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 December 15, 2006 Veryl Anderson Executive Director Professional Center for Child Development, Inc. 32 Osgood Street Andover, MA 01810 Re: Onsite Follow-up Monitoring Report: Program Review Corrective Action Plan Verification and Mid-cycle Review Dear Ms. Anderson: Enclosed is the Department's Program Review Follow-up Monitoring Report together with findings regarding your private school’s Mid-Cycle 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 September 9, 2004. 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 on April 27, 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 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 5, 2007. 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 Preston Hall, Chairperson, Board of Directors Susan Buehler, Local Program Review Coordinator Encl.: Follow-up Monitoring Report Provisional Private School Approval Certificate, Expiration Date: April 27, 2007 MASSACHUSETTS DEPARTMENT OF EDUCATION PRIVATE SCHOOL MID-CYCLE PROGRAM REVIEW PROFESSIONAL CENTER FOR CHILD DEVELOPMENT ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Action Plan Submitted on November 15, 2004 Progress Reports Submitted on March 24, 2005, March 1, 2006, June 20, 2006, and August 8, 2006 Onsite Visit Conducted on November 6, 2006 Date of this Report December 15, 2006 Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation 1.3 (NOW 7.1) Program’s Curriculum 28.09(9) 2.2 Approvals, Licenses, Certificates of Inspection 28.09 (2)(b)4-5 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 Documentatio n See criterion 7.1. Documentatio n The Professional Center for Child Development has current licenses, approvals, and certificates of inspection by state and local agencies. Professional Center for Child Development Program Review Mid-cycle Report December 15, 2006 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 Verifica-tion 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 The Professional Center for Child Development did not submit their most recently approved program budget. Submit to the Department by March 30, 2007 a copy of the most recently approved program budget as approved by the Operational Services Division that indicates the approved full time equivalents for all staff positions. 28.09(5) 28.09(6) 18.04(1) 102 CMR 3.06 (4)(b) 2.3 DEEC Licensure (Not Applicable to Day Schools) 2.5 Financial Management 28.09(2)(b)4 Not Applicable Documentatio n from annual update (NA for Public Programs) Page 2 of 28 Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 3.2 Health Care Manual 18.05 (9)(d) 4.4 Advanced Notice of Program/ Facility Change 28.09(5)(c) 4.5 Immediate Notification 18.03(10) 18.05(7) 28.09(12) 5.2 Documentatio n The Professional Center for Child Developments maintains a written and current health care policies and procedures manual that contains all required policies and is approved by the school’s licensed physician. Documentatio n The Professional Center for Child Development provides written notice to the Department to obtain approval prior to any substantial change to the program or physical plant. Documentatio n The Professional Center for Child Development’s policy and procedures for the immediate notification to parents, the public school district, all involved state agencies, and the Department includes all incident types requiring reporting of serious incidents. Documentatio The Professional Center for Child Page 3 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Policies and Procedures for Coordination Collaboration with Public School Districts n Development has a policy that describes their practices to ensure that they coordinate and collaborate with public school districts. Documentatio n The Professional Center’s policy and procedures includes all required areas for coordination and collaboration with public school districts. 28.06(2-3) 28.09(9)(c)& (d) 28.09(2)(b)7 Federal Regulations: 300.349 and 300.400.401 5.2(a) (Formerly 5.3) Content requirements policies/ procedures for Coordination Page 4 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Verifica-tion 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 The Professional Center for Child Development provides only four hours of structured learning time. Submit to the Department by March 30, 2007, the program’s plan to increase its structured learning time so that it meets the requirements of the student learning time regulations. / Collaboratio n with Public School Districts 28.06(2-3) 28.07(5) 28.09(9)(c) and (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 6.2 School-towork Documentatio n and interview Not applicable. Page 5 of 28 Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion 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 (Instructiona l hours) 603 CMR 27.02, 27.04 6.3 Kindergarten (Instructiona l hours) 603 CMR 27.03(5) 6.4 School Days per Year 28.09(9) Interview The Professional Center for Child Development does not set a separate school year and school day schedule for kindergarten aged students. Documentatio n The Professional Center for Child Development provides 198 days of instruction as indicated on their school calendar. 6.5 Early Release of High School Seniors Not applicable 603 CMR 27.05 7.1 Curriculum Frameworks Documentatio n and Page 6 of 28 The Professional Center for Child Development Submit to the Department by March 30, 2007, a plan to Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 28.09(9)(b) 7.2 Staff Training 28.09(9)(b) Documentatio n 7.3 State/District Wide Assessments 28.09(9)(d) 8.2 Implementation Related Services Documentation submitted by The Professional Center for Children indicated that all teaching staff are participating in trainings and curriculum development relative to the Massachusetts Curriculum Frameworks as required. Not applicable. The Professional Center for Child Development serves students who are aged 3 to 7 years and are not eligible for MCAS testing. Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting has developed only two areas of curriculum, ELA and Math. The program has a plan to expand the curriculum to include all core subjects. expand the curriculum to include all core subjects, ELA, Math, social studies and science. interview Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Documentatio n The Professional Center for Child Development’s narrative regarding the implementation of related services includes all Page 7 of 28 Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 28.04 and 28.09(8) 34 CFR 300.24 8.4 Program Modifications and Support Services for Limited English Proficient Students 8.8 (Formerly 8.7) IEP Progress Reports 28.07(3) 20 U.S.C. Chapter 33, Section 1414(d)(1)( A) (viii) required elements. Documentatio n and interview The Professional Center for Child Development indicated that it will work with the public school district to implement necessary program modifications and support services to serve effectively limited English proficient students. Documentatio n and student record review Progress reports sent to parents and school districts by The Professional Center for Child Development include written information on the student’s progress toward the annual goals in the IEP. Documentation in the student records show that progress reports are distributed quarterly to parents and Local Education Administrators. Page 8 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified IDEA Regulations: 300.347 8.9 IEPRevisions & Changes 34 CFR 300 9.1 Policies and Procedures 18.05(5) 9.3 Runaway Students 18.03(10) Documentatio n The Professional Center for Child Development’s policy indicates that it notifies the responsible public 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. Documentatio n The Professional Center for Child Development has a comprehensive set of policies and procedures dealing with discipline and behavior management. Documentatio n The Professional Center for Child Development has a written policy appropriate for the school population and location, as well as procedures for handling students who run away. Page 9 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 9.4 Restraints 18.05(5)(h) 603 CMR 46.00 102 CMR 3.00 9.5 3-5 Day Suspensions 18.05(6) 9.6 10+ Day Suspensions Joint Responsibilit ies of the private school and the responsible 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 The Professional Center for Child Development has not developed a policy on the use of physical restraints and does not provide the necessary annual training required state restraint regulations. Submit a policy relative to restraints to the Department by March 30, 2007. Include information on all staff that have received restraint training. Documentatio n and interview Documentatio n The Professional Center for Child Development’s policies and procedures regarding suspensions for 3 to 5 days meet the requirements of this criterion. Documentatio n The Professional Center for Child Development’s policy regarding suspensions over 10 days includes all required elements of this criterion. Page 10 of 28 Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified school district 34 CFR 300.519-529 9.7 Termination s Documentatio n The Professional Center for Child Development’s policy regarding terminations includes all required elements of this criterion. Documentatio n The Professional Center for Child Development ensures that instructional groupings do not exceed required student/teacher ratios. 18.05(7) 28.09(12)(b) 10.1 Student: Teacher Ratios 28.06(6)(d) &(g) 28.09(7)(e) 10.4 Student: Child Care Ratios 28.09(7) 18.01(2) 11.1 Personnel Not Applicable Documentatio The Professional Center for Child Page 11 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Policies 28.09(7) 28.09(11)(a) 18.05(11) 11.4 Teachers Special Education Teachers and Regular Education Teachers 28.09(7)(b)( c) 18.05(11)(f) 11.4(a) Professional Developmen t Plans 28.09(7)(b) (c) n Development has written personnel policies and procedures that describe each of the required elements. Documentatio n All teachers employed by The Professional Center for Child Development are appropriately licensed or waivered by the Department. Documentatio n All licensed teaching staff holding professional licensure have received supervisor approval of their Professional Development Plans pursuant to 603 CMR 44.04. Documentatio The roster of related services 18.05(11)(f) 11.5 Related Page 12 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Services Staff 28.09(7)(d) 11.7 Job Descriptions 18.05(11)(d) The master staff roster submitted by The Professional Center for Child Development lists the classroom aide as UFR 120. Teacher assistants should be listed as UFR 134-136. Additionally the roster indicates that one of the staff is a day care teacher. Explain use of staff classifications as day care staff and the discrepancies noted in the left column. Revise and resubmit the master staff roster by March 30, 2007. Please also refer to criterion 2.5. providers submitted by The Professional Center for Child Development indicates that related services providers are appropriately licensed and credentialed. Documentatio n Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting n 11.6 Master Staff Roster 28.09(7) Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Documentatio n The Professional Center for Child Development has written job descriptions for all staff positions. The job descriptions include the Uniform Financial Report (UFR) number for each staff title. 11.8 Page 13 of 28 Criterion Number and Topic Salary Ranges 18.05(11)(e) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented 11.9 Organizational Structure 28.09(7) 28.07(c) 11.11 Supervision of Students 28.09(7) 11.12 Accessibility of Extracurricu -lar Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Documentatio n The Professional Center for Child Development has established salary ranges including benefits covering all positions. 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 The Professional Center for Child Development’s organizational chart includes a category of day care assistant teachers rather than assistant teachers under the UFR for direct care workers. Submit a revised organizational chart that includes appropriate staff titles by March 30, 2007. Documentatio n Documentatio n The Professional Center for Child Development has a detailed plan that describes how appropriate supervision is provided to students while they are engaged in schoolrelated activity on and off school grounds. Documentatio n The Professional Center for Child Development indicated that it does not sponsor intramural or interscholastic sports or clubs at Page 14 of 28 Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Activities this time. 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), (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, 5; 603 CMR 26.06 12.1 Staff Orientation Training 18.05(11)(g) Documentatio n The Professional Center for Child Development has a written plan for staff orientation and provides an orientation-training program for all new staff to ensure an understanding of the school’s philosophy, organization, program, practice and goals. The plan states how newly hired staff are provided training on all required topics. Page 15 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 12.2 Annual InService Training Plan and Calendar 28.09(7)(f) 18.05(11)(h) 12.2(a) Behavior Management and Restraint Training 28.09(11) 18.05(5) 12.2(g) Interns and Volunteers Training 18.05(11)(I) 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 Documentatio n “Transportation Safety” was not included on the annual training schedule. Submit evidence to the Department by March 30, 2007 that training has occurred with all staff regarding transportation safety. Documentatio n and interview The Professional Center for Child Development does not provide annual restraint training for all staff and does not provide intensive training for members of a school resource team relative to restraint. Submit to the Department by March 30, 2007, a description of the program’s restraint training and the names and training of the staff who have received intensive training to function as a school resource team. Documentatio n The Professional Center for Child Development has a policy and procedure for the training and orientation of interns, volunteers and others who work at the program. Page 16 of 28 Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 13.3 Comparability of Facilities 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) Documentatio n and observation Where The Professional Center for Child Development provides separate facilities for members of a specific group those facilities are comparable to those offered other students in the program. Page 17 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Verifica-tion 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 The Professional Center for Child Development does not make field trips accessible to all students. Those students whose parents are not able to transport them for field trips are not able to participate. Submit a plan to the Department by March 30, 2007, that ensures that all students are able to participate in field trips regardless of whether their parents are able to attend with them. 13.4 13.6 Classroom Space 18.04(6)(a) 15.1 Parental Involvement and Parents’ Advisory Group 18.05(4)(a) Interview Physical Facility/ Architectual Barriers 18.04(8) Observation Each room that is utilized for the instruction of students at The Professional Center for Child Development is adequate with respect to the number of students, size and age of students and students’ specific educational needs. Documentatio n and interview The Professional Center for Child Development has a plan for involving parents. While the program does not currently have an active Parent Advisory Group (PAG) to fulfill the advisory responsibilities, it does have several groups of parents that it Page 18 of 28 Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified meets with regularly and involves in discussions and activities that pertain to the education, health and safety of the students in the program. 15.3 Information to be translated into Languages other than English Documentatio n and interview The Professional Center for Child Development has a procedure in place to provide general announcements, or notices in the primary language of the home if they should enroll a student whose parents’ primary language was not English. Documentatio n The Professional Center for Child Development has a written plan for ensuring that it is informed by a parent or guardian of any Title VI; EEOA: 20 U.S.C. 1703(f); M.G.L. c. 76, s. 5; 603 CMR 26.02(2) 15.4 (Formerly 15.3) Change of Student’s Page 19 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Legal Status 18.05(4)(b) 15.5 (Formerly 15.4) Parent Consent 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 changes in a student’s legal status. Documentatio n The Professional Center for Child Development requests parental consent for all items included in this criterion. 28.07(1)(b) 15.8 (Formerly 15.7) Registering Complaints Documentatio n 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. Page 20 of 28 The Professional Center for Child Development informs parents and students that if they have a complaint they should speak to the program administrator. It does not have grievance procedures for students and employees providing for prompt resolution of complaints and prompt and equitable resolution of grievances alleging discrimination based on sex or disability. The Department recommends that the Professional Center for Child Development revise its procedures for handling complaints and grievances to Submit to the Department by March 30, 2007, a revised complaint and grievance procedure specifically stating the process for filing grievances relative to discrimination based on disability or sex. Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 722(g)(1)(J)(ii ) 16.1 Health Care Policy and Procedure Manual 18.05(9)(c) 18.05(9)(d) 16.2 Physician Consultation 18.05(9)(a) 16.5 Administrati on of Medication Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance include a process for filing a formal written complaint, providing the name of the person with whom the complaint should be filed, timelines for response, and the process to appeal the resolution if appropriate. Documentatio n The Professional Center for Child Development has a comprehensive, written health care policies and procedures manual that describes provisions made for medical, nursing and infirmary care of students. A licensed physician approves the manual. Documentatio n The Professional Center for Child Development has secured the services of a licensed physician available for consultation. Documentatio n The Professional Center for Child Development has developed written policies and procedures Page 21 of 28 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 Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 18.05(9)(f) 16.6 Administrati on of Antipsychoti c Medication 18.05(9)(f)(9 regarding the administration of medication. Documentatio n 16.10 Meningococ cal Disease and Vaccination The Professional Center for Child Development has developed written policies and procedures regarding the administration of antipsychotic medication. Not Applicable MGL, Chapter 76, s.15D 105 CMR 220.700 18.2 Student Records 28.09(10) Student record reviews The Professional Center for Child Development’s student records contain all required information required by this criterion. MGL c. 71, s. 34H 603 CMR Page 22 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of 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 Verifica-tion Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified 23.00 Family Educational Rights and Privacy Act (FERPA) Page 23 of 28 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Education and Timelines for Implementation and Further Progress Reporting