The Commonwealth of Massachusetts
Department of Education
350 Main Street, Malden, Massachusetts 02148-5023
Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
January 28, 2005
Janice Brenner, Executive Director
8 Pearl Street,
Charlestown, MA 02129
Re:
Onsite Follow-up Monitoring Report: Program Review Corrective Action Plan
Verification and Mid-cycle Review
Dear Ms. Brenner:
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 May 3, 2002. 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 April 28, 2005. The reasons for the “Provisional Approval” are clearly
indicated on the attached Corrective Action Plan Implementation Checklist.
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
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 15, 2005.
Your staff's cooperation throughout these follow-up monitoring activities is appreciated. Should
you require additional clarification of information included in our report, please do not hesitate to
contact the Onsite Team Chairperson at 781-338-3739.
Sincerely,
Suzanne Conrad, Program Review Follow-up Chairperson
Program Quality Assurance Services
John D. Stager, Administrator
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
James M. Tierney, Chairperson, Board of Directors
Encl.: Follow-up Monitoring Report
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
PROGRAM REVIEW
Holden School
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION
Action Plan Submitted on June 5, 2002Onsite Visit Conducted on December 16, 17, 2004
Date of this Report January 28, 2005
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
2.2
Approvals,
Licenses,
Certificates of
Inspection
28.09 (2)(b)4-5
28.09(5)
28.09(6)
18.04(1)

Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting


1.3
Program’s
Curriculum
28.09(9)
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Documentatio
n Review and
Observations
Documentatio
n Review and
Observations.
Holden School has provided
the Department with a
description of the program’s
curriculum and staff
qualifications.

Holden School’s Building
Inspection expired in
November 2004. Holden
School does not have a
current PCP inspection or
a current Asbestos
inspection.
By February 21, 2005, the
program will submit these
documents.
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


102 CMR 3.06
(4)(b)
2.3
OCCS Licensure
(Not Applicable
to Day Schools)
3.2
Health Care
Manual
Not Applicable

Documentatio
n Review
Holden School has a current
health care manual that is
reviewed annually by a
physician.

Documentatio
n Review
Holden School has not had
any program or facility
changes that warrant
notification, but it does have
the required policy.
18.05(9)(d)
4.4
Advanced Notice
of Program/
Facility Change
28.09(5)(c)
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
2
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
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 Education
and Timelines for
Implementation and Further
Progress Reporting
Holden School has not
notified the Department of
all required notifications,
specifically for all
runaways, emergency
terminations and
hospitalizations.
By February 21, Holden School
will develop a written policy
and procedure for notification
of serious incidents and train all
staff on policies and procedures
for immediate notification
requirements. Please submit a
copy of the time and date, the
name of the trainer and copy of
attendance for the training.


4.5
Immediate
Notification
18.03(10)
18.05(7)
28.09(12)

Documentatio
n Review and
Staff
Interviews
5.1
Student
Admissions

Documentatio
n
Review
28.09(11)
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Holden School has the
required admissions policy
and ensures that physical
exams are completed within
the required timelines.
3
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


5.2
Policies and
Procedures for
Coordination/
Collaboration
with Public
School Districts
&
Content
requirements
policies/procedures for
Coordination/
Collaboration
with Public
School Districts

Documentatio
n Review
Holden School has
policies/procedures that
describe the roles and
responsibilities of all staff
regarding the coordination
and collaboration with public
school districts.
28.06(2-3)
28.09(9)(c)&(d)
28.09(2)(b)7
Federal
Regulations:
300.349 and
300.400-.401
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
4
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
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

Documentatio
n Review and
Staff
Interviews

Documentatio
n Review
Holden School provided the
Department with a copy of its
school to work program that
is also described in the
Holden School Student
Handbook.
Documentatio
n Review
Holden School provides 180
days of school during the
academic year for its 10
month program.
Not Applicable

Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Holden School’s daily
instructional hours fall
short of the required 990
per school year because of
scheduled half days.
By February 21, Holden School
will submit a schedule for the
2005-2006 school year that
includes the 990 required
instructional hours.


6.1
Daily
Instructional
Hours
603 C.M.R. 27.00
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)
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
5
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


6.5

Documentatio
n Review and
Staff
Interviews

Documentatio
n Review and
Observations

Documentatio
n Review and
Interviews
Early Release of
High School
Seniors
603 CMR 27.05
7.1
Curriculum
Frameworks
28.09(9)(b)
7.2
Staff Training
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Holden School schedules
early release of its high
school seniors in accordance
with state requirements.
Holden School personnel
reflect an understanding of
the connection between the
Massachusetts Curriculum
Frameworks and the
expectations of the state for
student performance.
Holden School annually
trains all non-professional
staff on the Massachusetts
Curriculum Frameworks
6
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
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
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Holden School has not
developed a narrative
description regarding the
MCAS Alternative
Assessment and whether it
has been discussed as an
option in any team
meeting of a student with
a significant disability
and/or who has failed the
standard MCAS.
By February 21, please submit
a description of the MCAS
Alternative and whether it will
be discussed in team meetings
of any student who has failed
the standard MCS.


7.3
State/District
Wide
Assessments
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

Documentatio
n Review
28.09(9)(d)
Holden School also needs
to provide written
information on the
alternate assessment to its
parents.
Holden School has not
provided documentation
of attendance at annual
MCAS trainings.
7
By February 21, please provide
evidence that parents will be
informed of the alternate
assessment and evidence that
school personnel have or will
attend MCAS trainings.
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
28.04 and
28.09(8)
8.2
Implementation
of Related
Services
28.04 and
28.09(8)
8.4
Current IEP &
Student Roster
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
A few students have
expired IEP’s and do not
have meetings scheduled
until several months after
the IEP expiration date.
By February 21, please provide
the Department with a revised
IEP and student roster. Provide
a written explanation of why
students TC and JD had
meetings several months after
the expiration of their IEP’s.


8.1
Implementation
Educational
Services
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

Documentatio
n Review
Holden School has specified
how the relevant educational
services are implemented for
its students.

Documentatio
n Review
Holden School submitted a
plan for how it would provide
for the related services in this
criterion should a student
need these services
Documentatio
n Review and
Staff
Interviews

28.09
8
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


8.8
IEP Progress
Reports

Documentatio
n Review
8.10
IEP- Less
Restrictive
Placement

Documentatio
n Review and
Staff
Interviews
28.09(9(c)
8.11
IEP Transition
Planning
34 CFR
300.347(b)(1)(2)
9.3
Runaway
Students
18.03(10)
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Documentatio
n Review and
Staff
Interviews

Documentatio
n Review and
Staff
Interviews
Progress reports include
progress towards annual
goals and include a
description of the student’s
classroom performance.
Holden School has a written
policy that addresses
students’ ability to maximize
opportunities to gain capacity
to return to a less restrictive
environment.
Holden School works with
the responsible school district
to ensure that student IEP’s
include appropriate transition
planning for students.
Holden School has recently
revised its runaway policy to
more accurately reflect the
appropriate response relevant
to its student population.
9
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
Implementation Status
of Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation


9.5
3-5 Day
Suspensions
18.05(6)
10.1
Student:Teacher
Ratios
28.06(6)(d)&(g)
28.09(7)(e)
10.2
Age Range
28.06(6)(f)
10.4



Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Documentatio
n Review
Documentatio
n Review and
Classroom
Observations
Documentatio
n review
Holden School has developed
and implemented a 3-5 day
suspension policy that
complies with appropriate
state regulations.
Holden School is in full
compliance with the required
student/teacher ratios.
The instructional grouping in
all classrooms does not differ
by more than 48 months.
Not Applicable
Student: Child
Care Ratios
28.09(7)
18.01(2)
10
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
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

Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting


11.1
Personnel Policies
28.09(7)
28.09(11)(a)
18.05(11)
11.3
Educational
Administrator
Qualifications
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Personnel
Records and
Documentatio
n Review
Holden School has developed
personnel policies that
include all required criteria.

Documentatio
n Review and
Staff
Interviews
28.09(7)(a)
603 CMR
44.00 and 44.04
11
The current Educational
Administrator does not
hold the appropriate
license or waiver for the
Educational Administrator
position. The current
“Supervisor/Director”
waiver does not satisfy the
requirements of this
position.
By February 21, the school
must submit a “Special
Educational Administrator”
waiver for the Educational
Administrator and must send
transcripts of all graduate
courses taken that show
“substantial compliance”
towards receiving licensure as
an Educational Administrator.
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


11.4
Teachers
Special
Education
Teachers and
Regular
Education
Teachers

Documentatio
n Review and
Staff
Interviews
Holden School teaching staff
have the appropriate teaching
license or waiver to meet the
needs of the student
population.
Documentatio
n Review
All related services staff are
appropriately certified.
Documentatio
n Review
Holden School maintains a
master list of all staff.
28.09(7)(b)(c)
18.05(11)(f)
11.5
Related Services
Staff
28.09(7)(d)
11.6
Master Staff
Roster
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified


28.09(7)
12
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
Implementation Status
of Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation


11.7
Job Descriptions
18.05(11)(d)
11.8
Salary Ranges
18.05(11)(e)
11.9
Organizational
Structure
28.09(7)
28.07(c)
11.11
Supervision of
Students

Documentatio
n Review
Holden School has written
job descriptions for all staff
positions.

Documentatio
n Review
Holden School has written
salary ranges including
benefit coverage for each
employee.
Documentatio
n Review
Holden School’s
organizational structure
provides for the efficient and
effective operation of the
school.
Holden School has developed
a plan for the appropriate
supervision of its students.


Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Documentatio
n Review
28.09(7)
13
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
Implementation Status
of Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation


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;
NCLB: Title X,
Part C, Sec. 721;
Mass. Const.
amend. art 114;
M.G.L. c. 76, s. 5;
603 CMR 26.06

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Documentatio
n Review and
Observation
Holden School provides
equally and in a
nondiscriminatory manner all
extracurricular activities
including participation in
sports.
14
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
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

Documentatio
n Review
Holden has a written plan for
staff orientation that
describes how newly hired
staff are provided training
when hired mid-year.

Documentatio
n review
Holden School has developed
and implemented a written
plan and calendar for its
annual in-service training that
includes intern and
volunteers. The medication
training is given by a
registered nurse,.
18.05(11)(g)
12.2
Annual InService Training
Plan and
Calendar
28.09(7)(f)
18.05(11)(h)
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The written plan
submitted does not
include the time, date and
name of the trainers for
staff orientation.
By February 21, please provide
the Department with a written
plan for staff orientation that
includes all required
information.


12.1
Staff Orientation
Training
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
15

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


13.3
Comparability of
Facilities

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Interviews
and Facilities
Observation
Holden School does not
provide separate facilities for
members of any specific
group.
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)
16
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
Implementation Status
of Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation

Interviews
and
Observations

Observation
Holden School currently has
a library and a resource room
sufficient to meet the needs
of its students.

Documentatio
n Review and
Staff
Interviews
Holden School has developed
a written plan for involving
parents, however it needs to
include a formal Parent
Advisory Group meeting at
some point during its other
offerings to parents.
18.04(8)
13.7
Library/Resourc
e Room
18.04(6)(b)
15.1
Parental
Involvement and
Parents’
Advisory Group
18.05(4)(a)
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
Holden School has been
unable to raise the funding
necessary to follow
through with its plan to
make the school fully
accessible for students
with limited mobility.
By February 21, Holden School
must develop a plan and
timetable for making the school
accessible to students with
limited mobility.


13.4
Physical
Facility/Architec
tural Barriers
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
17
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



15.3
Information to be
translated into
Languages other
than English
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Documentatio
n Review and
Interviews
Holden school ensures that
parents with limited English
language skills receive
general school
announcements and notices
in the primary language of
the home.
Title VI; EEOA:
20 U.S.C.
1703(f); M.G.L.
c. 76, s. 5; 603
CMR 26.02(2)
18
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
Implementation Status
of Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation


15.8
Registering
Complaints
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)

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Documentatio
n Review
Holden School has provided
parents and students with a
set of written procedures that
may be used for registering
complaints regarding the
students education and also
has provided written
complaint procedures for
students and employees
alleging sex and/or disability
discrimination.
19
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
Implementation Status
of Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation


16.1
Health Care
Policy and
Procedure
Manual
18.05(9)(d)
16.5
Administration
of Medication
18.05(9)(f)
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Documentatio
n Review
Holden School has a health
care manual that is approved
by a physician.

Documentatio
n Review
Holden School ensures that
there is annual written
authorization from parents in
order to dispense medication
to the relevant students.
20
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Criterion
Number
and
Topic
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
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
Annual consents including
restraint consent are not
consistently maintained in
the student records.
By March 15, Holden School
will submit a student roster that
verifies that current, annual
consents are in each student
record.


18.2
Student Records
28.09(10)
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

Documentatio
n and Student
Record
Review
MGL c. 71, s.
34H
603 CMR 23.00
Family
Educational
Rights and
Privacy Act
(FERPA)
21