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
February 14, 2006
Richard W. Small, Ph.D.
Executive Director
Walker Home and School
1968 Central Avenue
Needham, MA 02492
Re:
Onsite Follow-up Monitoring Report: Program Review Corrective Action Plan
Verification and Mid-cycle Review for the Day and Intensive Residential Program
(Needham Campus)
Dear Dr. Small:
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 to verify the
implementation status and effectiveness of corrective steps taken in response to your Program
Review Report issued on April 7, 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 July 14, 2006. The reasons for the “Provisional Approval” are clearly
indicated on the attached Corrective Action Plan Implementation Checklist. In areas where the
private school has failed to implement fully its approved Corrective Action Plan, the Department
views these findings to be serious.
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 Kevin Bobetich by February 28, 2006. The
private school must demonstrate the specific steps to be taken to come into substantial
compliance with all identified areas requiring corrective action by March 22, 2006. Pending the
outcome of review of these steps, the Department will determine whether or not sanctions in the
form of “Probationary Approval” status and/or a closing of the private school’s intake are
necessary at that time.
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 Kevin Bobetich at 781-338-3746.
Sincerely,
Kevin Bobetich, Program Review Follow-up Chairperson
Program Quality Assurance Services
John D. Stager, Administrator
Program Quality Assurance Services
c:
David P. Driscoll, Commissioner of Education
Encl.: Follow-up Monitoring Report
2
MASSACHUSETTS DEPARTMENT OF EDUCATION
MID-CYCLE PROGRAM REVIEW
Walker Home and School Day and Intensive Residential (Needham Campus)
ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION
AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION
Action Plan Submitted on May 28, 2004
Progress Reports Submitted on May 28, December 3, 2004 and January 24, 2005
Onsite Visit Conducted on November 17-18, 2005
Date of this Report: February 14, 2006
Criterion
Number
and
Topic
1.2
Program and
Student
Description
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

Documentation
review and
Interviews
The Walker Home and School
closed the Regular Residential
Program on July 1, 2005.
Walker now has one approved
Residential Program that is
referred to as the Intensive
Residential Program. Students
in the Day and Intensive
Residential Program are
“mixed” together during the
school day. Walker states that
the ratios are the same for both
programs for the school portion
of the day.
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 Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

1.3
Program’s
Curriculum
28.09(9)
Documentation
review and
interviews
The Walker Home and School
has a description of the
program’s curriculum, and a
written plan that describes
opportunities for students to
participate in daily and
recreational activities that are
appropriate to their ages,
interests, and needs.
2


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 Walker Home and
School submitted
evidence of their
curriculum in the area of
English Language Arts
after the Mid-Cycle
Review.
The Walker Home and School
must develop a written plan
that describes steps that will be
taken to create a comprehensive
curriculum that is consistently
implemented throughout the
entire 12-month school year by
March 1, 2006. Essential
learning opportunities that are
offered to students to reach the
state graduation requirements
must be included.
Interviews and
documentation revealed
that the school utilizes a
different curriculum
during the summer, which
is not implemented during
the school year. For
example, the curriculum
utilized during the
summer months does not
consistently address all of
the areas appropriate to
students’ specific grade
level and the content areas
as outlined in each
student’s IEP.
The School must provide
written evidence of monthly
progress towards a
comprehensive curriculum to
the Department through
September of 2006.
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

2.2
Approvals,
Licenses,
Certificates of
Inspection
28.09 (2)(b)4-5
28.09(5)
28.09(6)
18.04(1)
Documentation
review and
interviews
The Walker Home and School
has an updated lead paint
inspection.
Documentation
review and
interviews
The Department of Early
Education & Care is currently
updating the Walker Home and
School’s approval status. The
school will submit the updated
approval status to the
Department after the
Department of Early Education
and Care complete the licensing
study.
102 CMR 3.06
(4)(b)
2.3
DEEC
Licensure (Not
Applicable to
Day Schools)

3


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 Walker Home and
School has not provided
the Department with the
asbestos and PCB
inspections as cited in the
Program Review.
The Walker Home and School
must provide the Department
with a plan to inspect for
asbestos and PCB’s or provide
certificates of inspection by
March 1, 2006.
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
Documentation
review
The Walker Home and School
has developed policies and
procedures for items 1i, 1k, 1m,
and 2b, 2c, 2d, 2f, 2h, 2m, and
2n. The school provides written
notice to parents that the policies
and procedures manual is
available upon request on a
yearly basis. The school
maintains their policies on an
electronic database.

3.1
Policies and
Procedures
Manual
28.09(11)(b)


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 school’s policy and
procedure manual did not
contain 1d, 2i, and 2k.
The school has placed all
of its policies on an online
database, but the database
is not yet accessible to
parents.
The Department will review the
policies that were submitted
after the review. If not
submitted already the school
must submit the policies and
procedures for 1d, 2i, and 2k to
the Department for approval by
March 1, 2006.
Once approved by the
Department the Walker Home
and School mist retrain all staff
on the new policies and
procedures by April 1, 2006.
The school must develop a
procedure for making the
complete policy and procedure
manual available to parents
upon request by March 1,
2006.
4
The school must have a hard
copy of the policy and
procedure manual on-site for
each program by March 1,
2006.
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

3.2
Health Care
Manual
18.05 (9)(d)
Documentation
review
The Walker Home and School has
submitted a Health Care Manual.
4.2
Documentation
review and
interviews
The Walker Home and School
posts first aid and medical
emergency procedures, the location
of the nearest telephones within
each building, and emergency
phone numbers in each building.
The school has evacuation routes
posted in some areas.
Public
Information
and Postings
28.09(6)(a,b,c,
d,e)
28.09(2)(b)(4)
5



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 Walker Home and
School was missing some
policies and procedures from
the Health Care Manual at
the time of the Mid-Cycle
Review. The school was in
the final stages of
completing an electronic
database of all the policies.
Most of the missing policies
were found and submitted
after the date of the review.
Refer to criterion 3.1.
The Department determined
that the Walker Home and
School did not post enough
evacuation routes in order
for students to evacuate the
school building safely.
Specifically, the school
building does not have clear
lines of sight, which make it
difficult to locate the exit in
case of an emergency.
The Walker Home and School
must collaborate with the
Department to determine the areas
of the education building that will
need additional evacuation routes
posted by April 1, 2006.
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

Documentation
review
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)

Documentation
review
The Walker Home and School
has notified the Department of
some substantial changes
through the required Form 1
procedures.
The Walker Home and School
consistently notifies the parent,
the public school district special
education administrator, any
state agency involved in the
student care or placement, and
the Department of Education of
all required incidents that
require immediate notification.
6


Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
The Walker Home and
School has not given the
Department advanced
notice of program/facility
changes. Specifically, the
school did not seek prior
written approval before
closing the Regular
Residential Program.
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
The school must update their
policy on immediate
notification to include prior
approval from the Department
for all form 1 requests by
March 1, 2006.
The school must retrain all
administrative staff on the
updated policy and procedure
by April 1, 2006.
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
Documentation
review and
interviews
The Walker Home and School’s
policy states that the policies and
procedures manual is available
to parents prior to admission.
Students are now required to
have documentation from a
licensed physician of a complete
physical examination not more
than (12) months prior to
admission.

5.1
Student
Admissions
28.09(11)
18.05(1) and (2)


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
Documentation review
indicated that not all
consent forms have been
completed prior to student
admission.
The Walker Home and School
must retrain all admissions staff
on the student admissions
policy to ensure that students
are admitted to the program
with all required consents. A
copy of the agenda and sign in
sheet from the training must be
sent to the Department by
April 1, 2006.
See criterion15.5.
.
The Walker Home and School
must review all student records
and update any records that do
not have all required consents
by March 1, 2006.
The Department will conduct
an on-site visit to review
student records prior to the end
of the school year.
7
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
Documentation
review and
interviews
The Walker Home and School
has contracts signed by both
parties and include all required
elements. Items c, d, k, and l are
included in the documentation
submitted

5.2
Policies and
Procedures for
Coordination/
Collaboration
with Public
School Districts
&
Content
requirements
policies/procedures for
Coordination/
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
8


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 Walker Home and
School was missing some
policies and procedures at
the time of the Mid-Cycle
Review. The school was
in the final stages of
completing an electronic
database that maintains all
the policies.
The Walker Home and School
must revise its’ policy and
procedure for Coordination and
Collaboration with Public
School Districts to meet state
and federal laws and
regulations and submit them to
the Department for review by
April 1, 2006.
Most of the missing
policies were found and
submitted after the date of
the Mid-Cycle Review.
One section of the policies
and procedures that was
submitted after the review
was complete policies and
procedure specific to the
Coordination and
Collaboration with Public
School Districts.
Once approved by the
Department the school must
retrain all educational staff on
the updated policies and
procedures. An agenda and
sign-in sheet for the training
must be submitted to the
Department by May 1, 2006.
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

Documentation
review and
interviews
6.1
Daily
Instructional
Hours
603 C.M.R.
27.00
The Walker Home and School
has provided the Department
with a schedule of the
instructional hours for both the
day and residential programs.


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 school offers
activities that are counted
as instructional time
which are not specified on
student’s IEP’s.
The Walker Home and School
must revise its’ schedule for
daily instructional hours by
April 1, 2006. The schedule
must demonstrate how both the
day and residential program’s
average instructional hours are
based upon student’s IEP’s.
A review of the school
schedule for the summer
months and student’s
IEP’s revealed that not all
IEP goals are addressed
during the summer
months and the 12 -month
program service delivery
page does not match the
services provided.
6.2
School-to-work
(Instructional
hours)
603 CMR
27.02, 27.04
Not Applicable
9
The school must provide a
revised summer schedule that
meets the minimum daily
instructional hours and are
based on the services that are
specified on the student’s IEP’s
by May 1 2006.
Criterion
Number
and
Topic
6.3
Kindergarten
(Instructional
hours)
603 CMR
27.03(5)
6.4
School Days per
Year
28.09(9)
6.5
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

Not Applicable
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

Documentation
review and
interviews
The Walker Home and School
has provided the Department
with a schedule, which includes
the required number of school
days per year.
Not Applicable
Early Release of
High School
Seniors
603 CMR 27.05
10

The Walker Home and
School operates a twelvemonth day program and a
twelve-month residential
program. The school has
developed a different
schedule for the summer
months.
Refer to criterion 6.1.
Criterion
Number
and
Topic
7.1
Curriculum
Frameworks
28.09(9)(b)
7.2
Staff Training
28.09(9)(b)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented



7.3
State/District
Wide
Assessments
28.09(9)(d)
8.4
Current IEP &
Student Roster
28.09

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Documentation
review and
interviews
The Walker Home and School
provides Curriculum
Frameworks training to all staff.
Documentation
review and
interviews
All staff receive training and
have an understanding of the
Curriculum Frameworks.
Documentation
review and
interviews
The Walker Home and School
ensures that all enrolled students
participate in all required State
and/or District wide
assessments. The Walker Home
and School has a written
procedure outlining how the
school will ensure that all
students participate in State
and/or District wide
assessments.
The Walker Home and School
has provided the Department
with a current IEP and student
roster.
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 school has not
provided a list of initials
of students participating in
MCAS testing, either with
or without
accommodations as
required.
The school must provide a list
of initials of the students
participating in MCAS testing,
either with or without
accommodations by April 1,
2006.

Documentation
review and
interviews
11

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

8.7
IEP-Progress
Reports
28.07(3)
20 U.S.C.
Chapter 33,
Section
1414(d)(1)(A)(v
iii)
Documentation
review and
interviews
A review of the Walker Home
and School’s progress reports
showed that the school
consistently documents the
quarter during which the
progress report was written.


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
A review of student
records indicated that not
all of Walker Home and
School’s progress reports
include information on the
extent to which a student’s
progress is sufficient to
achieve the goals by the
end of the year.
The school must retrain all staff
on the policies and procedures
for IEP Progress Reports to
ensure that the progress reports
document the extent to which
such progress is sufficient to
enable the child to achieve the
goals by the end of the year.
The school must submit an
agenda and sign in sheet to the
Department by April 1, 2006.
Some progress reports
were written based upon
rejected or unsigned
IEP’s.
IDEA
Regulations:
300.347
Some progress report
summaries, particularly
those issued in the
summer-months, do not
report on the IEP goals as
required.
12
The school must revise its’
policy on IEP progress reports
to meet state and federal laws
and procedures by April 1,
2006.
The school must retrain all
educational staff on the updated
policy and procedure and
submit an agenda and sign-in
sheet to the Department by
May 1, 2006
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

8.9
IEP Revisions
and Changes
34 CFR 300
Documentation
review and
interviews
The Walker Home and School
has a policy and procedure for
IEP revisions and changes.
13


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
Some school districts have
requested that the Walker
Home and School conduct
team meetings without the
presence of an
administrative
representative from the
responsible school district.
The Walker Home and School
must submit a complete policy
for IEP revisions and changes
by April 1, 2006.
The school must retrain all
educational staff on the new
policy and procedure and
submit an agenda and sign-in
sheet to the Department by
May 1, 2006.
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

Documentation
review and
interviews
8.10
IEP- Less
Restrictive
Placement
28.09(9(c)
9.1
Policies and
Procedures
18.05(5)

Documentation
review
The Walker Home and School
coordinates with the sending
school district to transition
students to the least restrictive
environment.
The Walker Home and School
has developed a comprehensive
set of policies and procedures
dealing with discipline and
behavior management and the
staff consistently utilize these
policies and procedures.
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 Education
and Timelines for
Implementation and Further
Progress Reporting
The Walker Home and
School does not have a
complete policy for IEPless restrictive placement.
Interviews with staff
revealed that the school
had a student who
attended a public school
part-time while
transitioning back to a less
restrictive placement, yet
there was no policy or
procedure.
The Walker Home and School
must submit an updated policy
on IEP-less restrictive
placement to meet state and
federal laws and procedures by
April 1, 2006.
The school must retrain all
educational staff on the new
policy and procedure and
submit an agenda and sign-in
sheet to the Department by
May 1, 2006.
Criterion
Number
and
Topic
9.3
Runaway
Students
18.03(10)
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented


9.5
3-5 Day
Suspensions
18.05(6)

9.6
10+ Day
Suspensions

Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

Interviews
Interviews with staff revealed
that all staff are aware of the
definition of a runaway and are
familiar with the policy and
procedure for a runaway student.
Documentation
review
The Walker Home and School
has a complete policy and
procedure for 3-5 Day
Suspensions.
Documentation
review
The Walker Home and School
has a complete policy and
procedure for 10+ Day
Suspensions.
Joint
responsibilities
of the private
School and the
Sending School
District
34 CFR
300.519-529
15
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
9.7
Terminations
18.05(7)
28.09(12)(b)
10.1
Student:
Teacher Ratios
28.06(6)(d)&(g)
28.09(7)(e)
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 Education
and Timelines for
Implementation and Further
Progress Reporting
The Walker Home and
School is approved as a
12-month program for the
Day and Intensive
Residential Programs.
Documentation review,
personnel records, and
interviews revealed that
the student: teacher ratios
are not the same for the
summer months as during
the school year. Some
instructional groupings do
not have teachers during
the summer months.
The school must develop a plan
to ensure that the student:
teacher ratios are the same
throughout the entire school
year and are approved by the
Department by April 1, 2006.

Documentation
review
The Walker Home and School
has a complete policy and
procedure for Terminations.
Documentation
review and
interviews
The Walker Home and School
has on average a 3:1 ratio during
school hours. Classes are
composed of approximately 8-10
students with at least one
teacher, an assistant teacher, a
child-care worker, and
occasionally an additional intern
or volunteer.
16

Criterion
Number
and
Topic
10.4
Student: Child
Care Ratios
28.09(7)
18.01(2)
11.1
Personnel
Policies
28.09(7)
28.09(11)(a)
18.05(11)
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
Documentation
review and
interviews
The childcare ratios for the
Intensive Residential Program
are 8 students to 3 staff in the
afternoon, in which supervisors
and float staff are not included
in the ratio. The overnight staff
ratio is approximately 8 students
to 2 staff. (See 10.1 for Day
program ratios)
Documentation
review and
interviews
The Walker Home and School
has a set of written personnel
policies and procedures. The
Walker Home and School
recently revised its’ written plan
for using volunteers and/or
intern services.

17
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 Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

11.3
Educational
Administrator
Qualifications
28.09(7)(a)
603 CMR
44.00 and 44.04
11.4
Teachers
Special
Education
Teachers and
Regular
Education
Teachers
28.09(7)(b)(c)
18.05(11)(f)


Documentation
review and
interviews

Documentation
review and
interviews
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 Educational
Administrator does not
meet the required
qualifications to serve in
this role.
Documentation must be
submitted by March 1, 2006
that shows evidence that the
person serving in the role of
Educational Administrator is
qualified to serve in this role.
Not all teaching staff at
the Walker Home and
School have a license or
an approved waiver issued
by the Department.
The Walker Home and School
must ensure that all teaching
staff are appropriately licensed
or on an approved waiver by
submitting an updated teacher
roster that specifies the
requirements as listed in this
criterion by March 1, 2006.
For teachers who do not hold
the appropriate license and/or
waiver by March 1, 2006, a
plan specific to coming into
compliance is required to be
submitted as well.
18
Criterion
Number
and
Topic
11.4(a)
Professional
Development
Plans
28.09(7)(b)(c)
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

Documentation
review and
interviews
The Walker Home and School
develops and approves
professional development plans
for staff holding a professional
license.
18.05(11)(f)
11.5
Related
Services Staff
28.09(7)(d)

Documentation
review and
interviews
All Walker Home and School’s
related service staff hold an
appropriate license.
11.6
Master Staff
Roster
28.09(7)

Documentation
review
The Walker Home and School
has provided the Department
with an updated Master Staff
Roster for both the Day and
Intensive Residential Programs.
11.7
Job
Descriptions
18.05(11)(d)

Documentation
review
The Walker Home and School
maintains job descriptions for all
staff positions.
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 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



11.8
Salary Ranges
18.05(11)(e)
Documentation
review
11.9
Organizational
Structure
28.09(7)
28.07(c)
11.11
Supervision of
Students
28.09(7)
Documentation
review
The Walker Home and School
has provided the Department
with a current organizational
chart.
Documentation
review and
interviews
The Walker Home and School
has a detailed plan for the
supervision of students.

20

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 Walker Home and
School has not provided
the Department with a list
of the salary ranges for all
staff positions.
The Walker Home and School
must provide the Department
with a list of the salary ranges
for all staff by March 1, 2006.
See criterion 4.4
See criterion 4.4.
Criterion
Number
and
Topic
11.12
Accessibility of
Extracurricular
Activities
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, s. 5; 603
CMR 26.06
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
Documentation
review and
interviews
The Walker Home and School’s
extracurricular activities are
accessible to all students.

21
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
12.1
Staff
Orientation
Training
18.05 (11)(g)
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)
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
Documentation
review
The Walker Home and School
provides all required orientation
trainings to new staff prior to
working directly with students.
Documentation
review
The Walker Home and School
provides annual trainings to all
staff, which, is documented in
personnel records.
Documentation
review
Documentation and staff
interviews revealed that there
are procedures for obtaining and
recording data regarding student
discipline and behavior along
with a description of how such
data is integrated into IEP team
discussions.

22
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
12.2(b)
Child Abuse
Reporting
18.05(9)(j)
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
Documentation
review and
interviews
All staff have now received
training in reporting child abuse
and neglect to both the
Department of Social Services
and/or the Disabled Persons
Protection Committee.

12.2 (d)
Medication
Training
18.05(9)(f)(3)©

Documentation
review and
interviews
All staff providing direct care to
students, who receive
medication, now receive training
that includes the nature of the
medication, potential side effects
and any special precautions or
requirements.
12.2(i)
Staff
Evaluations
18.05(110©1

Documentation
review and
interviews
All written performance
evaluations are maintained on
staff and personnel are evaluated
annually.
23
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
13.3
Comparability
of Facilities
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

Observations
and interviews
The Walker Home and School
has co-ed residences, which are
comparable in size for all
students.
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)
24
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
15.1
Parental
Involvement
and Parents’
Advisory Group
18.05(4)(a)
15.2
Orientation
Procedures
28.09(11)
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
Documentation
review and
interviews
The Walker Home and School’s
Parents Advisory Group meets
monthly and advises the schools
on matters that pertain to the
education, health and safety of
the students.
Documentation
review and
interviews
The Walker Home and School
has developed a more formal
process for orientation
procedures for parents and
students. The school has an
Admissions Coordinator who is
responsible for providing
orientation to parents.

25
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 Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

15.3
Information to
be translated
into Languages
other than
English
Documentation
review
The Walker Home and School
has recently developed an
updated policy and procedure
for information to be translated
into languages other than
English.
Title VI;
EEOA: 20
U.S.C. 1703(f);
M.G.L. c. 76, s.
5; 603 CMR
26.02(2)
26


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 Walker Home and
School’s submitted a new
policy and procedure for
Information to be
Translated into Languages
other than English after
the review.
All staff must be trained on the
new policy and a copy of the
training agenda and sign-in
sheet must be submitted to the
Department by May 1, 2006.
The school must submit to the
Department a sample of a
document that has been
translated into another language
by May 1, 2006.
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
Documentation
review and
interviews
Consents for IEP related matters
and restraint procedures were
consistently found in the Walker
Home and School’s student
files.

15.5
Parent Consent
28.07(1)(b)
27


Findings Regarding
Incomplete
Implementation of
Approved Corrective
Action Plan or
Identification of
Additional Issues of
Noncompliance
Consents for human
sexuality training were not
found in the Walker Home
and School’s student
records.
Further Corrective Action
Ordered by the
Department of Education
and Timelines for
Implementation and Further
Progress Reporting
See criterion 5.1.
Criterion
Number
and
Topic
15.8
Registering
Complaints
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

Documentation
review
The Walker Home and School
has a policy and procedure for
registering complaints.
Documentation
review
The Walker Home and School
now has emergency first aid
procedures that include all
required elements.
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.
722(g)(1)(J)(ii)
16.4
Emergency
First Aid

18.05(9)(e)
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 Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

16.5
Administration
of Medication
Documentation
review and
interviews
The Walker Home and School
has a policy and procedure for
administration of medication.
18.05(9)(f)


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 policy and procedure
for administration of
medication does not meet
all of the Department’s
requirements.
The Walker Home and School
must submit an updated policy
and procedure on
administration of medication to
meet state and federal laws and
procedures by March 1, 2006.
Walker Home and School must
train all staff on the new policy
and procedure by
April 1, 2006.
A copy of the agenda and sign
in sheet must be submitted to
the Department by May 1,
2006.
29
Criterion
Number
and
Topic
16.6
Administration
of
Antipsychotic
Medication
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

Documentation
review and
interviews
The Walker Home and School
has developed a policy and
procedure for administration of
antipsychotic medication.
18.05(9)(f)(9)
30
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 Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified
Documentation
review and
interviews
The Walker Home and School
recently submitted a complete
policy for preventive health care.

16.7
Preventive
Health Care
18.05(9)(f)(9)(h)
31


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 Walker Home and
School’s submitted a
complete policy for
preventive health care
after the program review.
All staff must be retrained on
the new policy and procedure
and a copy of the training
agenda and sign-in sheet must
be submitted to the Department
by April 1, 2006.
Criterion
Number
and
Topic
16.9
Students with
Comfort
Care/Do Not
Resuscitate
Orders
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

Documentation
review
The Walker Home and School
has a policy and procedure for
students with comfort care/do
not resuscitate orders.
32
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
16.10
Meningococcal
Disease and
Vaccination
Implementation Status of
Requirements
or
Corrective
Action Plan
Determined to
be Substantially
Implemented

Not Applicable
Method(s)
of Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

The Walker Home and School
does not have students in grades
9-12 and therefore is not
required to have a policy for
Meningococcal-Disease and
Vaccination.
MGL, Chapter
76, s.15D
105 CMR
220.700
33
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 Verification
Comments Regarding
Corrective Action Plan
Implementation
Corrective
Action Plan
Determined
to be Not
Fully
Implemented or
Additional
Issues
Identified

18.2
Student Records
28.09(10)
Documentation
review
The Walker Home and School
has a recent picture of each
student in the student records.
MGL c. 71, s.
34H
603 CMR 23.00
Family
Educational
Rights and
Privacy Act
(FERPA)
34


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 Walker Home and
School has stored all of
the student’s information
from the face sheets on an
electronic database.
During the review, a hard
copy of the Walker Home
and School’s face sheets
did not include all of the
required items. The
school was able to update
the hard copy of all of the
face sheets shortly after
the on-site visit.
The Walker Home and School
must develop a policy to ensure
that all face sheets are updated
annually and include all
required elements and submit it
to the Department by April 1,
2006.
The Department will conduct
an on-site visit to ensure that
there is a hard copy on the face
sheet in each student’s file.