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 October 31, 2011 Ms. Joan Wallace-Benjamin, Executive Director Home for Little Wanderers Southeast Campus Day and Residential Programs 271 Huntington Avenue Boston, MA 02130 Re: Mid-cycle Review and Verification of previous Program Review Corrective Action Plan Dear Ms. Wallace-Benjamin: Enclosed is the Department of Elementary and Secondary Education’s (“Department”) Mid-cycle Report based upon the Mid-cycle review conducted in your private school program in August 2011. 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 May 16, 2008. This report also includes a report on the status of implementation for new state or federal special education requirements enacted since your program’s last Program Review. While the Department 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 February 3, 2012. The reasons for the “Provisional Approval” are clearly indicated on the attached Mid-cycle Review Report. 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 these requirements 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 new special education requirements. Please provide the Department with your written assurance that the Department's requirements Page 1 of 2 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 November 14, 2011. Please be advised that the attached Department Approval Certificate must be conspicuously posted in a public place within the program as required by 603 CMR 28.09. 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 781-338-3721. Sincerely, Audrey Macmillan, 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 John Hailer, Chairperson, Board of Directors Kaitlyn Brosnan, Program Director Encl.: Mid-cycle Review Report Provisional Private School Approval Certificate, Expiration Date: February 3, 2012 Page 2 of 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION PRIVATE SCHOOL MID-CYCLE REVIEW HOME FOR LITTLE WANDERERS SOUTHEAST CAMPUS Day and Residential Programs MID-CYCLE REVIEW REPORT Previous Program Review Corrective Action Plan Submitted on 6/30/08 Progress Reports Submitted on 8/4/08, 9/30/08, 12/10/08, 2/27/09 Mid-cycle Onsite Visit Conducted on 8/22/11 Date of this Report 10/31/11 Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 1 of 28 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 2.2 Approvals, Licenses, Certificates of Inspection Documentation Observation Southeast Campus has all current approvals, licenses and certificates of inspection as required. Documentation Observation Southeast Campus has a current license issued by the Department of Early Education and Care as required. 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 programs only) Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 2 of 28 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic 8.5 Current IEP & Student Roster 28.09(5)(a) 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 Student Record Review A review of student records confirms Southeast Campus has on file a current IEP for each enrolled Massachusetts student that has been issued by the responsible public school district and consented to and dated by the student’s guardian. Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 3 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 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 At the time of the 2008 Program Review two Southeast Campus teachers were not properly licensed and did not have approved waivers. By January 3rd, 2012 Southeast Campus must submit to the Department an updated Teacher Roster, including the submission of licenses and waivers for all teachers. 11.4 Teachers (Special Education Teachers and Regular Education Teachers) Comments Regarding Corrective Action Plan Implementation Documentation Staff Record Review The Teacher Roster and copies of licenses that Southeast Campus submitted for the Midcycle demonstrates that only three out of six teachers are licensed in the appropriate grade level and subject area in which they are teaching. 18.05(11)(f); 28.09(5)(a); 28.09(7)(b, c); 34 CFR 300.321 Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 4 of 28 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 Southeast Campus submitted ELAR sheets for the remaining three teachers reflecting requests for waivers in the appropriate grade level and subject area in which they are teaching; these requests all indicate “Ready for Review”. Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 5 of 28 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic 11.5 Related Services Staff Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification 28.09(7) Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation Staff Record Review Southeast Campus submitted a current Related Services Roster and license and/or Massachusetts State Board of Registration license that shows all Related Services Staff are appropriately certified, licensed or registered in their professional areas as required. Documentation Staff Record Review Interview Southeast Campus submitted a current Master Staff Roster that includes all required elements for each position and corresponds to the last approved Program Budget as required. 28.09(7)(d) 11.6 Master Staff Roster Comments Regarding Corrective Action Plan Implementation Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 6 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic 19 Anti-Hazing M.G.L. c. 269, §§ 17 through 19 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 Documentation Student Record Review Interview Southeast Campus submitted an anti-hazing disciplinary policy, as well as evidence of distribution to all its students and training of the policy. Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 7 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Identified Areas of Non-Compliance from the Previous Program Review or Other Areas of Concern 2.2 Approvals, Licenses, Certificates of Inspection Documentation 18.04(1); 28.09(2)(b)(5); 28.09(5)(b); 28.09(6)(b, c) 4.5 Immediate At the time of the 2008 Program Review Southeast Campus did not submit a copy of its local school committee approval. A review of documentation conducted at the time of the Mid-cycle Review indicates that Southeast Campus is now in possession of local school committee approval as required. Documentation At the time of the 2008 Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 8 of 28 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 Program Review Southeast Campus’ Policies and Procedures Manual did not contain an Immediate Notification section. Notification 18.03(10); 18.05(7); 28.09(12)(a,b) A review of documentation conducted at the time of the Mid-cycle Review indicates Southeast Campus currently has a policy in place regarding Immediate Notification. 5.1 Student Admissions 28.09(11); 18.05(1)(b)(117); 18.05(2); Documentation At the time of the 2008 Program Review the program’s Policies and Procedures Manual did not contain a written admissions policy that included the following: the Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 9 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 18.05(3)(c) Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified type of services provided, a description of parents’ rights, activities related to daily living skills, any specific treatment strategy employed by the facility, visiting hours and other procedures related to communication with students and the facility, the name and telephone number of a staff person whom the parents may contact on an ongoing basis, a description of a procedure which the parents or student may use to register complaints regarding the student’s education and care at the facility, and a copy of the approved calendar. Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 10 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 A review of documentation conducted at the time of the Mid-cycle Review indicates Southeast Campus currently has an Admissions policy that includes all required criteria. 6.4 School Days Per Year 603 CMR 27.05(2); 28.09(9)(a) Documentation Observation At the time of the 2008 Program Review documentation indicated that Southeast Campus had shortened the school day during the summer months without Department approval. A review of documentation and comprehensive classroom observations conducted at the time of the Mid-cycle Review Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 11 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 indicates Southeast Campus is adhering to an approved schedule and meeting the required number of instructional hours. 8.4 Program Modifications and Support Services for Limited English Proficient Students M.G.L. c. 71A; Title VI Documentation At the time of the 2008 Program Review Southeast Campus’ Policies and Procedures Manual did not include written policies that addressed the requirements of providing students with sheltered content instruction and additional instruction in English as a Second Language, as well as students being afforded the same opportunity to access and participate in the Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 12 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 program’s services, activities and other benefits as all other students. A review of documentation conducted at the time of the Mid-cycle Review indicates Southeast Campus currently has developed a policy that addresses all required provisions for Limited English Proficient students. 9.1(a) Student Separation Resulting from Behavior Management Documentation At the time of the 2008 Program Review Southeast Campus’ Policies and Procedures Manual did not contain written policies and procedures regarding student Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 13 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 separation. 18.05(5)(i); 18.05(6, 7); 46.02(5)(b) 9.6 10+Day Suspensions 34 CFR 300.530 – 537 18.05(7) Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified A review of documentation conducted at the time of the Mid-cycle Review indicates Southeast Campus currently has in place a policy regarding the separation of a student. Documentation At the time of the 2008 Program Review Southeast Campus’ Policies and Procedures Manual did not contain written procedures addressing requests that the student’s responsible school district reconvene an IEP Team meeting prior to a suspension that constitutes a change in Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 14 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 placement of a student with disabilities. A review of documentation conducted at the time of the Mid-cycle Review indicates Southeast Campus currently has in place a policy regarding student suspension that meets all required criteria. 9.7 Terminations 18.05(7); 28.09(12)(b) Documentation At the time of the 2008 Program Review documentation indicated that the Southeast Campus’ Policies and Procedures Manual contained provisions for planned terminations; Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 15 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 however, the written procedures did not contain the following elements: the need for an IEP review meeting and provision of notice of this meeting to all appropriate parties ten (10) days in advance of the intended date of the meeting, and the purpose of the meeting to develop a clear and specific termination plan for the student that shall be implemented in no less than thirty (30) days unless all parties agree to an earlier termination date. A review of documentation conducted at the time of the Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 16 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Mid-cycle Review indicates Southeast Campus currently has in place a policy regarding student terminations that meets all required criteria. Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 17 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic 11.5 Related Services Staff 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 Documentation Staff Record Review 28.09(7)(d) At the time of the 2008 Program Review an approved LICSW position was not filled with an individual who was properly licensed. A review of documentation and staff records conducted at the time of the Mid-cycle Review indicates all Related Services Staff are appropriately licensed and credentialed. 11.6 Master Staff Roster 28.09(7) Documentation At the time of the 2008 Program Review the full-time equivalent positions listed on the last approved Program Budget did not align with the full time equivalent positions Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 18 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 At the time of the 2008 Program Review the Southeast Campus new staff orientation training By January 3rd, 2012 Southeast Campus must submit to the Department: o A list of all new staff indicated on the Master Staff Roster, with no explanation provided to explain the discrepancies. A review of documentation conducted at the time of the Mid-cycle Review confirms that Southeast Campus’ revised Master Staff Roster now corresponds to the last approved Program Budget as required. 12.1 New Staff Orientation and Training Staff Record Review Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 19 of 28 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 was not always documented in individual staff files. 18.05(11)(g, i); 28.09(7)(f) A review of staff records at the time of the Mid-cycle Review indicates Southeast Campus continues to inconsistently document new staff orientation training in individual staff files. Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 20 of 28 o hired since September 2011; Sign-in sheets for all orientation and trainings conducted to date during the 2011-2012 school year. By April 2nd, 2012 Southeast Campus must submit to the Department: o A list of all new staff hired since January 2012; o Sign-in sheets for all orientations and trainings conducted from the date 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 Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting last Corrective Action submission. 12.2 InServices Training Plan and Calendar Staff Record Review 28.09(7)(f); 28.09(9)(b); 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; At the time of the 2008 Program Review required in-service training topics that must be provided annually to all staff were not always documented in individual staff files. A review of staff records at the time of the Mid-cycle Review indicates Southeast Campus staff are not consistently receiving Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 21 of 28 By January 3rd, 2012 Southeast Campus must submit to the Department: o A Training Calendar for the 2011-2012 school year; o A current Master Staff Roster; o Sign-in sheets for all trainings conducted to date during the 2011-2012 school year. By April 2nd, 2012 Southeast Campus must 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 18.04(8); Section 504: 29 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting annual in-service training an average of at least two hours per month. submit to the Department: o A Training Calendar for the 2011-2012 school year; o A current Master Staff Roster; o Sign-in sheets for all trainings conducted from the date of the last Corrective Action submission. 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/Archit ectural Barriers Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Observation At the time of the 2008 Program Review Southeast Campus had four areas (the library and classroom building, another building housing two classrooms, the time-out room, and the building housing the Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 22 of 28 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 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. 114 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified nurse) that were not accessible to students with limited physical mobility. Southeast Campus submitted a plan and timetable for two of the four buildings to become accessible to students with limited physical mobility. A tour of the facilities and comprehensive observations conducted at the time of the Mid-cycle Review confirms that Southeast Campus has made necessary modifications to its facilities to accommodate students with limited physical mobility. Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 23 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic 15.1 Parental Involvement and Parents’ Advisory Group 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 Documentation At the time of the 2008 Program Review Southeast Campus’ Policies and Procedures manual did not contain a written plan for involving parents. 18.05(4)(a) A review of documentation conducted at the time of the Mid-cycle Review indicates that Southeast Campus now has a policy in place addressing the various ways in which parents are encouraged to be involved in the program. 15.5 Parent Consent and Required Documentation Student Record Review At the time of the 2008 Program Review parent consents were not being Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 24 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 obtained annually for restraints. Notification 18.05(5)(c); 18.05(8); 18.05(9)(f)(1); 18.05 (9)(j); M.G.L. c. 71, § 32A 16.3 Nursing 18.05(9)(b) M.G.L c. 112 M.G.L. c. 71, §§ 53, 53A, and 53B Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation Observation A review of documentation and student records conducted at the time of the Mid-cycle Review confirms Southeast Campus is currently obtaining all required consents on an annual basis. At the time of the 2008 Program Review Southeast Campus’ Health Care Manual did not include information regarding the nurse’s shift, schedule, or an explanation of how the nurse’s availability is sufficient for the needs of the student population. Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 25 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 A review of documentation and onsite observations conducted at the time of the Mid-cycle Review confirms that Southeast Campus has revised its Health Care Manual to include information regarding the nurse’s shift, schedule, and an explanation of how the nurse’s availability is sufficient for the needs of the student population. The program’s description of nursing services is appropriate to the current needs of the student population. 16.7 Preventive Documentation At the time of the 2008 Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 26 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Health Care 18.05(9)(g) M.G.L. c. 71, § 57 M.G.L. c. 111, § 111. Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Student Record Review Program Review The Health Care Manual did not include a written plan to address the provision for each student to receive an annual comprehensive medical and dental examination. A review of student records indicated that postural and visual screenings for day students were not consistently documented in the students’ records. A review of documentation conducted at the time of the Mid-cycle Review confirms that Southeast Campus has revised its Health Care Manual Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 27 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 to include a written plan to address the provision for each student to receive an annual comprehensive medical and dental examination. In addition, a review of student records confirmed that Southeast Campus is consistently documenting postural and visual screenings for day students. Home for Little Wanderers Mid-cycle Review Report Southeast Campus October 31, 2011 Page 28 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Commonwealth of Massachusetts Department of Elementary and Secondary Education HOME For LITTLE WANDERERS A PRIVATE SPECIAL EDUCATION PROGRAM OPERATED PURSUANT TO 603 CMR 18.00 AND 28.09 SOUTHEAST CAMPUS DAY PROGRAM 900 Ship Pond Road, Plymouth, MA 02360 Program Rate Based on: 30 Students Approved Enrollment: 30 Students Day Program Summer Program Residential Program 10 month program 11 month program 12 month program APPROVED STUDENT:LICENSED EDUCATOR RATIO: 6:1 APPROVED STUDENT:LICENSED EDUCATOR:AIDE RATIO: Not Applicable APPROVAL STATUS PROVISIONAL Expires on: February 3, 2012 The current approval is a result of a Mid-cycle Review conducted in the 2010-2011 school year and the next review is scheduled for the 2013-2014 school year. AUDREY MACMILLAN, EDUCATIONAL SPECIALIST, PROGRAM QUALITY ASSURANCE SERVICES NINA M. MARCHESE, SUPERVISOR, PROGRAM QUALITY ASSURANCE SERVICES DARLENE A. LYNCH, DIRECTOR, PROGRAM QUALITY ASSURANCE SERVICES DATE ISSUED: 10/31/11 Commonwealth of Massachusetts Department of Elementary and Secondary Education HOME For LITTLE WANDERERS A PRIVATE SPECIAL EDUCATION PROGRAM OPERATED PURSUANT TO 603 CMR 18.00 AND 28.09 SOUTHEAST CAMPUS RESIDENTIAL PROGRAM 900 Ship Pond Road, Plymouth, MA 02360 Program Rate Based on: 32 Students Approved Enrollment: 32 Students Day Program Summer Program Residential Program 10 month program 11 month program 12 month program APPROVED STUDENT:LICENSED EDUCATOR RATIO: 6:1 APPROVED STUDENT:LICENSED EDUCATOR:AIDE RATIO: Not Applicable APPROVAL STATUS PROVISIONAL Expires on: February 3, 2012 The current approval is a result of a Mid-cycle Review conducted in the 2010-2011 school year and the next review is scheduled for the 2013-2014 school year. AUDREY MACMILLAN, EDUCATIONAL SPECIALIST, PROGRAM QUALITY ASSURANCE SERVICES NINA M. MARCHESE, SUPERVISOR, PROGRAM QUALITY ASSURANCE SERVICES DARLENE A. LYNCH, DIRECTOR, PROGRAM QUALITY ASSURANCE SERVICES DATE ISSUED: 10/31/11