title VI: 42
U.S.C. 2000d; 34
CFR 100.3(a),
(b); Title IX: 20
U.S.C. 1681; 34
CFR 106.31,
106.41; Section
504: 29 U.S.C.
794; 34 CFR
104.4,104.37(a),
(c); Title II: 42
U.S.C. 12132; 28
CFR 35.130;

Documentation
review
The Department found this
criterion to be implemented at the
time of the 2003 Program Review.
Documentation review during the
July 2006 Mid-cycle Review
indicates that New Directions
School continues to be in
compliance with requirements of
this criterion.
23
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
supervision of students to the
Department of Education by
April 2, 2007.
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


NCLB: Title X,
Part C, Sec. 721;
Mass. Const.
amend. art 114;
M.G.L. c. 76, s.
5; 603 CMR
26.06
12.1
Staff Orientation
Training
Documentation
and personnel
record review

18.05(11)(g)
The concern at the time of the
2003 Program Review was that
new staff members were not
receiving training in all
mandated topics prior to
assuming direct care duties.
Additionally, the school had no
written plan describing how
newly hired staff would be
provided training on all required
topics at the time of hire if the
required topics had already been
covered with existing staff.
A review of the of school’s
New Staff Orientation
procedures during the July 2006
Mid-cycle review indicates that
not all mandated topics are
covered or required for all staff
members during orientation.
This policy states that all staff
members receive 40 hours of
restraint training, which is
offered by the school quarterly,
CPR within 6 months and First
24
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Revised policy on training
of new staff that indicates
that newly hired staff
receive training in all
Department of Education
mandated topics before
working directly with
children.
 Description of the private
school’s new system to
accurately document
training that each staff
member attends.
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


Aid within 3 months of
employment.
This indicates that some staff
members may not have
completed all mandated
trainings before being assigned
direct care duties with students.
Review of staff training records
confirms that new staff
members are not receiving
training in all mandated topics
before working directly with
students.
12.2
Annual InService Training
Plan and
Calendar
28.09(7)(f)
18.05(11)(h)
Title VI: 42
U.S.C.2000d;34
CFR
100.3;EEOA:20
U.S.C.1730(f);
Title IX: 20
U.S.C.1681; 34
CFR 106.31106.42;
M.G.L.c.76, s.5;

Documentation
review
The concern at the time of the 2003
Program Review was that
attendance at staff orientation and
in-service trainings was not
consistently documented.
A review of the school’s annual inservice training calendar during the
July 2006 Mid-cycle review
indicates that the school did not
offer an average of 2 hours of
training per month that included all
mandated topics for all staff
members in the 2005-2006
academic year, but has scheduled
all mandated trainings for all staff
members for the 2006-2007
academic year.
25
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


603 CMR 26.00,
esp.26.07(2),(3)
At this time it appears that the
private special education school has
already taken steps to come into
compliance with this regulation
regarding required staff trainings.
26
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


12.2 (a)
Behavior
Management and
Restraint
Training
Documentation
and personnel
record review

28.09(11)
18.05(5)
The concerns at the time of the
2003 Program Review were that
1) staff members did not
consistently understand the
legal requirement of the
restraint regulations, 2) the
school had no procedure for
integrating discipline and
behavior data into the IEP
TEAM discussion and 3) staff
training on this topic was not
consistently documented.
Review of the In-Service
Training calendar at the time of
the July 2006 Mid-cycle
Review indicates that the school
offered refresher training in
restraint procedures and its
behavior management level
system within the past 12
months.
Review of staff training log in
July 2006 indicates that not all
staff members have participated
in restraint refresher and
behavior management training
within the past 12 months.
27
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 List of all staff members
who the private special
education school requires
to be fully restraint trained
 Indicate the date of the
most recent full training or
refresher training for each
of these staff members
 Written procedures on
how the private special
education school will
ensure that discussion of
each student’s recent
behavior and discipline
history at each IEP
meeting will be
documented and placed in
the student record.
Indicate what data will be
brought to the IEP Team
meeting and who will be
responsible for
communicating this
information to the IEP
Team.
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


12.2 (b)
Details
Child Abuse
Reporting
Documentation
and personnel
record review

New Directions School did not
submit a copy of its procedure
to ensure that information on
the
student’s recent behavior and
discipline history is
communicated to IEP Team
members. Review of student
records did not indicate that
discussion of a student’s
behavior or discipline was
documented in the student
record.
The concern at the time of the
2003 Program Review was that
orientation and in-service
training on this topic was not
consistently documented.
18.05(9)(j)
Review of the In-Service
Training calendar at the time of
the July 2006 Mid-cycle
Review indicates that the school
offered training in reporting
child or adult abuse and neglect
within the past 12 months.
12.2 (c)
Details
Review of the staff training log
in July 2006 indicates that not
all staff members participated in
this training.
The concern at the time of the
2003 Program Review was that
Documentation
28
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Indicate the date of the
most recent training in
reporting abuse or neglect
for each staff member
 Description of the private
school’s new system to
accurately document
training that each staff
member attends
Submit the following
documents to the Department
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


Emergency First
Aid Training and
CPR Certification

and personnel
record review
18.05(9)(e)
12.2 (f)
Emergency
Procedures
Training
orientation and in-service
training on this topic was not
consistently documented.
Review of the In-Service
Training calendar at the time of
the July 2006 Mid-cycle
Review indicates that the school
offered training in CPR but did
not offer training in Emergency
First Aid within the past 12
months.
Documentation
and personnel
record review

18.05(10)
Review of the staff training log
in July 2006 indicates that not
all staff members participated in
these trainings. The CPR or
first aid training for some staff
members had expired.
The concern at the time of the
2003 Program Review was that
staff members were not trained
in the use of the alarm system
and equipment such as fire
extinguishers.
Review of the In-Service
Training calendar at the time of
the July 2006 Mid-cycle
Review indicates that the school
offered training in evacuation
and emergency procedures and
policies within the past 12
29
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
of Education by April 2, 2007:
 Indicate the date of the
most recent training in
CPR and First Aid for
each staff member
 Description of the private
school’s new system to
accurately document
training that each staff
member attends
Submit the following
documents to the Department
of Education by April 2, 2007:
 Indicate the date of the
most recent training in
evacuation and emergency
procedures and policies
for each staff member
 Description of the private
school’s new system to
accurately document
training that each staff
member attends
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


months.
Review of the staff training log
in July 2006 indicates that not
all staff members participated in
this training.
12.2 (i)
Staff Evaluations
18.05(11)(c)1.
Documentation
and personnel
record review

The concern at the time of the
2003 Program Review was that
written performance evaluations
were not maintained on all staff.
Review of personnel records
during the Mid-cycle Review in
July 2006 indicates that staff
members are not all receiving
an evaluation after 90 days of
employment and annually as
written in the personnel policy
manual.
30
New Directions School Cutchins Program Mid-cycle Review Report
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Submit the following
documents to the Department
of Education by April 2, 2007:
 List of staff members
hired after July 1, 2006
and the date of their most
recent written
performance evaluation
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


13.3
Comparability of
Facilities

Observation
Title VI: 42
U.S.C. 2000d; 34
CFR 100.3(b)(2);
Title IX: 20
U.S.C. 1681; 34
CFR
106.33,106.40(b)
(3); Section 504:
29 U.S.C. 794;
34 CFR
104.34(c); Mass.
Const. amend.
art. 114; 603
CMR 28.03(1)(b)
The Department found during the
July 2006 Mid-cycle Review that
this criterion continues to be fully
implemented.
13.4
Physical Facility/
Architectural
Barriers
18.04(8)
Section 504: 29
U.S.C. 794;34
CFR 104.21.
104.22; Title II:
42 U.S.C. 12132;
28CFR 35.149,
The Department found this
criterion to be implemented at the
time of the 2003 Program Review.

Documentation
review and
observation
The concern at the time of the 2003
Program Review was that the
school building bathroom was not
accessible.
Observation at the time of the July
2006 Mid-cycle review is that the
“Carriage House” classroom
building is not handicapped
accessible. This is where the
younger students have classes.
Documentation review indicates
that New Direction School’s plan is
to move a classroom from the
31
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


35.150; Mass.
Const. amend.
art. 114
Carriage House building to the
Montgomery school building to
hold classes for younger students
there if a student that required a
handicapped accessible classroom
were enrolled at Cutchins School.
(Formerly 13.3)
13.5
Observation

Kitchen, Dining,
Bathing/
Toilet, and
Living Areas
The concern at the time of the
2003 Program Review was that
school buildings were not
always clean or well
maintained.
Submit the following
documents to the Department
of Education by April 2, 2007:
 Plan for scheduled
building maintenance
Observation at the time of the
July 2006 Mid-cycle review
indicates that, although school
buildings seem to be clean,
floors are old and some walls
need to be painted.
18.04(2, 3, 4, 5)
(Formerly 13.4)
13.7
Observation

Library/
Resource Room
The concern at the time of the
2003 Program Review was that
the school did not have a library
or resource room in addition to
the regular instructional area.
18.04(6)(b)
Observation during the July
2006 Mid-cycle review
indicates that although the
school has identified a location
for the library space within the
computer room, it does not
(Formerly 13.6)
32
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Plan for increasing the
number of books and other
materials in the library
 Description for cataloging
library materials
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


contain a variety of materials
appropriate to the age of
students served at New
Directions School.
33
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


13.8
Observation

Indoor Space
18.04(7)(a)
The concern at the time of the
2003 Program Review was that
overhead lighting fixtures in the
Carriage House building were
not covered and may present a
potential safety hazard.
Observation at the time of the
July 2006 Mid-cycle review
indicate that classroom in the
basement of the Carriage House
smelled musty, was not well
ventilated and had potential
electrical hazard with the easily
accessible fuse box and
surrounding electrical
equipment. The timeout room
in the Carriage House is located
in a former garage and has
many hazards such as
protruding springs and metal
garage door mechanisms. In
addition, classroom spaces were
cluttered and disorganized.
Classroom space for
individualized reading in the
Carriage House is located in a
small room off of the art room
that is inappropriate because it
is dark, cluttered and located in
34
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Timeline for moving
classroom from the
basement or plan to cover
fuse box and modify this
classroom so that it is
properly ventilated.
 Timeline for moving the
timeout room in the
Carriage House or
modifying it so that it does
not have protruding
objects.
 Plan to ensure that
extraneous items in
classrooms are removed or
properly stored. Include
staff member who will be
responsible for monitoring
this.

Memo to staff members
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


a space that is adjacent to the
open space where art classes are
held as well as the time-out
room.
15.1
Parental
Involvement and
Parents’
Advisory Group
18.05(4)(a)
15.2
Orientation
Procedures

Documentation
review
The Department found this
criterion to be implemented at the
time of the 2003 Program Review.
The Department found during the
July 2006 Mid-cycle Review that
this criterion continues to be fully
implemented.

Documentation
review
28.09(11)
The concern at the time of the 2003
Program Review was that the
school had not developed or
implemented orientation
procedures for parents upon student
admission to the program.
The Department found during the
July 2006 Mid-cycle Review that
this criterion is fully implemented.
15.3
Information to be
translated into
Languages other

Documentation
review
Compliance with this regulation
was not monitored at the time of
the 2003 Program Review.
The Department found during the
35
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007

about the need to maintain
clean and organized
classroom spaces.
Plan to move location of
individualized reading to
another location.
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


than English
July 2006 Mid-cycle Review that
this criterion is fully implemented.
Title VI; EEOA:
20 U.S.C.
1703(f); M.G.L.
c. 76, s. 5; 603
CMR 26.02(2)
15.6
Student
Involvement

Documentation
review
The concern at the time of the 2003
Program Review was that the
school did not have a written policy
in place regarding student
participation in TEAM meetings.
34 CFR 300.344
The Department found during the
July 2006 Mid-cycle Review that
New Directions School has a policy
on student involvement that meets
the requirements.
(Formerly 15.5)
15.7
Consent at Age
of Majority
Documentation
and student
record review

The concern at the time of the
2003 Program Review was that
the school did not have a policy
in place regarding student
consent.
28.07(5)
The Department found during
the July 2006 Mid-cycle
Review that New Directions
School has a policy on student
consent at age of majority that
meets requirements.
(Formerly 15.6)
36
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Memo sent to all staff
members on how the
private special education
will ensure that when the
student turns 17 years old,
the requirement for the
student to sign the IEP at
age 18 and the student’s
wishes about parental
involvement in
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


Review of student records
indicates that discussion of
consent at age of majority is not
always documented in student
records.
15.8
Registering
Complaints

Documentation
review
The Department found this
criterion to be implemented at the
time of the 2003 Program Review.
The Department found during the
July 2006 Mid-cycle Review that
New Directions School continues
to fully implement this criterion.
18.05(1)(b)16
Title IX: 20
U.S.C. 1681; 34
CFR 106.8;
Section 504: 29
U.S.C. 794; 34
CFR 104.7; Title
II: 42 U.S.C.
12132; 28 CFR
35.107; NCLB:
Title X, Part C,
Sec.
722(g)(1)(J)(ii)
(Formerly 15.7)
16.9
Students with
Comfort Care/Do
Not Resuscitate
Orders

Documentation
review
Compliance with this regulation
was not monitored at the time of
the 2003 Program Review.
The Department found during the
July 2006 Mid-cycle Review that
37
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
educational decisionmaking after age 18 is
documented in student
records.
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


New Directions School has
developed a policy on Comfort
Care/Do Not Resuscitate Orders
that contains required elements.
16.10
Meningococcal
Disease and
Vaccination

Documentation
review
Compliance with this regulation
was not monitored at the time of
the 2003 Program Review.
The Department found during the
July 2006 Mid-cycle Review that
New Directions School has
developed a policy on
Meningococcal Disease and
Vaccination that contains required
elements.
MGL, Chapter
76, s.15D
105 CMR
220.700
17.1
Transportation
Safety
Documentation
and personnel
record review

The concern at the time of the
2003 Program Review was that
orientation and training of staff
is inconsistently documented.
28.09(11)(b)
Review of the In-Service
Training calendar and sign-in
sheet at the time of the July
2006 Mid-cycle Review
indicates that the school offered
training in transportation
procedures and policies within
the past 12 months. Review of
the written policy on
transportation safety, however,
38
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 Submit a revised
Transportation Policy
 Submit a list of all staff
members who transport
students in their personal
vehicles
 For each staff member
who transports students in
their personal vehicle,
submit a review of their
individual personnel
record that indicates
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


indicates that the policy does
not address the requirement for
staff members who transport
students to receive in-service
training on the individual needs
of students they transport. This
policy also does not state that
New Directions School is
required to notify the
Department of Education if staff
members are involved in a
motor vehicle accident while
transporting students.
Review of personnel records in
July 2006 indicates that New
Directions School is not
keeping a copy of current
driver’s license on file for all
staff members who transport
student in school-owned vans.
If staff members ever transport
students in their personal
vehicles, information on car
insurance and registration is not
maintained in personnel
records.
39
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
whether a current drivers
license, vehicle
registration and inspection
are found in each
personnel record.
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


18.2
Student Records
28.09(10)
Student record
review

MGL c. 71, s.
34H
603 CMR 23.00
Family
Educational
Rights and
Privacy Act
(FERPA)
The concern at the time of the
2003 Program Review was that
student records did not contain
the following items:
 Log of access
 Recent picture
 Educational assessments
 Correspondence with the
parent and sending school
district
Face Sheets were not updated
annually and they did not
contain the following items:
 Name of Educational Case
Manager
 Information to the transfer
of rights upon the student
reaching eighteen years of
age
 Information on other state
agency involvement
 Date of the student’s last
physical exam
40
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Submit the following
documents to the Department
of Education by April 2, 2007:
 A statement that assures
the Department that all
student record face sheets
have been reviewed and
revised to include all
required elements.
 Submit a random sample
of the face sheets of ten
students.
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be
Substantially
Implemented
Method(s) of
Verification
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


Review of student records at the
time of the July 2006 Mid-cycle
Review indicates that New
Directions School maintains a
current log of access and recent
picture and correspondence with
parent and sending school
district in each student file.
Face Sheets have been revised
to contain a space for staff
members to record information
on Educational Case Manager,
transfer of rights, other state
agency involvement, and date of
physical exam, but information
on face sheets is not always
completed with all required
information or updated
annually.
41
New Directions School Cutchins Program Mid-cycle Review Report
February 7, 2007
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting