Massachusetts Department of
Elementary and Secondary Education
75 Pleasant Street, Malden, Massachusetts 02148-4906
Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
January 5, 2010
Bruce Bona, Executive Director
Eagleton School
446 Monterey Rd.
Great Barrington, MA 01230
Re: Mid-cycle Review and Verification of previous Program Review Corrective Action Plan
Dear Mr. Bona:
Enclosed are the Department’s findings regarding your private school program’s recent onsite
Mid-cycle Review. This Mid-cycle Review Report contains the Department's findings regarding
the implementation status and effectiveness of corrective steps taken in response to your previous
Program Review Report issued on March 13, 2008. This report also includes the status of the
program’s implementation of new state or federal special education requirements enacted since
your program’s last Program Review.
While the Department of Elementary and Secondary Education found one previous area of
noncompliance to be only partially corrected, we are pleased to indicate that the Department has
found your program’s overall approved Corrective Action Plan to be substantially implemented
and effective in remedying previously identified noncompliance issues. Additionally, we have
determined that your program is in substantial compliance with any new state or federal special
education requirements enacted since your last Program Review. Therefore, your program will
receive an updated status of “Full Approval.” This approval shall remain in effect for three (3)
years from the date of this letter and attached approval certificate. This approval will be
contingent upon continued compliance with all regulations contained within 603 CMR 28.00
“Special Education Regulations” and 603 CMR 18.00 “Program And Safety Standards For
Approved Public Or Private Day And Residential Special Education School Programs.” The
Department of Elementary and Secondary Education may change this approval status at any point
during this three-year period if circumstances arise that warrant such a change.
The findings of the Department are included in the attached Mid-cycle Review Report. You and
your entire staff are to be congratulated for your efforts in implementing all necessary
improvements.
Page 1 of 2
As the Department previously informed you, in cases where a program fails to fully and
effectively implement a Corrective Action Plan which was proposed by your program and
approved by the Department, the Department must then prepare a Corrective Action Plan for the
program which must be implemented without further delay. You will find this requirement for
corrective action and further progress reporting included in the attached report, together with any
steps that must be taken by the program to fully implement the special education requirements.
Please provide the Department with your written assurance that the Department's requirements
for corrective action will be implemented by your program within the timelines specified. Your
statement of assurance must be submitted to the Department's Onsite Chairperson by January
15, 2010.
The Department will notify you of your program’s next regularly scheduled Program Review
several months before it is to occur. At this time we anticipate the Department's next routine
monitoring visit to occur sometime during the FY 2013, unless the Department determines that
there is some reason to schedule this visit earlier.
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, Mid-cycle Review Chairperson
Program Quality Assurance Services
Darlene Lynch, Director
Program Quality Assurance Services
c:
Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education
Daniel Farrell, Local Program Review Coordinator
Encl.: Mid-cycle Review Report
Full Private School Approval Certificate, Expiration Date: August 31, 2013
Page 2 of 2
MASSACHUSETTS DEPARTMENT OF
ELEMENTARY AND SECONDARY EDUCATION
PRIVATE SCHOOL MID-CYCLE REVIEW
Eagleton School
Intensive Residential Program
MID-CYCLE REVIEW REPORT
Previous Program Review Corrective Action Plan Submitted on April 28, 2008
Progress Reports Submitted on September 12, 2008 and January 1, 2009
Mid-cycle Onsite Visit Conducted on December 8, 2009
Date of this Report: January 5, 2010
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

Selected Approved Private School Program Mid-cycle Review Criteria
Eagleton School Intensive Residential Program Mid-cycle Review Report
December 21, 2009
Page 1 of 14
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
2.2
Approvals,
Licenses,
Certificates of
Inspection
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

Documentation
Review
Eagleton School submitted
current copies of licenses,
approvals, and certificates of
inspection for all buildings
that are accessed by students.
Documentation
Review
Eagleton School submitted a
current EEC license for each
of its residential buildings.
Documentation
Review
Eagleton School submitted a
written plan that addresses
how the program will
effectively serve limited
English proficient (LEP)
students.
18.04(1);
28.09(2)(b)(5);
28.09(5) (b);
28.09(6) (b, c)
2.3
EEC Licensure

102 CMR 3.00
(Residential
Schools only)
8.4
Program
Modifications
and Support
Services for
Limited
English
Proficient
Students

Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 2 of 14
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary 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

M.G.L. c. 71A;
Title VI
8.5
Current IEP &
Student Roster

Documentation
and Student
Record Review
Eagleton School submitted a
current IEP and Student
Roster for all district-funded
Massachusetts students
enrolled in the program that
contains all the required
elements for this criterion.

Documentation
Review
Eagleton School has a
designated Educational
Administrator who is
appropriately qualified to
supervise the provision of
special education services in
the program and ensures that
the services specified in each
student’s IEP are delivered as
required.
28.09(5)(a)
11.3
Educational
Administrator
Qualifications
28.09(5)(a);
28.09(7)(a);
603 CMR
44.00
Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 3 of 14
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
11.4
Teachers
(Special
Education
Teachers and
Regular
Education
Teachers)
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

Documentation
Review
Eagleton School submitted
documentation verifying that
all teaching staff members are
appropriately licensed. A
Professional Development
Plan was submitted for each
teacher who holds a
professional level license.

Documentation
Review
All staff providing or
supervising the provision of
related services for Eagleton
School are appropriately
certified, licensed or registered
in their professional areas.

Documentation
Review
Eagleton School submitted a
Master Staff Roster that
contains the name, program
job title, corresponding UFR
title number, licensure and/or
18.05(11)(f);
28.09(5)(a);
28.09(7)(b, c);
34 CFR
300.321
11.5
Related
Services Staff
28.09(7)(d)
11.6
Master Staff
Roster
28.09(7)
Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 4 of 14
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary 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 Elementary
and Secondary Education
and Timelines for
Implementation and Further
Progress Reporting

certification if appropriate,
full-time equivalent (FTE),
and qualifications for current
staff.
The Master Staff Roster
accurately corresponds to the
last approved ESE Program
Budget as required.
Identified Areas of Non-Compliance During the 2007 Program Review or Other Areas of Concern
1.2
Program and
Student
Description

Documentation
Review
Eagleton School provided a
written narrative that now
fully describes the program’s
philosophy, goals, objectives,
student population,
educational services, and
related services.

Documentation
Review
Eagleton School provided a
copy of it policy and
procedures to make prior
notification in advance of
proposing program or facility
28.09(2)(a)(2);
28.09(2)(b)(2,
3, 7)
4.4
Advanced
Notice of
Proposed
Program/
Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 5 of 14
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

changes. This policy indicates
that Eagleton School is now
knowledgeable about the
Department’s current
reporting requirements.
28.09 (5)(c)

Documentation
Review
Eagleton School provided a
copy of its policy and
procedures to make required
notifications of incidents
involving both students from
Massachusetts and those from
out of state. This policy now
indicates that Eagleton School
is knowledgeable about the
Department’s current
reporting requirements.

Documentation
Review
Eagleton School submitted
block schedules that now
indicate students attending
pre-vocational classes and
academic classes participate in
a school day that is of
equivalent length. All
students are provided with a
class schedule that meets the
18.03(10);
18.05(7);
28.09(12) (a, b)
6.1
Daily
Instructional
Hours
603 CMR 27.04
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

Facility
Change
4.5
Immediate
Notification
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 6 of 14
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary 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 Elementary
and Secondary Education
and Timelines for
Implementation and Further
Progress Reporting
Student record review
indicates that progress
reports are not always
written to address goals of
the IEP most recently
signed by the
parent/guardian.
Eagleton School has recently
obtained a program for staff
members to be able to access
the most current copy of each
IEP via internal intranet that
will be used to ensure teachers
write progress reports on each
goal of the current IEP.

Department’s required annual
instructional hours.
8.8
IEP – Progress
Reports
28.07(3);
34 CFR
300.320(a)(3)(i,
ii)
Student
Record Review
and Interview

Eagleton school states that
it sends a copy of each
progress report to sending
public school districts and
involved state agencies, if
applicable, by placing a
copy of the fax cover
sheet in each student’s
record. Parents/Guardians
are mailed progress
reports without a cover
letter. No documentation
of mailing progress
reports to
parents/guardians was
found in student records.
Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 7 of 14
Eagleton School must submit a
narrative description of
procedures to ensure that
progress reports address
progress toward each goal on
the current IEP for each
student. This description must
include the title of each staff
person who has a role in these
revised procedures.
Eagleton School must submit a
narrative description of updated
procedures to document that
progress reports are sent to
parents/guardians. This
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 Elementary
and Secondary Education
and Timelines for
Implementation and Further
Progress Reporting

description must include the
title of each staff person who
has a role in these revised
procedures.
Eagleton School must submit a
copy of the memo sent to staff
members that details the
revised procedures to ensure
that a progress report is written
on each goal of the student’s
current IEP.
These documents must be
received at the Department by
February 12, 2010.
Eagleton must submit the most
recently signed IEP and
progress report of five students
that shows that progress reports
are now written to address all
goals of the IEP most recently
signed by the parent/guardian.
Evidence of when and to whom
Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 8 of 14
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 Elementary
and Secondary Education
and Timelines for
Implementation and Further
Progress Reporting

the school sent copies of the
most recently issued progress
reports must also be submitted.
These documents must be
received at the Department by
April 2, 2010.
9.7
Terminations

Documentation
Review
Eagleton School submitted a
written termination policy and
procedures that now includes
all required elements of this
criterion for both planned
terminations and emergency
terminations. This policy no
longer references termination
of enrollment based on refusal
of medical treatment based on
religious beliefs or refusal to
receive antipsychotic
medication.

Documentation
Review
Eagleton School submitted a
statement that acknowledges
the most recent ESE approved
Student: Licensed Educator
Ratio as 8:1 in each
instructional group. Block
18.05(7);
28.09(12)(b)
10.1
Staffing for
Instructional
Groupings
28.06(6)(d);
Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 9 of 14
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

28.09(7)
12.2
In-Service
Training Plan
and Calendar
28.09(7)(f);
28.09(9)(b);
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary Education
and Timelines for
Implementation and Further
Progress Reporting
schedules were submitted that
indicates the approved ratios
are now being maintained in
all classrooms.

Documentation
Review
Eagleton School submitted
block schedules with the
birthdates of each student in
each instructional group.
Review of block schedules
indicates that the age range of
students in each instructional
group does not exceed 48
months.

Documentation
Review
Eagleton School submitted a
copy of its current
organizational chart that now
includes lines of supervision.
Documentation
Review and
Interview
Eagleton School submitted its
2009-2010 In-Service
Training Plan and Calendar
that contains all elements of
this criterion along with a
sign-in sheet with the
signature of each staff member
28.06(6)(f, g)
11.9
Organizational
Structure
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

28 09(7)(e)
10.2
Age Range
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 10 of 14
Eagleton School is developing
a new tracking system that will
provide managers with a more
efficient method to easily see
when individual staff members
are due for participation in an
annual required training.
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

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary Education
and Timelines for
Implementation and Further
Progress Reporting

in attendance at individual
trainings.
28.09(10);
18.03(3);
18.05(9)(e)(1);
18.05(10);
18.05(11)(h)
Title VI: 42
U.S.C. 2000d;
34 CFR 100.3;
EEOA: 20
U.S.C. 1703(f);
Title IX: 20
U.S.C. 1681;
34 CFR
106.31-106.42;
M.G.L. c. 76,
§ 5; 603 CMR
26.00, esp.
26.07(2, 3)
13.4
Physical
Facility/
Architectural
Barriers
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Eagleton School must submit a
narrative description of
procedures to ensure that all
staff members attend annually
required trainings. This
description must include the
title of each staff person who
has a role in these revised
procedures.
Eagleton School must submit a
copy of the memo sent to all
staff members, which details
these revised tracking
procedures.
These documents must be
received at the Department by
February 12, 2010.

Observation
Observation indicates that the
residence known as Upper 23
has been completely
renovated. The staircase has
been moved so it is no longer
necessary to walk through one
Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 11 of 14
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

18.05(5)(c);
18.05(8);
18.05(9)(f)(1);
18.05 (9)(j);
M.G.L. c. 71, §
32A
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary Education
and Timelines for
Implementation and Further
Progress Reporting
Eagleton School has
parents/guardians sign
consents for medication
administration, emergency
medical treatment and
restraint procedures at the
time of admissions, but
these consents are not
renewed annually, as
required.
Eagleton School must submit a
narrative description of
procedures to ensure
parents/guardians sign the three
required consents annually.
This description must include
the title of each staff person
who has a role in these revised
procedures.

student’s bedroom to get to all
other student bedrooms. Tile
and fixtures in the bathroom
are no securely attached to the
wall. There is no longer an
air-conditioning unit in a
student’s closet that could leak
onto a student’s possessions.
18.04(8);
Section 504:
29 U.S.C. 794;
34 CFR
104.21,104.22;
Title II: 42
U.S.C. 12132;
28 CFR
35.149, 35.150;
Mass. Const.
amend. art.
15.5
Parent
Consent and
Required
Notification
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Documentation
and Student
Record Review

Eagleton School must submit a
copy of the memo sent to all
staff members involved in
ensuring parent/guardian
signatures on consents are
Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 12 of 14
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 Elementary
and Secondary Education
and Timelines for
Implementation and Further
Progress Reporting

current and found in student
records.
Eagleton School must submit a
report on the results of the
review of five Massachusetts
students’ records. This report
must include the initials of the
student and the date each of the
three consents mentioned here
were most recently signed.
These documents must be
received at the Department by
February 12, 2010.
16.5
Administration
of Medication
18.05(9)(f)(8)

Documentation
Review
Eagleton School submitted
written policy and procedures
for the administration of
medication that now contains
all required elements of this
criterion.
Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 13 of 14
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

16.6
Administration
of Antipsychotic
Medication
18.05(9)(f)(9)

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

Documentation
Review
Eagleton School submitted
written policy and procedures
for the administration of
antipsychotic medication that
now contains all required
elements of this criterion.
Eagleton School Intensive Residential Program Mid-cycle Review Report
January 5, 2010
Page 14 of 14
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary Education
and Timelines for
Implementation and Further
Progress Reporting