2 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 11, 2012
Maureen Vibert, Executive Director
Nashoba Learning Group
Day Program
10 Oak Park ‘Drive
Bedford, MA 01730
Re:
Mid-cycle Review and Verification of previous Program Review Corrective Action Plan
Dear Ms. Vibert:
Enclosed is the Department of Elementary and Secondary Education’s (“Department”) Midcycle Report based upon the Mid-cycle review conducted in your private school program in
September 2012. 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 April 23, 2010. 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 December 5, 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
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
October 19, 2012.
Page 1 of 2
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 2015-2016 school year, unless the Department determines that
there is some reason to schedule this visit earlier.
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
Elizabeth Martineau, Chairperson, Board of Directors
Maureen Vibert, Local Program Review Coordinator
Encl.: Mid-cycle Review Report
Provisional Private School Approval Certificate, Expiration Date: December 5, 2012
Page 2 of 2
MASSACHUSETTS DEPARTMENT OF
ELEMENTARY AND SECONDARY EDUCATION
PRIVATE SCHOOL MID-CYCLE REVIEW
NASHOBA LEARNING GROUP
DAY PROGRAM
MID-CYCLE REVIEW REPORT
Previous Program Review Corrective Action Plan Submitted on May 24, 2010
Progress Reports Submitted on September 27, 2010 and November 18, 2010
Mid-cycle Onsite Visit Conducted on September 14, 2012
Date of this Report: October 11, 2012
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 1 of 14
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
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)
Not Applicable
Documentation
Observation
Nashoba Learning Group
submitted all current
approvals, licenses, and
certificates of inspection by
state and local agencies as
required.
Nashoba Learning Group is a
Day Program.
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 2 of 14
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary Education
and Timelines for
Implementation and
Further Progress
Reporting
Criterion
Number
and
Topic
6.1 Daily
Instructional
Hours
603 CMR
27.04
&
6.4 School
Days Per Year
Implementation
Status of
Requirements
or
Corrective
Action Plan
Determined
to be
Substantially
Implemented


Method(s) of
Verification
Comments Regarding
Corrective Action Plan
Implementation
Documentation
Nashoba Learning Group
submitted the Learning Time
Worksheet indicating that they
provide the required
instructional hours for a 12
month 216 day program by
offering 1296 hours of
instruction per year.
Corrective
Action Plan
Determined
to be Not
Fully
Implemented
or
Additional
Issues
Identified

Interviews
603 CMR
27.05(2);
28.09(9)(a)
8.5 Current
IEP & Student
Roster

Documentation
Student Record
Reviews
28.09(5)(a)
Interviews
Nashoba Learning Group 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
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 3 of 14
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of 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
Nashoba Learning
Center has nine
designees to the
Educational
Administrator who
attend IEP Team
meetings who have not
submitted proof of the
master’s degree in
Special Education and a
minimum of one year
of administrative
experience. Five of
these teachers have
current licenses as
special educators.
Nashoba Learning
Group has applied for
By November 20, 2012
Nashoba Learning Group
must submit the names and
proof of a master’s degree in
Special Education or a
related field for the nine
teachers who attend IEP
Team Meetings and serve as
designees to the Educational
Administrator and provide
the name and a copy of the
Special Education license or
waiver for five of the
teachers.

parent(s) as required.
11.3
Educational
Administrator
Qualifications
28.09(5)(a);
28.09(7)(a);
603 CMR
44.00
Documentation
Staff Record
Reviews
Interviews
The assigned Educational
Administrator meets the
required qualifications to serve
in this capacity and the names
and qualifications of designees
to the Educational
Administrator who attend IEP
Team Meetings were not
submitted.

Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 4 of 14
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

waivers for four
teachers which have not
yet been approved.
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 5 of 14
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

11.4 Teachers
(Special
Education
Teachers and
Regular
Education
Teachers)
Documentation
Staff Record
Reviews
Nashoba Learning Group has
applied for waivers for five
teachers which have not yet
been approved.
Corrective
Action Plan
Determined
to be Not
Fully
Implemented
or
Additional
Issues
Identified


Interviews
18.05(11)(f);
28.09(5)(a);
28.09(7)(b, c);
34 CFR
300.321
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 6 of 14
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary Education
and Timelines for
Implementation and
Further Progress
Reporting
Nashoba Learning
Group has applied for
waivers for five
teachers which have not
yet been approved.
By November 20, 2012
Nashoba Learning Group
must submit the following
for the five teachers:
 Current teaching staff
roster that includes all
UFR 115’s special
education teachers and
UFR 116’s regular
education teachers in the
program that contains the
following information:
o UFR#;
o Name;
o Position title within
the program;
o Grade level(s) taught;
o Subject(s) taught;
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

o
o
o
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 7 of 14
Massachusetts
teaching license title,
type, grade level,
number and
expiration date;
Copy of license or
most current ELAR
activity sheet; and
In instances where
teachers do not hold
Massachusetts
licensure for the area
in which they are
employed, a copy of
a current certification
waiver is provided or
ELAR activity sheet.
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
Documentation
All related service providers
are currently certified, licensed
or registered in their
professional area as required.

Interviews
28.09(7)(d)
11.6 Master
Staff Roster

Documentation
Interviews
28.09(7)
19 Anti-Hazing
M.G.L. c. 269,
§§ 17 through
19

Corrective
Action Plan
Determined
to be Not
Fully
Implemented
or
Additional
Issues
Identified
Documentation
Student Record
Reviews
Interviews
Nashoba Learning Group
submitted a Master Staff
Roster for every position
within the program that
corresponds to the last
approved Program Budget as
required.
Nashoba Learning Group
provided evidence of
distribution of the Anti-hazing
policy as approved by the
program’s Board of Directors
to all secondary aged students,
as well as documentation of
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 8 of 14
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of 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

20 Bullying
Prevention and
Intervention
M.G.L. c. 71, s.
37H, as
amended by
Chapter 92 of
the Acts of
2010. M.G.L.
c. 71, s. 37O
(e)(1) & (2).
M.G.L. c. 71, s.
370(d).

Corrective
Action Plan
Determined
to be Not
Fully
Implemented
or
Additional
Issues
Identified

Documentation
Interviews
students’ receipt of the policy
as required.
Nashoba Learning Group has
amended its handbook
admission material to include
an age-appropriate summary
of their Bullying Prevention
and Intervention Plan and
included a description of how
it is distributed. The program
also submitted a description of
the professional development
plan for all staff for the 20122013 school year and provided
evidence of its implementation
including dates, format used,
and sign-in sheets indicating
staff attendance.
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 9 of 14
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of 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 2009-2010 Program Review or Other Areas of Concern
8.8 IEP –
Progress
Reports
28.07(3);
34 CFR
300.320(a)
(3)(I, ii)

Documentation
Student Records
Interviews
At the time of the Program
Review, while Nashoba
Learning Group staff wrote
progress reports for students
that were thorough and
specific, and interviews
revealed that information
about student progress was
shared with parents at
regularly occurring monthly
meetings, a review of student
records revealed that some
progress reports were not
dated, and there was no
evidence that progress reports
were sent to parents/guardians,
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 10 of 14
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

sending school districts and
applicable human service
agencies as required.
During the Mid-cycle Review,
review of student records
indicated that all progress
reports were dated and sent to
parents/guardians, and sending
school districts and applicable
human service agencies as
required.
12.2(c)
Required
TrainingCPR
Certification

Documentation
Interviews
At the time of the Program
Review, while Nashoba
Learning Group had developed
a training plan for CPR
certification, documentation
and interviews indicated that
not all appropriate staff had
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 11 of 14
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of 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


received the required annual
CPR training.
18.05(9)(e)
16.7
Preventive
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

Documentation
Student Records
Interviews
During the Mid-cycle Review,
review of documentation of
the training plan and name and
certification of the certified
instructor providing CPR
training, and staff interviews
revealed that all staff have
current CPR certification.
At the time of the Program
Review, student record review
and interviews revealed that
Nashoba Learning Group had
not ensured that each student
received an annual dental and
physical examination.
Additionally, the school had
not developed a plan to ensure
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 12 of 14
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of 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

that vision, hearing, and
postural screenings (grades 59) had been completed as
required.
A review of Student Records
revealed that all students now
receive a yearly dental
examination onsite and there
are copies of physical
examinations as required. The
program has developed and
implements vision, hearing,
postural screenings (grades 59) as required.
18.1
Confidentiality
of Student

Documentation
Student Records
At the time of the Program
Review, student records
revealed that the log of access
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 13 of 14
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of 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


Records
Interviews
28.09(5)(a);
28.09(10);
23.07(1);
M.G.L. c. 71, §
34H
Corrective
Action Plan
Determined
to be Not
Fully
Implemented
or
Additional
Issues
Identified
kept by Nashoba Learning
Group did not contain the
name, position and signature
of the person releasing the
information as required.
The log of access now
contains all required elements.
Nashoba Learning Group, Day Program Mid-cycle Review Report
October 11, 2012
Page 14 of 14
Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Further Corrective Action
Ordered by the
Department of Elementary
and Secondary Education
and Timelines for
Implementation and
Further Progress
Reporting
Commonwealth of Massachusetts
Department of Elementary and Secondary
Education
NASHOBA LEARNING GROUP
DAY PROGRAM
A PRIVATE SPECIAL EDUCATION PROGRAM OPERATED PURSUANT TO
603 CMR 18.00 AND 28.09
10 Oak Park Drive
Bedford, MA 01730
Program Rate Based on: 70 Students
Approved Enrollment: 90 Students
Day Program
Summer Program
Residential Program
10 month program
11 month program
12 month program
APPROVED STUDENT:LICENSED EDUCATOR RATIO: Not Applicable
APPROVED STUDENT:LICENSED EDUCATOR:AIDE RATIO: 10:1:10
APPROVAL STATUS
PROVISIONAL APPROVAL
Expires on: December 5, 2012
The current approval is a result of a Mid-cycle Review conducted in the 2012-2013 school year
and the next review is scheduled for the 2015-2016 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:
10/11/12