Massachusetts Department of Elementary and Secondary Education 75 Pleasant Street, Malden, Massachusetts 02148 Telephone: (781) 338-3700 TTY: N.E.T. Relay 1-800-439-2370 December 11, 2008 Ms. Nancy E. Rosoff, Executive Director Little People’s School, Inc. Learning Prep School 1507 Washington Street W. Newton, MA 02465 Re: Mid-cycle Review Dear Ms. Rosoff: Enclosed is the Mid-cycle Review for Learning Prep School. 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 October 5, 2006. 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 Elementary and Secondary Education found certain noncompliance issues to be resolved, another was partially corrected and a new issue was 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 June 8, 2009. 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 January 9, 2009. Page 1 of 2 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 781-338-3723. Sincerely, Mary K. Howard, Program Review Follow-up Chairperson Program Quality Assurance Services Darlene Lynch, Director Program Quality Assurance Services c: Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education Encl.: Follow-up Monitoring Report Provisional Private School Approval Certificate, Expiration Date: June 8, 2009 Page 2 of 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION PRIVATE SCHOOL MID-CYCLE PROGRAM REVIEW Little People’s School, Inc. Learning Prep School ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Action Plan Submitted on November 24, 2006 Progress Reports Submitted on Feb. 12, May 29, June 21, 2007 Onsite Visit Conducted on November 5 and 6, 2008 Date of this Report: December 11, 2008 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 Mid-cycle Review Criteria Little People’s School, Learning Prep Program Review Mid-cycle Report December 11, 2008 Page 1 of 10 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 2.2 Approvals, Licenses, Certificates of Inspection Documentation and Student record review Not applicable Learning Prep School has current licenses, approvals and certificate of inspections by all required state and local agencies. Learning Prep is a day school program and therefore, is not required to obtain a license from EEC. 102 CMR 3.00 (Residential Schools only) 8.4 Program Modifications and Support Services for Limited English Proficient Students Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance 18.04(1); 28.09(2)(b)(5); 28.09(5) (b); 28.09(6) (b, c) 2.3 EEC Licensure Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation review Learning Prep has a policy for Program Modifications and Support Services for Limited English Proficient Students that meets all current requirements. M.G.L. c. 71A; Little People’s School, Learning Prep Program Review Mid-cycle Report December 11, 2008 Page 2 of 10 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 Title VI Documentation review Learning Prep has on file a current IEP for each MA enrolled student that has been issued by the responsible public school district, consented to and dated by student’s parent (or student when applicable). Documentation review Learning Prep submitted documentation that it has at least one designated educational administrator who is appropriately licensed. 8.5 Current IEP & Student Roster 28.09(5)(a) 11.3 Educational Administrator Qualifications 28.09(5)(a); 28.09(7)(a); 603 CMR 44.00 11.4 Teachers (Special Education Teachers and Regular Education Documentation review Not all teachers on the submitted Special Education and Regular Education Roster were appropriately licensed. Additionally, the Department is unable to Little People’s School, Learning Prep Program Review Mid-cycle Report December 11, 2008 Page 3 of 10 Learning Prep must submit an updated master staff roster indicating that all teachers are licensed or have been granted waivers. Submit by February 13, 2009. 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 verify that all teaching positions have been approved. (Please see 11.6.) 18.05(11)(f); 28.09(5)(a); 28.09(7)(b, c); 34 CFR 300.321 Documentation review Leaning Prep submitted a current Related Services Staff roster and documentation that staff providing or supervising the provision of related services are appropriately certified, licensed or registered in their professional areas. Documentation review; Interviews Learning Prep submitted a master staff roster, however the Department was not able to verify appropriate positions were filled since they did not submit the last approved ESE program budget. 28.09(7)(d) 11.6 Master Staff Roster 28.09(7) Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Teachers) 11.5 Related Services Staff Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified PLEASE NOTE the Follow-up action steps described under “Comments Regarding Corrective Learning Prep must submit a program budget that reflects Little People’s School, Learning Prep Program Review Mid-cycle Report December 11, 2008 Page 4 of 10 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 Action Plan Implementati on that are needed in this regard. 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 the current staffing patterns and includes the current program costs as paid by funding sources. Once approved, Learning Prep will be held accountable to the positions of staff as indicated in the full time equivalents of each UFR position on the budget. Learning Prep must also submit an updated staff roster that includes all requirements as specified on the master staff roster form so that the Department can then verify the programmatic need of the positions approved. The budget and master staff roster must be submitted to the Department not later than February 13, 2009. Little People’s School, Learning Prep Program Review Mid-cycle Report December 11, 2008 Page 5 of 10 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 Identified Areas of Non-Compliance During 2006 Program Review or Other Areas of Concern 3.1(a) Contents (Now 15.8) 5.2(a) Contracts Policy and Procedure Manual review Learning Prep submitted documentation and has on file a copy of the policy for registering complaints and grievances for parents, students and employees that contain all required elements. Policy and Procedure Manual Learning Prep submitted documentation that its contracts with school systems now include a statement that allows the placing school district and/or the Department to conduct unannounced visits. Sample contract 8.2 Implementatio n-Related Services Policy and Procedure Manual review Learning Prep submitted a written description of how it would provide services to a visually impaired student or a deaf/hard of hearing student should a student with these disabilities be admitted. Little People’s School, Learning Prep Program Review Mid-cycle Report December 11, 2008 Page 6 of 10 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 8.8 IEP – Progress Reports 9.1 Policies and Procedures for Behavior Management 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 Learning Prep has developed a process to include student progress towards reaching the annual goal(s) set in the IEP; however, this process is being initially implemented in the 200809 school year and therefore progress reports are not currently completed or filed in student records. Learning Prep must issue progress reports that reflect the annual goals on each student’s IEP as well as student progress towards meeting those goals. Documentation and Student Record Review Documentation review Learning Prep maintains internal progress reports in each student record. Leaning Prep submitted documentation that it has a comprehensive set of policies and procedures dealing with discipline and behavior management that meet all federal and state special education requirements. Little People’s School, Learning Prep Program Review Mid-cycle Report December 11, 2008 Page 7 of 10 Learning Prep must submit to the Department progress reports for three students in the elementary school, three students in the middle school and three students in the high school. Documentation of when and to whom the reports were sent must be included. Submit by February 13, 2009. Criterion Number and Topic 9.4 Physical Restraint 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 Policy and Procedures Manual Student record review Learning Prep submitted a written policy on the use of physical restraint in accordance with the requirements of 603 CMR 46. A copy of the parent guardian annual consent form was documented in each student record. 9.5 3-5 Day Suspensions Policy and Procedures Manual Learning Prep submitted a copy of its written policy on suspension procedures that contains all required elements. 9.6 10+Day Suspensions Policy and Procedures Manual Learning Prep submitted documentation that it has a written policy and procedures when suspension constitutes a change of placement which now contains all required elements. 12.2(a) Details Behavior Management Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified See 9.4 Little People’s School, Learning Prep Program Review Mid-cycle Report December 11, 2008 Page 8 of 10 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 and Restraint Training 13.7 Library/Resou rce Room 15.5Parent Consent and required Notification Observation Observations revealed that Learning Prep has established a library in the Elementary and Middle School building that contains a variety of materials appropriate for the age and abilities of the students enrolled and is available to all enrolled students. They have also established a library for High School Students, which is located in the Work Study building. Both sites contain computers with library software and manuals which index the title and location of all books and resource material in the entire school. See 9.4. Little People’s School, Learning Prep Program Review Mid-cycle Report December 11, 2008 Page 9 of 10 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 15.8 Complaints and GrievancesParents, Students and Employees 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 See 3.1 (a) Little People’s School, Learning Prep Program Review Mid-cycle Report December 11, 2008 Page 10 of 10 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting