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 November 9, 2010 Alex Michaels, Executive Director Milestones, Inc. School for Accelerated Learning Day Program 460 Totten Pond Road, Suite 300 Waltham, MA 02451 Re: Mid-cycle Review and Verification of Previous Program Review Corrective Action Plan Dear Ms. Michaels: 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 September 2010. 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. We are pleased to indicate that the Department has found your program’s approved Corrective Action Plan to be substantially implemented and effective in remedying previously identified noncompliance issues. Additionally, we have determined that your program is in substantial compliance with any new state or federal special education requirements enacted since your last Program Review. You and your entire staff are to be congratulated for your efforts in implementing all necessary improvements. Your program will now receive an updated status of “Full Approval.” This approval shall remain in effect for three (3) years and will be contingent upon continued compliance with all regulations contained within 603 CMR 28.00 “Special Education Regulations” and 603 CMR 18.00 “Program And Safety Standards For Approved Public Or Private Day And Residential Special Education School Programs.” The Department may change this approval status at any point during this three-year period if circumstances arise that warrant such a change. The Department will notify you of your program’s next regularly scheduled Program Review several months before it is to occur. At this time we anticipate the next routine monitoring visit to occur sometime during the 2013-2014 school year, unless the Department determines that there is some reason to schedule this visit earlier. Page 1 of 2 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 781-338-3713. Sincerely, Helen M. Murgida, 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 Encl.: Mid-cycle Review Report Full Private School Approval Certificate, Expiration Date: August 31, 2014 Page 2 of 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION PRIVATE SCHOOL MID-CYCLE REVIEW MILESTONES, INC. SCHOOL FOR ACCELERATED LEARNING DAY PROGRAM MID-CYCLE REVIEW REPORT Previous Program Review Corrective Action Plan Submitted on July 29, 2008 Progress Reports Submitted on September 2, 2008 and October 16, 2008 Mid-cycle Onsite Visit Conducted on September 15 and 16, 2010 Date of this Report November 9, 2010 Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Selected Approved Private School Program Mid-cycle Review Criteria Milestones, Inc. Milestones Day Program Mid-cycle Review Report November 9, 2010 Page 1 of 18 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic 2.2 Approvals, Licenses, Certificates of Inspection Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Documentation Milestones submitted all current approvals, licenses, and certificates of inspection by state and local agencies. 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 18.04(1); 28.09(2)(b)(5); 28.09(5)(b); 28.09(6)(b, c) 2.3 EEC Licensure Not Applicable Milestones is a Day Program, therefore, this criterion is not applicable. 102 CMR 3.00 (Residential Schools only) Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 2 of 18 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 Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Documentation Milestones has on file a current IEP for each Massachusetts enrolled student that has been issued by the responsible public school district and consented to and dated by the student’s parent(s). Student Records Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance 28.09(5)(a) 11.3 Educational Administrator Qualifications 28.09(5)(a); 28.09(7)(a); 603 CMR 44.00 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation Personnel Records The Educational Administrator meets the required qualifications to serve in this position. Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 3 of 18 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic 11.4 Teachers (Special Education Teachers and Regular Education Teachers) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Documentation All teaching staff have teaching licenses or current certification waivers appropriate to meet the needs of the population being served. 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 Personnel Records Interviews Observations 18.05(11)(f); 28.09(5)(a); 28.09(7)(b, c); 34 CFR 300.321 11.5 Related Services Staff 28.09(7)(d) Documentation Personnel Records The related service roster is complete and all related service providers are currently certified, licensed Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 4 of 18 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 or registered in their professional area as required. 11.6 Master Staff Roster Documentation Milestones submitted a master list of all staff for every position within the program that corresponds to the last approved Program Budget as required. Documentation Milestones Anti-Hazing policy contains all required elements and the education director has sent a copy of M.G.L. c.269 §§ 17 through 19 to every 28.09(7) 19 Anti-Hazing M.G.L. c. 269, §§ 17 through 19 Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 5 of 18 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 secondary school age student enrolled full-time, and every student group, student team, or student organization, including every unaffiliated student group, student team, or student organization, and a copy of the school program’s anti-hazing disciplinary policy approved by the program’s Board of Directors. Milestones has filed its annual report with the Department certifying its compliance with its responsibility to inform Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 6 of 18 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 student groups, teams or organization, and every full-time enrolled student, its adoption of a disciplinary policy with regard to the organizers and participants of hazing, and the hazing policy has been included in the student handbook or other means of communicating school program policies to students. Identified Areas of Non-Compliance During the Program Review or Other Areas of Concern 4.5 Immediate Documentation Milestones Policies and Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 7 of 18 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 18.03(10); 18.05(7); 28.09(12) (a, b) M.G.L. c. 71 § 3 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Procedures Manual now contains the program’s written procedures for immediate notification of serious incidents to appropriate parties. Notification 6.1(a) Physical Education Requirement Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation Milestones submitted block schedules for each classroom that indicated physical education periods for all students. Milestones also submitted a written statement that physical education is now a required subject at all grade levels for all students for the purpose of promoting the Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 8 of 18 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 physical well being of students. 8.8 IEP – Progress Reports Documentation Student Records State: 28.07(3); Federal 20 U.S.C. Chapter 33, Section 1414(d)(1)(A)( viii); 34 CFR 300.320(a)(3)(i, ii) 9.1 Policies Documentation Student records now contain copies of progress reports as well as evidence that parents and the school district receive copies of progress reports as required. Milestones’ written Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 9 of 18 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 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance behavior management procedures now include the type and range of restrictions a staff member can impose for behavior which is unacceptable, including suspension and termination. and Procedure for Behavior Management 18.03(7)(b)(2); 18.05(5, 6, 7); 28.09(11); 603 CMR 46.00; ESE Advisory on Restraint in Special Education Programs dated 12/20/05. 9.7 Terminations Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation Milestones’ written emergency termination Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 10 of 18 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(7); 28.09(12)(b) 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 policy now includes the statement that, “At the request of the public school district, the special education school shall delay termination of the student for up to two calendar weeks to allow the public school district the opportunity to convene an emergency Team meeting or to conduct other appropriate planning discussions prior to the student's termination from the special education school program” as required. Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 11 of 18 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 11.1 Personnel Policies and Procedures Manual Documentation Personnel Records Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance 18.05(11); 18.05(11)(c)(1); 28.09(7); 28.09(11)(a); M.G.L. c. 71, § 38R; ESE Advisory on CORI revised 5/7/07 12.2 In Service Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation The Personnel Policies and Procedures Manual indicated that written staff performance evaluations occur annually and copies of the written staff performance annual evaluations are now documented in all the personnel files. Staff interviews indicated that annual trainings do Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 12 of 18 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 Training Plan and Calendar Personnel Records 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; EEOA: 20 U.S.C. 1703(f); Title IX: 20 U.S.C. 1681; 34 CFR Interviews occur and review of personnel files indicated that documentation of inservice training had not been maintained prior to August 2007, but is now maintained as required. Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 13 of 18 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 106.31-106.42; M.G.L. c. 76, § 5; 603 CMR 26.00, esp. 26.07(2, 3) 15.1 Parental Involvement and Parents’ Advisory Group Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Documentation Interviews 18.05(4)(a) 15.3 Information to be translated into Languages Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Milestones’ written parental involvement and parent’s advisory group policy now clearly states who facilitates parent meetings, develops written agendas, and maintains a list of parents in attendance. Milestones submitted a written description of how the program will respond promptly to Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 14 of 18 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 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance parent/guardian requests to have important school information translated on demand, either orally or in writing. other than English Title VI; EEOA: 20 U.S.C. 1703(f); M.G.L. c. 76, § 5; 603 CMR 26.02(2) 15.5 Parent Consent and Required Notification 18.05(5)(c); 18.05(8); 18.05(9)(f)(1) Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation Student Records Milestones’ consent forms now meet the requirements of the Department. Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 15 of 18 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic 15.8 Registering Complaints and Grievances – Parents, Students and Employees 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 Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Documentation The written procedures regarding complaints and grievances contained within the Policies and Procedures Manual now addresses findings of the investigation and describes what steps to take and the timeframe if the complainant wishes to appeal the determination of the complaint or grievance. 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 Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 16 of 18 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 U.S.C. 12132; 28 CFR 35.107 16.3 Nursing Documentation The Health Care Manual now includes the name of the school nurse, the nurse’s shift schedule, and a full explanation of how the nurse’s availability is sufficient to meet the health care needs of the student population. Documentation The Health Care Manual regarding the administration of 18.05(9)(b) 16.5 Administration of Medication Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 17 of 18 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(9)(f) 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 medication now includes written policies and procedures regarding prescription and administration of medication when necessary; including authorization, prepackaging and staff training, disposing of or return to the parents of any unused medication, delivering medication to the school by a responsible adult in a container labeled by the physician or pharmacist, and refrigerating medications, as required. Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 18 of 18 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 16.7 Preventive Health Care Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Documentation Student Records 18.05 (9)(g) Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified The review of student records indicates that there is now documentation of annual dental exams in the student files as required. Milestones, Inc. School for Accelerated Learning Day Program Mid-cycle Review Report November 9, 2010 Page 19 of 18 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 MILESTONES, INC. SCHOOL FOR ACCELERATED LEARNING DAY PROGRAM A PRIVATE SPECIAL EDUCATION PROGRAM OPERATED PURSUANT TO 603 CMR 18.00 and 28.09 460 Totten Pond Road, Suite 300 Waltham, MA 02451 Program Rate Based on: 21 Students Approved Enrollment: 21 Students Day Program Summer Program 10 month program Residential Program 11 month program 12 month program APPROVED STUDENT:LICENSED EDUCATOR RATIO: NOT APPLICABLE APPROVED STUDENT:LICENSED EDUCATOR:AIDE RATIO: 7:1:1 APPROVAL STATUS FULL APPROVAL Expires on: August 31, 2014 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. HELEN M. MURGIDA, EDUCATIONAL SPECIALIST, PROGRAM QUALITY ASSURANCE SERVICES NINA M. MARCHESE, SUPERVISOR, PROGRAM QUALITY ASSURANCE SERVICES DARLENE A. LYNCH, DIRECTOR, PROGRAM QUALITY ASSURANCE SERVICES DATE ISSUED: NOVEMBER 9, 2010