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
October 4, 2006
Robert Broudo
President and Headmaster
Landmark Schools
P.O. Box 227
Prides Crossing, MA 01965-0227
Re:
Onsite Follow-up Monitoring Report: Program Review Corrective Action Plan
Verification and Mid-cycle Review
Dear Mr. Broudo:
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 June 11, 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 February 12, 2007. 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
1
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
October 20, 2006.
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 781-338-3701.
Sincerely,
Diane L. Chadwell, Program Review Follow-up Chairperson
Program Quality Assurance Services
Darlene Lynch, Director
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
Nicholas Lopardo, Chairperson, Board of Directors
Daniel Ahearn, Local Program Review Coordinator
Encl.: Follow-up Monitoring Report
Provisional Private School Approval Certificates, Expiration Date: February 12, 2007
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
PRIVATE SCHOOL MID-CYCLE PROGRAM REVIEW
Landmark School, Inc.
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION
Action Plan Submitted on August 1, 2003
Progress Reports Submitted on February 18, 2004 and August 2, 2004
Onsite Visit Conducted on May 1 and 2, 2006
Date of this Report: October 2, 2006
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s)
of Verification

1.3
Program’s
Curriculum
28.09(9)
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
Landmark School
provided a description of
its curriculum but did not
provide a description of
the general types of staff
qualifications. The
school’s policy regarding
the awarding of diplomas
must be included in the
description.
Submit a description of the
general types of staff
qualifications that have been
established to meet all special
education and related services
included in students’ IEPs and
describe the school’s policy
regarding awarding diplomas to
the Department by December
15, 2006.

Documentation

Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 1 of 22
Criterion
Number
and
Topic
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented
Method(s)
of Verification

2.2
Approvals,
Licenses,
Certificates of
Inspection
28.09 (2)(b)4-5
28.09(5)
28.09(6)
18.04(1)
102 CMR 3.06
(4)(b)
2.3
EEC Licensure
(Not Applicable
to Day Schools)
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

While Landmark School
provided evidence of
current licenses, approvals
and certificates of
inspection by state and
local agencies, it did not
provide evidence of
current health safety
inspections of its food
services facilities.
Submit evidence of current
health safety inspections to the
Department by December 15,
2006.

While at the time that
Landmark School
submitted its reapproval
package to the Department
it had a current, full
license from the
Department of Early
Education and Care (EEC)
to operate as a residential
school; this license
expired on November 9,
2005.
Submit evidence of current
EEC licenses to the Department
by December 15, 2006.

Documentation
3.1
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 2 of 22
Criterion
Number
and
Topic
Policies &
Procedures
Manual
28.09(11)(b)
3.2
Health Care
Manual
18.05 (9)(d)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented



4.2
Public
Information and
Postings
28.09(6)(a,b,
c,d,e)
28.09(2)(b)(4)
4.4
Advanced
Notice of
Program/
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
Landmark School does not
post emergency
evacuation routes in all
classrooms.
Post the emergency evacuation
route in all classrooms and
“main areas” of the school.
Submit a description of the
current status of these posting
to the Department by
December 15, 2006.

Documentation
Landmark School maintains a
policies and procedures manual
and has a procedure to provide
notice to parents of enrolled
students annually that copies of
the policies and procedures are
available upon request.
Documentation
Landmark School has a recently
revised Health Care Manual,
which includes all of the
required areas of this criterion.

Facility tour

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Documentation and
interviews
Landmark School has recently
submitted three (3) written
notices (Form 1) of substantial
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 3 of 22
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/proce-
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
Landmark School does not
have a procedure to ensure
that IEPs are signed by
students when they turn
age 18 years. (See
criterion 15.7 below.)
Develop a procedure to ensure
that the student and/or other
appropriate persons sign the
IEP when the student turns age
18 years.

Facility Change
28.09(5)(c)
4.5
Immediate
Notification
18.03(10)
18.05(7)
28.09(12)
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
change to the Department
regarding building changes
planned by the School.
Landmark School administrators
are aware of this requirement
and provide notification as
necessary.

Documentation
Landmark School’s policy and
procedures regarding
notifications as revised in May
2006 includes all areas stated on
the Department’s Form 2 that
require immediate notification.
partial
Student
records and
interviews
Landmark School has policies
and procedures that describe the
roles and responsibilities of the
program and its staff as well as
general communications and
procedures to collaborate with
sending school districts to
ensure that requirements of this
criterion are met. Record
reviews indicated that the
partial
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 4 of 22
Submit a copy of the updated
procedures to the Department
by December 15, 2006.
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
Documentation submitted
by the School indicates
Provide a plan to implement the
state physical education

dures for
Coordination/
Collaboration
with Public
School Districts
School collaborates with the
sending district to ensure that
transition discussions and ageof-majority- discussions are
documented in student IEPs.
28.06(2-3)
28.09(9)(c)&(d)
28.09(2)(b)7
Federal
Regulations:
300.349 and
300.400-.401
6.1
Daily
Instructional
Hours
603 C.M.R.
27.00
6.1(a)
Physical
Education

Documentation
Documentation and
Landmark School provides an
average annual minimum of five
hours per school day for
elementary and middle school
students and five and a half
hours per school day for
secondary students.

Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 5 of 22
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

Requirements
6.2
School-to-work
(Instructional
hours)
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
that the School does not
provide physical
education as a required
subject at all grade levels.
The School requires only
one year of physical
education at the high
school level. Please note
that Massachusetts
students must have
physical education every
year in order to receive a
diploma from their local
school district. Please
review the DOE
Commissioner’s memo of
April 2000 at
http://www.doe.mass.edu/
news/news.asp?id=649
regarding clarification of
the Department’s physical
education requirement.
requirement at all grade levels.

interviews
NA
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Interviews
Landmark School does not
currently have a School-to-Work
program.
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 6 of 22
Submit a copy of plan to the
Department by December 15,
2006.
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

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)
6.5
Early Release of
High School
Seniors
603 CMR 27.05
7.1
Curriculum
Frameworks
28.09(9)(b)
NA
NA
Landmark School does not
enroll kindergarten age students.

Documentation
Landmark School is approved as
a ten month school program and
is in session 180 school days.

Documentation
Landmark School releases its
senior class six (6) days prior to
the regular scheduled closing
date for the School, which is
within the requirements.

Documentation
Landmark School has a
curriculum that reflects the
Massachusetts Curriculum
Frameworks. The School has
taken steps to provide all
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 7 of 22
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
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
Landmark School did not
submit information about
how it would work with a
sending school district to
implement necessary
program modifications
and support services to
serve limited English
proficient (LEP) students
who need special language
assistance.
Develop a plan to ensure that
effective program
modifications and support
services will be implemented
for LEP students when needed.

students with essential learning
opportunities that prepare
students to reach the state
graduation standards.
7.3
State/District
Wide
Assessments
28.09(9)(d)
8.4
Program
Modifications
and Support
Services for
Limited English
Proficient
Students
Title VI: 42
U.S.C. 2000d;
34 CFR
100.3(a), (b);
EEOA: 20
U.S.C. 1703(f);
MGL c. 71, s.

Documentation and
interviews
Documentation
Landmark School has written
procedures outlining how the
School will ensure that all
students participate in state
and/or district wide assessments.

Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 8 of 22
Submit a copy of the plan to the
Department by December 15,
2006.
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

38Q1/2; 603
CMR
28.03(3)(a);
MGL c. 71A,
ss. 2(e), 4;
603 CMR
14.04; MGL c.
76, s. 5’603
CMR 226.03
8.9
IEP – Revisions
& Changes
34 CFR 300
8.11
IEPTransition
Planning
34 CFR
300.347(b)(1)
34 CFR

Documentation and
interviews
Landmark School has policies
and procedures to notify the
responsible school district and
parents whenever the IEP needs
to be revised to reflect a change
in goals, placement, or a return
to a less restrictive setting.

Student
records
Landmark School collaborates
with school districts to ensure
that transition planning
discussions are documented in
the student record, and that,
where appropriate, transitionrelated IEP goals are contained
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 9 of 22
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

Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
in IEPs.

Documentation
18.03 (10)
9.4
Restraints
18.05 (5)
Landmark School has a written
policy and procedure relative to
runaways that includes a
statement that the Department
will be notified when a student
runs away and who is
responsible for this notification.

Documentation and
interviews
603 CMR 46.00
9.6
Suspensions
Joint
responsibilities
of the public/
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

300.347(b)(2)
9.3
Runaway
Students
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Documentation
Landmark School has
appropriate policies and
procedures regarding
suspensions exceeding ten (10)
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 10 of 22
Landmark School has not
provided either the
overview of their restraint
policy for all staff during
the first month of the
school year or provided
ongoing intensive training
for designated “restraint
resource people.”
See criterion 12.2 above.
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
Several of the
instructional groupings at
both the
elementary/middle school
and the high school
exceed the ratio of eight
students to one teacher
without an aide.
Submit block schedules that
clearly display the numbers and
initials of students, and the
numbers and initials of teachers
and teacher assistants in all
classrooms for all periods
throughout the day indicating
the appropriate staff to student
ratios.

private school
and the
responsible
school district
school days including the
required manifestation
determination that is held prior
to the determination that a
student will be suspended for
more than ten (10) days.
Federal
Requirements:
34 CFR
10.1
Student:Teacher
Ratios
28.06(6)(d)&(g)
28.09(7)(e)

Documentation and
interviews
Submit a copy of the block
schedules to the Department by
December 15, 2006.
10.4
Student: Child
Care Ratios

Documentation
Landmark Schools maintains
appropriate student to childcare
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 11 of 22
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)
18.01(2)
11.1
Personnel
Policies
28.09(7)
28.09(11)(a)
18.05(11)
11.3
Educational
Administrator
Qualifications
28.09(7)(a)
603 CMR
44.00 and 44.04
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
worker ratios.

Documentation
Landmark School has written
personnel policies and
procedures that meet the
requirements of 603 CMR
28.09(7), 603 CMR
28.09(11)(a) and 603 CMR
18.05(11) including policies and
procedures for the use of
volunteers and interns.

Documentation
Landmark School has an
educational administrator to
supervise the provision of
special education services in the
school and to ensure that the
services specified in each
student’s IEP are delivered. The
educational administrator has an
appropriate license from the
Department.
11.4
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 12 of 22
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
Teachers
Special
Education
Teachers and
Regular
Education
Teachers
28.09(7)(b)(c)
18.05(11)(f)
11.4(a)
Professional
Development
Plans
28.09(7)(b)(c)
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 files did not
include Professional
Development Plans for
each professionally
licensed teacher.
Documentation submitted
by the School indicated
that the School has
developed a plan to
develop Professional
Development Plans with
all licensed teachers by
December 15, 2006.
Submit a roster of
professionally licensed teachers
including the name of their
supervisors and the date that
their Professional Development
Plan was approved by their
supervisor to the Department
by December 15, 2006.

Landmark School did not
Submit a copy of the DOE and

Documentation,
interviews
and
personnel
files
Landmark School ensures that
all teaching staff are
appropriately certified or on
approved waivers issued by the
Department of Education.
18.05(11)(f)
11.5
Related
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 13 of 22
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 Staff
28.09(7)(d)
submit copies of the
licenses of their
speech/language
pathologists.
state Board of Licensure
licenses for the speech
language pathologists.
Submit a copy of the required
licenses to the Department by
December 15, 2006.
11.6
Master Staff
Roster
28.09(7)

Documentation
Landmark schools provided a
master staff roster for the day
and residential schools that
included all required
information.

Documentation
Landmark School has written
job descriptions for all staff
positions.
11.8
Salary Ranges
18.05(11)(e)

Documentation
Landmark School has a salary
range covering all positions.
11.9
Organizational
Structure

Documentation and
Landmark School has an
organizational structure that
11.7
Job
Descriptions
18.05(11)(d)
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 14 of 22
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)
28.07(c)
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),
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
provides for an effective and
efficient operation of the school,
supervision of school staff, and
supervision of students.

Documentation

Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance

interviews
11.11
Supervision of
Students
28.09(7)
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Documentation
Extracurricular activities
sponsored by Landmark School
are nondiscriminatory in that
equal opportunity is provided for
all students to participate in
intramural and interscholastic
sports and extracurricular
activities and clubs do not
exclude students based on race,
sex, color, religion, national
origin, sexual orientation,
disability, or homelessness.
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 15 of 22
Landmark Schools did not
provide a plan that
describes how appropriate
supervision is provided to
students while engaged in
school-related activity on
and off school grounds.
Submit a detailed plan for the
supervision of students.
Submit a copy of plan to the
Department by December 15,
2006.
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
While Landmark School's
2005-2006 training
schedule includes all
required trainings, the list
of mandated staff trainings
included in Landmark
School’s Policy and
Procedures Manual does
not include training
relative to the School’s
runaway policy or civil
rights responsibilities.
Interviews indicated that
Landmark School does
provide some restraint
training, but it does not
Revise the training policy and
procedures to include these two
areas. Submit a copy of the
revised policy to the
Department by December 15,
2006.

(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
12.2
Annual InService
Training Plan
and Calendar
28.09(7)(f)
18.05(11)(h)

Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 16 of 22
Submit a plan to the
Department by December 15,
2006 to provide training for
staff pursuant to state restraint
regulation. Please be aware that
state regulations require that
staff are trained regarding
restraint during the first month
of the school year and that a
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

provide restraint training
in the manner required by
state regulations.
number of staff receive
intensive training annually.
Submit a list of staff who
receive the intensive training.
Submit a list to the Department
by December 15, 2006 of all
restraint trainings that have
occurred indicating when the
training was provided and the
target audience. Also see
criterion 9.4.
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October 4, 2006
Page 17 of 22
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


Facility tour
Where Landmark Schools
provides separate facilities for
members of a specific group,
those facilities are comparable to
those offered other students in
the program.

Documentation
Landmark School has a written
plan for involving parents and
has a Parent Advisory Group
that advises the school on
matters pertaining to the
education, health and safety of
the students in the program.
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)
15.1
Parental
Involvement
and Parents’
Advisory Group
18.05(4)(a)
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
15.3
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October 4, 2006
Page 18 of 22
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
Information to
be translated
into Languages
other than
English
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented


Method(s)
of Verification
15.8
Registering
Documentation and
interviews
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
Landmark School does not
have a process to ensure
that students sign
permission for the district
or School to continue
providing special
education services when
they have turned 18 years
of age. (See criterion 5.2
above.)
Develop a process to ensure
that all IEPs are signed by the
student when they become age
18 years.
Landmark Schools indicated that
it will provide translations in the
home language for parents who
whose primary language is not
English when needed and
identified the staff who will be
responsible for implementation
of this policy

Documentation, student
records, and
interviews

Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Title VI;
EEOA: 20
U.S.C. 1703(f);
M.G.L. c. 76, s.
5; 603 CMR
26.02(2)
15.7
Consent at Age
of Majority
28.07(5)
Comments Regarding
Corrective Action Plan
Implementation
Documenta-
Landmark School has written
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October 4, 2006
Page 19 of 22
Submit a copy of the new
process to the Department by
December 15, 2006.
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

Complaints

tion
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)
16.4
Emergency First
Aid
18.05(9)(e)
16.9
Students with
Comfort
Care/Do Not
Resuscitate
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Facilities
tour

Documentation
procedures that may be used to
register complaints regarding the
student’s education and care at
the school and a grievance
procedure revised May 2006
providing for the prompt and
equitable resolution of
complaints alleging
discrimination based on sex or
disability.
Landmark School has all
emergency numbers posted by
the phone in each of its
dormitories.
Landmark School has a written
policy for the care of a child
with a DNR order.
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October 4, 2006
Page 20 of 22
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
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

Orders
16.10
Meningococcal
Disease and
Vaccination

Documentation
Landmark School has a written
policy regarding meningococcal
disease and required
vaccination.
MGL, Chapter
76, s.15D
105 CMR
220.700
18.2
Student Records
28.09(10)
Student
records

MGL c. 71, s.
34H
603 CMR 23.00
Family
Educational
Rights and
Privacy Act
(FERPA)
Landmark Schools Program Review Mid-cycle Report
October 4, 2006
Page 21 of 22
Student record face sheets
do not include a place for
the primary language of
the parent, educational
surrogate contact
information, notation of
allergies and/or any other
medical condition
affecting the student’s
well-being, or information
specific to the student
regarding the handling of
medical emergencies.
Revise the student record face
sheet to include all required
elements.
Submit a copy of the revised
face sheet to the Department by
December 15, 2006.
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October 4, 2006
Page 22 of 22