Massachusetts Department of Elementary and Secondary Education 350 Main Street, Malden, Massachusetts 02148-5023 Telephone: (781) 338-3700 TTY: N.E.T. Relay 1-800-439-2370 November 16, 2007 Alan Klein, Program Director RFK Lancaster School 220 Old Common Road Lancaster, MA Re: Onsite Follow-up Monitoring Report: Program Review Corrective Action Plan Verification and Mid-cycle Review Dear Mr. Klein: Enclosed is the Department's Program Review Follow-up Monitoring Report together with findings regarding your private school’s Mid-cycle Program Review. This report contains the Department's findings based on the onsite activities conducted in your school. 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, 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 May 15, 2008. The reasons for the “Provisional Approval” are clearly indicated on the attached Corrective Action Plan Implementation Checklist. The Department has prepared 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 December 3, 2007. 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 781-338-3719. Sincerely, Dee Wyatt, Program Review Follow-up Chairperson Program Quality Assurance Services Darlene Lynch, Director Program Quality Assurance Services c: Jeffrey Nellhaus, Acting Commissioner of Education Caryn Goldberg, Local Program Review Coordinator Encl.: Follow-up Monitoring Report Private School Approval Certificate, Expiration Date: May 15, 2007 Page 2 of 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION PRIVATE SCHOOL MID-CYCLE PROGRAM REVIEW RFK LANCASTER SCHOOL ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Onsite Visit Conducted on October 10-11, 2007 Date of this Report November 16, 2007 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 2.2 Approvals, Licenses, Certificates of Inspection 18.04(1); 28.09(2)(b) (5); 28.09(5)(b); Documentation Review RFK Lancaster School submitted current approvals, licenses and certificates of inspection for all buildings. RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 1 of 19 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 28.09(6)(b, c) 2.3 EEC Licensure Documentation Review Documentation Review 102 CMR 3.00 (NA for Public Day Schools) 7.4 High School Diplomas and Certificates of Attendance M.G.L. c. 69, § 1D; Administrative Advisory SPED 2002-4REVISED: Special Education Students in Out-of-District PlacementsParticipation RFK Lancaster School submitted a letter from EEC dated 9/13/07 stating the EEC license is valid until the current licensing process is completed. RFK Lancaster School must submit to the Department of Elementary and Secondary Education a copy of the new EEC license once it is received. RFK Lancaster School has a policy that describes the awarding of diplomas and/or certificates to its students that recognizes achievement, attendance, course completion, or participation. RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 2 of 19 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 Review of student records revealed that the progress reports issued by RFK Lancaster School did not report on the student’s RFK Lancaster School must conduct a training session with all teachers regarding the writing of progress reports to reflect the student’s progress in MCAS Testing and High School Graduation Standards 8.4 Program Documentation Review RFK Lancaster School has a written plan for working with public school districts to implement necessary program modifications and support services to identify and effectively serve limited English proficient students. Documentation Review, Student Records RFK Lancaster School has on file a current IEP for each enrolled Massachusetts student that has been issued by the responsible public school district and consented to and dated by the student’s parent(s). Modifications and Support Services for Limited English Proficient Students M.G.L. c. 71A; Title VI 8.5 Current IEP & Student Roster 28.09(5)(a) 8.8 IEP – Progress Reports RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 3 of 19 Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting progress toward meeting the annual goals as stated in the IEP. toward meeting the annual goals as stated in the IEP. The training agenda and sign-in sheet for this training must be submitted to the Department of Elementary and Secondary Education by December 21, 2007. The Department will conduct an onsite visit to review a random selection of progress reports in February, 2008. 9.1(a) Student Separation resulting from Behavior Management 18.05(5)(i); 46.02(5)(b) Documentation Review, Student Records, Observation RFK Lancaster School has written policies and procedures regarding student separation that contains all required elements of this criterion. Observation of the time out rooms verified compliance of the physical requirements. 11.3 Educational Documentation Review, Personnel Records The Educational Administrator for RFK Lancaster School meets the required qualifications for this position and has a supervisory 28.09(5)(a); Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance 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 Administrator Qualifications Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 4 of 19 Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation 28.09(7)(a); 603 CMR 44.00 11.4 Teachers (Special Education Teachers and Regular Education Teachers) Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified approved Professional Development Plan. Documentation Review, Personnel Records RFK Lancaster School submitted a current teacher roster and verification that all teachers have either a current teaching license or waiver. 11.5 Related Services Staff 28.09(7)(d) Documentation Review RFK Lancaster School submitted a current related services staff roster that indicated all were appropriately certified, licensed or registered in their professional areas. 11.6 Documentation RFK Lancaster School 18.05(11)(f); 28.09(5)(a); 28.09(7)(b, c) RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 5 of 19 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 Review submitted a master list of all staff for every position within the program that contained job titles, UFR title numbers, FTEs, certification/licensure information and qualifications. The roster correctly corresponded to the school’s last approved program budget. Documentation Review, Personnel Records RFK Lancaster School has a training plan for CPR Certification which identifies the staff positions to be trained, how many staff will be trained, the frequency of CPR training and certification, and the name and qualifications of the certified instructor providing the CPR training. Documentation Review RFK Lancaster School has written policies and procedures regarding visitation and other forms of communication with family, friends and others. The name Master Staff Roster 28.09(7) 12.2(c) Details about Required TrainingCPR Certification 18.05(9)(e) 14.4 Visiting, Mail and Telephones (Residential Schools Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 6 of 19 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 Only) 18.03(9)(a) and (b) 16.3 Nursing Documentation Review Documentation Review, Student Records, Observation RFK Lancaster School has a written policy for protecting a student from exposure to foods, chemicals, or other materials to which they are allergic. Appropriate notations in the student records and postings in appropriate areas were observed. Documentation Review RFK Lancaster School has a written policy that prohibits the use of any tobacco product within the school buildings, 18.05(9)(h) 16.12 No Smoking Policy and title of the person responsible for oversight was provided. RFK Lancaster School provided the name of the school’s RN, a copy of her current license, her shift schedule and an explanation of how the nurse’s availability is sufficient for the needs of the student population. 18.05(9)(b) 16.11 Student Allergies Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 7 of 19 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 the school facilities, on the school grounds or on school buses by any individual. M.G.L. c. 71, § 37H Identified Areas of Non-Compliance During Previous Program Review or Other Areas of Concern 4.2 Public information and Postings Observation RFK Lancaster School maintains onsite and makes available for public review all required postings. Documentation Review RFK Lancaster School has a school calendar that clearly indicates 216 scheduled school days as well as 5 additional days to account for unforeseen circumstances. 28.09(6)(a, b, c, d, e); 28.09(2)(b)(4 6.4 School Days Per Year 603 CMR 27.05(2); 28.09(9)(a) 7.4 High School Diplomas and See above. RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 8 of 19 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 Certificates of Attendance M.G.L. c. 69, § 1D; Administrative Advisory SPED 20024-REVISED: Special Education Students in Out-ofDistrict PlacementsParticipation in MCAS Testing and High School Graduation Standards (Formerly 5.2) 8.4 See above. Program Modifications and Support Services for RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 9 of 19 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 Limited English Proficient Students M.G.L. c. 71A; Title VI (Formerly 8.2) 8.5 Current IEP & Student Roster 28.09(5)(a) 8.8 IEP – Progress Reports State: 28.07(3); Federal 20 U.S.C. Chapter 33, Section 1414(d)(1)(A )(viii) See above. See above. RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 10 of 19 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 34 CFR 300.320(a)(3) (i, ii) 8.11 IEP Transition Planning Documentation Review, Student Records RFK Lancaster School has a written plan that addresses transition planning and working with the responsible school district to discuss a student’s transition needs at the IEP team meeting. The Department of Elementary and Secondary Education Transition Planning Chart is used. Documentation Review Documentation Review RFK Lancaster School has a written policy that addresses students who run away. The policy includes a definition of runaways, the procedures for handling these students, the necessary notifications to be made, and the required documentation. RFK Lancaster School has a written suspension policy and procedure to be followed. It is expected that every effort will 34 CFR 300.347(b)(1, 2) 9.3 Runaway Students 18.03(10) 9.5 3-5 Day Suspensions Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 11 of 19 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 be made to keep students in school. However, in the event that suspension from the school program is necessary and suspended students are assigned to the residences, RFK Lancaster School will ensure that the educational services included in the IEPs will be implemented. In addition, RFK Lancaster School now maintains a suspension log. 18.05(6) 11.1 Personnel Policies and Procedures Manual 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation Review, Personnel Records RFK Lancaster School now has written personnel policies and procedures that include the regular scheduling of written performance evaluations for all staff. The school also has a policy for requiring CORI evaluations for all employees, volunteers and transportation providers whose responsibilities bring them into direct and unmonitored contact with students. RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 12 of 19 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 revised 5/7/07 11.4 Teachers (Special Education Teachers and Regular Education Teachers) 18.05(11)(f); 28.09(5)(a); 28.09(7)(b, c) 11.5 Related Services Staff 28.09(7)(d) 11.6 Master Staff Roster 28.09(7) 12.1 Staff Orientation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified See above. See above. See above. Documentation Review, Personnel Records RFK Lancaster School has a written orientation and training program for initial staff that provides the required RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 13 of 19 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 trainings in emergency procedures, behavior management procedures and requirements related to student protections. The school’s policy states that new staff may not be assigned direct care duties with students until they have participated in all mandated trainings. and Training 18.05(11)(g, i); 28.09(7)(f) 12.2 In-Service Training Plan and Calendar 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 Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation Review, Personnel Records, Observation RFK Lancaster School has a policy that states that all staff, including new employees, interns and volunteers, must participate in annual in-service training on average at least two hours per month. A training schedule was submitted that included all mandated training topics, the appropriate number of required hours, and the name and job description of the staff person responsible for the RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 14 of 19 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 U.S.C. 2000d; 34 CFR 100.3; EEOA: 20 U.S.C. 1703(f); Title IX: 20 U.S.C. 1681; 34 CFR 106.31106.42; M.G.L. c. 76, § 5; 603 CMR 26.00, esp. 26.07(2, 3) (Formerly 12.2[e]) 12.2(d) Details about Required TrainingMedication Training 18.05(9)(f)(3) (c) Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified development and implementation of the inservice training program/calendar. Observation in the residences revealed secured areas in which all student-related documentation was kept. Documentation Review, Personnel Records RFK Lancaster School provides training about the nature of a medication, potential side effects and any special precautions or requirements by the school’s RN to all staff providing care or instruction to students for whom any staff administers medication. RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 15 of 19 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 13.2 Description of Physical Facility 18.04; 28.09(8) (Formerly 13.7) 13.7 Library/ Resource Room 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 RFK Lancaster School’s library continues to be inaccessible to students with limited mobility. RFK Lancaster School must submit a detailed plan to the Department of Elementary and Secondary Education that includes the following: Who is responsible at RFK Lancaster School for overseeing the construction of the new building? Who is the architect? Who is the contractor? Identify the construction phases with estimated timelines for each. Documentation Review, Observation RFK Lancaster School has a written plan to ensure the safety of all students in the event of excessive heat. Observation revealed all peeling paint had been removed and the electrical boxes in the time out rooms had either been removed or boxed to prevent access by students. 18.04(6)(b) (Formerly 13.6) RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 16 of 19 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 Identify on the plans the location of the library. This plan must be submitted to the Department of Elementary and Secondary Education by January 1, 2008. Additional progress reports on the status of the building project must be submitted to the Department of Elementary and Secondary Education quarterly beginning April 1, 2008. 15.3 Information to be translated into Languages other than English Documentation Review RFK Lancaster School has a written plan describing how the program will respond to parent/guardian requests to have important school information translated on demand, either orally or in writing. Title VI; EEOA: 20 U.S.C. 1703(f); RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 17 of 19 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 M.G.L. c. 76, § 5; 603 CMR 26.02(2) 15.5 Parent Consent 18.05(5)(c); 18.05(8); 18.05(9)(f)(1) 16.5 Documentation Review, Student Records RFK Lancaster School now offers parent notification for human sexual education. Documentation Review, Personnel Records RFK Lancaster School has a written policy that contains all required elements of this criterion. A training schedule was submitted that indicated annual training for the administration of medication is being provided. Documentation Review, Personnel Records RFK Lancaster School has a written policy that contains all required elements of this criterion. A training schedule was submitted that indicated annual training for the Administration of Medication 18.05(9)(f) 16.6 Administration of Antipsychotic Medication 18.05(9)(f)(9) RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 18 of 19 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 administration of antipsychotic medication is being provided. 17.1 Transportation Safety 28.09(11)(b) Documentation Review, Personnel Records RFK Lancaster School submitted a training schedule that indicated annual training for transportation safety is being provided. RFK Lancaster School Program Review Mid-cycle Report November 16, 2007 Page 19 of 19 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