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 January 10, 2007 Dr. Louis Abbate Executive Director Willie Ross School for the Deaf 32 Norway Street Longmeadow, MA 01106 Re: Onsite Follow-up Monitoring Report: Program Review Corrective Action Plan Verification and Mid-cycle Review Dear Dr. Abbate, 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 July 19, 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. We are pleased to indicate that the Department of Education has found your school’s approved Corrective Action Plan to be substantially implemented and effective in remedying previously identified noncompliance issues. Additionally, we have determined that your school is in substantial compliance with any new state or federal special education requirements enacted since your last Program Review. The findings of the Department are included in the attached Follow-up Monitoring Report. You and your entire staff are to be congratulated for your efforts in implementing all necessary improvements. Your private school will now receive an updated status of “Full Approval.” This approval shall remain in effect for three (3) years from the date of this letter and attached approval certificate. This approval will be contingent upon continued compliance with all regulations contained within 603 CMR 28.00 “Special Education Regulations” and 603 CMR 18.00 “Program And Safety Standards For Approved Public Or Private Day And Residential Special Education School Programs.” The Department of Education may change this approval status at any point during this three-year period if circumstances arise that warrant such a change. The Department will notify you of your school’s next regularly scheduled Program Review several months before it is to occur. At this time we anticipate the Department's next routine monitoring visit to occur sometime during FY 2010, unless the Department determines that there is some reason to schedule this visit earlier. 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 413- 858-4591. Sincerely, Sandra K. Hanig, Education Specialist Program Quality Assurance Services Darlene Lynch, Director Program Quality Assurance Services c: David P. Driscoll, Commissioner of Education Susan Phillips, Chairperson, Board of Directors Encl.: Follow-up Monitoring Report Application Face Sheet Full Approval Certificate, Expiration date: August 31, 2010 2 Willie Ross Mid-Cycle Report January 10, 2007 MASSACHUSETTS DEPARTMENT OF EDUCATION PRIVATE SCHOOL MID-CYCLE PROGRAM REVIEW Willie Ross School for the Deaf ONSITE VERIFICATION OF CORRECTIVE ACTION PLAN IMPLEMENTATION AND/OR IDENTIFICATION OF ADDITIONAL FINDINGS REQUIRING CORRECTIVE ACTION Action Plan Submitted on September 3, 2004 Progress Reports Submitted on January 30, 2006 Onsite Visit Conducted on November 20, 2006 Date of this Report: January 10, 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 2.2 Approvals, Licenses, Certificates of Inspection 28.09 (2)(b)4-5 28.09(5) 28.09(6) 18.04(1) Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that the school has all required inspections and licenses on file. 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 2.3 Not Applicable Willie Ross School For the Deaf is a day program. OCCS Licensure (Not Applicable to Day Schools) 2 Willie Ross Mid-Cycle Report January 10, 2007 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 3.2 Health Care Manual 18.05 (9)(d) (formerly 3.1, 3.2, 3.3) Documentation The concern at the time of the January 2004 program review was that the school did not have a single Health Care Policies and Procedures Manual containing all mandated health-related policies and procedures. The finding during the November 2006 mid-cycle review was that Willie Ross now has a separate Health Care Manual. It contains a policy on all required topics. The letter from the physician reviewing approving the Health Care Manual is dated within the past 12 months. 3 Willie Ross Mid-Cycle Report January 10, 2007 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 4.4 Advanced Notice of Program/ Facility Change 28.09(5)(c) Documentation and Interview The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that the school submitted its policy on notifying the DOE of program and facilities change, a copy of the Form 1 it uses and a copy of the Form 1 notifications it has submitted to the DOE in the past year and continues to be fully in compliance with this criterion. 4 Willie Ross Mid-Cycle Report January 10, 2007 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 4.5 Immediate Notification 18.03(10) 18.05(7) 28.09(12) Documentation and Interview The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that the school continues to fully implement this criterion. 5 Willie Ross Mid-Cycle Report January 10, 2007 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 5.1 Student Admissions 28.09(11) 18.05(1) and (2) Documentation review The concern at the time of the January 2004 program review was that the school had not made all mandated policies and procedures available to parents, student and the placing public school district prior to admission. The finding at the time of the November 2006 midcycle review was that Willie Ross School has revised its admissions policy to now state that parents and students (if appropriate) receive a copy of the Parent Manual that contains many policies prior to admission and the school district, parents and teachers are notified via letter that all policies and procedures are available for review at any time. 6 Willie Ross Mid-Cycle Report January 10, 2007 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 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 Documentation and Interview The concern at the time of the January 2004 program review was that the school did not have a separate Policies and Procedures Manual and Health Care Manual. The finding at the time of the November 2006 mid-cycle review is that Willie Ross School now has separate Policies and Procedures and Health Care Manuals. Willie Ross School has developed required policy on collaboration with public school districts. (Formerly 5.3 and 5.4) 7 Willie Ross Mid-Cycle Report January 10, 2007 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 6.1 Daily Instructional Hours 603 C.M.R. 27.00 Documentation and Interview The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that block schedules indicate that elementary students receive an average of at least 5 hours of structured learning time; high school students receive at least 5.5 hours. 8 Willie Ross Mid-Cycle Report January 10, 2007 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 6.2 School-to-work (Instructional hours) 603 CMR 27.02, 27.04 Documentation and Interview This criterion was not evaluated at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School has developed a School to Work Policy that describes the school to work program with written guidelines to ensure that students meet IEPs goals in the school to work placement as well as instruction in all core academic subjects during classroom time. The school has developed an evaluation checklist that is used for student evaluation and progress toward IEP goals in the school to work placement. 9 Willie Ross Mid-Cycle Report January 10, 2007 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 6.3 Documentation and Interview Kindergarten (Instructional hours) 603 CMR 27.03(5) The finding at the time of the November 2006 mid-cycle review was that the Kindergarten class exceeds required instructional learning time. 6.4 School Days per Year 28.09(9) (Formerly 6.2) This criterion was not evaluated at the time of the January 2004 program review. Documentation and Interview The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that the private school follows the school calendar for East Longmeadow public schools and contains 180 days + 5 additional days for emergency closures. 10 Willie Ross Mid-Cycle Report January 10, 2007 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 6.5 Early Release of High School Seniors 603 CMR 27.05 Documentation and Interview This criterion was not evaluated at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School has developed a written policy on the early release of high school seniors that states that graduating seniors may be released 12 school days prior to the end of the school year. The school reports that it follows the East Longmeadow public school calendar. 11 Willie Ross Mid-Cycle Report January 10, 2007 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 7.1 Curriculum 28.09(9)(b) (formerly 1.3) Documentation and Interview The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross has a well- developed written curriculum adapted for its population that is based upon the Massachusetts Curriculum Frameworks. 12 Willie Ross Mid-Cycle Report January 10, 2007 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 7.3 State/District Wide Assessments 28.09(9)(d) Documentation and Interview The concern at the time of the January 2004 program review was that the school has not developed written procedures outlining how the school will ensure that all students participate in state and district assessments. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School has developed a policy on administering MCAS and the MCAS alternate exam. The school also provided evidence that the form of MCAS that a student will take is discussed at each IEP Team meeting, evidence that staff members have been trained in MCAS alternate testing and the list of students participating in both the MCAS and alternate exams. 13 Willie Ross Mid-Cycle Report January 10, 2007 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 8.1 Implementation -Educational Services 28.04 and 28.09(8) 34 CFR 300.24 Documentation The concern at the time of the January 2004 program review was that the school had not developed a written description regarding how it provides students with daily living skills, social emotional needs or physical education. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School for the Deaf has developed a written description of how it provides students with daily living skills, social emotional needs or physical education. 14 Willie Ross Mid-Cycle Report January 10, 2007 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 8.4 Program Modifications and Support Service for Limited English Proficient Students Title VI: 42 U.S.C. 2000d; 34 CFR 100.3(a), (b); EEOA: 20 U.S.C. 1703(f); M.G.L.c. 71, s.38Q1/2; 603 CMR 28.03(3)(a); M.G.L.c. 71A, ss.2 (e), 4; 603 CMR 14.04; M.G.L.c. 76, s. 5; 603 CMR 26.03 Documentation Student Record Review and Interview This criterion was not evaluated at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that all students who attend Willie Ross School for the Deaf required special language assistance. Willie Ross School submitted a copy of its adapted English Language Arts Curriculum for all students. Each IEP included modifications for English language and reading development. 15 Willie Ross Mid-Cycle Report January 10, 2007 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 8.5 Current IEP & Student Roster 28.09 (formerly 8.4) Documentation and Interview The school was found to be in compliance with this criterion at the time of the January 2004 program review. The school did not always have an IEP on file that was signed by the student’s parent or guardian but the school presented documentation indicating that it had requested copies of the signed IEP from the sending school district, however in many cases the sending school district had not responded. The finding at the time of the November 2006 mid-cycle review was that the private school has made repeated attempts through both letters and phone calls to obtain a signed copy of the IEP for each student enrolled. Please note that the school must follow the IEP that is signed by the parent and school district and not the most currently developed, but unsigned IEP. 16 Willie Ross Mid-Cycle Report January 10, 2007 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 8.7 IEP- Progress Reports 28.07(3) 20 U.S.C. Chapter 33, Section 1414(d)(1)(A)(v iii) 34 CFR 300.347 Documentation The school was found to be in compliance with this criterion at the time of the January 2004 program review. A comment was made that information regarding persons or agencies receiving progress reports were maintained as a simple list. The school had not maintained cover letters in student records to document who received reports. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School has developed a form to record the date progress reports are sent to the LEA, parent and student file. 17 Willie Ross Mid-Cycle Report January 10, 2007 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 8.9 IEP- Revisions and Changes 34 CFR 300 (Formerly 8.8) Documentation and Interview The concern at the time of the January 2004 program review was that the school had not received or retained copies of the IEP TEAM sign in sheets; therefore, it was not possible to determine whether required persons attended all IEP Team meetings. A review of 6 randomly chosen IEPS at the time of the November 2006 mid-cycle review indicates that IEP sign in sheets are filed in each student record. All required persons are in attendance at each IEP meeting. 18 Willie Ross Mid-Cycle Report January 10, 2007 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 8.11 IEP- Transition Planning 34 CFR 300.347(b)(1) 34 CFR 300.347(b)(2) (formerly 8.10) Student Record Review The concern at the time of the January 2004 program review was that IEPs of all students over the age of sixteen (16) did not contain vision statements and statements of needed transition services. A review of student records at the time of the November 2006 mid-cycle review indicate that all records reviewed contained a vision statement and statement of needed transition services. 19 Willie Ross Mid-Cycle Report January 10, 2007 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 9.1 Policies and Procedures 18.05(5) Documentation and Interview The concern at the time of the January 2004 program review was that the Willie Ross Campus Program did not have sufficient numbers of staff members trained in physical restraint. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School requires five staff members to be trained in CPI. Staff member certifications expired in October 2006. Staff members attended a 6-hour refresher course in October 2006. Willie Ross School for the Deaf plans to have at least two more staff members fully training by the end of the 20062007 academic year. 20 Willie Ross Mid-Cycle Report January 10, 2007 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 9.3 Runaway Students 18.03(10) Documentation and Interview The concern at the time of the January 2004 program review was that the school had recently developed a written policy and procedure for handling students who run away from the program, however, staff had not been trained to implement this policy and procedure. The finding at the time of the November 2006 mid-cycle review was that the runaway policy is appropriate and the private school submitted evidence of staff training on this policy in August 2006. 21 Willie Ross Mid-Cycle Report January 10, 2007 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 9.4 Restraints 18.05 (5)(h) 603 CMR 46.00 102 CMR 3.00 Documentation and Interview The concern at the time of the January 2004 program review was that the Willie Ross Campus Program did not have sufficient numbers of staff members trained in physical restraint. The finding at the time of the November 2006 mid-cycle review was that five staff members have Crisis Prevention Intervention (CPI) training. Willie Ross School submitted a copy of CPI certificates that indicate these staff members completed refresher training in October 2006. 22 Willie Ross Mid-Cycle Report January 10, 2007 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 9.5 3-5 Day Suspensions 18.05(6) Documentation The concern at the time of the January 2004 program review was that the school did not have a written policy or procedure related to suspensions. The finding at the time of the November 2006 mid-cycle review was that Willie Ross has developed a suspension policy that contains all required elements, a log to track suspension and a letter to notify parents, LEA and other agencies involved of suspensions. 23 Willie Ross Mid-Cycle Report January 10, 2007 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 9.7 Terminations 18.05(7) 28.09(12)(b) Documentation and Interview The concern at the time of the January 2004 program review was that the school did not have a written policy or procedure related to terminations. The finding at the time of the November 2006 mid-cycle review was that Willie Ross has developed a policy on planned, unplanned (defined as when a student’s family suddenly moves out of the area or child is unable to attend classes) and emergency terminations that contains all required information. 24 Willie Ross Mid-Cycle Report January 10, 2007 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 10.1 Student: Teacher Ratios 28.06(6)(d)&(g) 28.09(7)(e) Documentation and Interview The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that at the Longmeadow Campus, Student: Teacher: Teacher Aid ratio for elementary students is 6 or 7:1:1, for middle is 4-6:1:1 and in the high school is 5:1:1. At the East Longmeadow Partnership program campus, the student:teacher:teacher aide ratio in elementary and middle school classes is 3-6:1:1/2. The high school ratio is 2-7:1:1. 25 Willie Ross Mid-Cycle Report January 10, 2007 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 10.4 Student: Child Care Ratios 28.09(7) 18.01(2) Not Applicable Documentation Willie Ross School is a day program. 26 Willie Ross Mid-Cycle Report January 10, 2007 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 11.1 Personnel Policies 28.09(7) 28.09(11)(a) 18.05(11) Documentation and interview The concern at the time of the January 2004 program review was that the school did not have sufficient written policies and procedures for handling staff complaints, working with volunteers and interns or nondiscrimination when hiring. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School for the Deaf has developed a policy and a complaint form for handling staff complaints as well as policies for working with volunteers and interns and nondiscrimination when hiring. 27 Willie Ross Mid-Cycle Report January 10, 2007 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 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 was found to be fully in compliance with this criterion at the time of the January 2004 program review. Submit a copy of the current Massachusetts Department of Education license or approved waiver for that one teacher to the Department of Education by February 28, 2007. 11.3 Educational Administrator Qualifications 28.09(7)(a) 603 CMR 44.00 and 44.04 11.4 Documentation and Interview The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that the Educational Administrator has a current DOE license and master’s degree in deaf education. Documentation and Interview Teachers Special Education Teachers and Regular Education Teachers 28.09(7)(b)(c) 18.05(11)(f) The finding at the time of the November 2006 mid-cycle review is that one teacher does not have a DOE license or approved waiver. 28 Willie Ross Mid-Cycle Report January 10, 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 11.4(a) Professional Development Plans 28.09(7)(b)(c) 18.05(11)(f) Documentation and Interview This criterion was not required at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School for the Deaf submitted required information on professional development plans for its DOE professionally licensed teachers, including the Speech and Language Pathologist. 29 Willie Ross Mid-Cycle Report January 10, 2007 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 11.5 Documentation and Interview Related Services Staff 28.09(7)(d) 11.6 Master Staff Roster 28.09(7) The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that the Related Services Roster includes information on each related service provider’s role in the program and all related services providers hold current licenses. Documentation The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School for the Deaf submitted a Master Staff Roster that contains all required information. 30 Willie Ross Mid-Cycle Report January 10, 2007 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 11.7 Documentation Job Descriptions 18.05(11)(d) 11.8 Salary Ranges 18.05(11)(e) Documentation This criterion was not evaluated at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School has developed job descriptions for each position that includes all required elements, including UFR #, title, qualifications and description of duties. This criterion was not evaluated at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School submitted information on the salary range for each position. 31 Willie Ross Mid-Cycle Report January 10, 2007 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 11.9 Organizational Structure 28.09(7) 28.07(c) Documentation The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School submitted a copy of the organizational chart. 32 Willie Ross Mid-Cycle Report January 10, 2007 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 11.11 Supervision of Students 28.09(7) Documentation and Interview The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School submitted block schedules that indicate supervision of students during its day program. For after school and field trips the staff to student ratio is equal to or more intensive than in the classrooms. 33 Willie Ross Mid-Cycle Report January 10, 2007 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 11.12 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 Documentation and Interview The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School’s policy on participation in extracurricular activities indicates that all students may participate with parental permission. Interview indicates that, on an individual case-bycase basis, a student may be required to maintain attendance standards at the school in order to participate in extra curricular activities. 34 Willie Ross Mid-Cycle Report January 10, 2007 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 12.1 Staff Orientation Training 18.05(11)(g) Documentation review The concern at the time of the January 2004 program review was that the school did not have a written plan describing how newly hired staff would be provided training on all required topics if staff were hired midyear and were not able to attend the annual orientation session for all employees. At the time of the November 2006 mid-cycle review was that Willie Ross School submitted a copy of its written plan on training new employees. This plan states that it is the responsibility of the Educational Administrator to ensure that new employees are fully trained in all required topics prior to working directly with staff members. 35 Willie Ross Mid-Cycle Report January 10, 2007 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 12.2 Annual InService Training Plan and Calendar 28.09(7)(f) 18.05(11)(h) Title VI: 42 U.S.C.2000d;34 CFR 100.3;EEOA:20 U.S.C.1730(f); Title IX: 20 U.S.C.1681; 34 CFR 106.31106.42; M.G.L.c.76, s.5; 603 CMR 26.00, esp.26.07(2),(3) Documentation Review of Personnel Records and Interview The concern at the time of the January 2004 program review was that the school had not provided annual training to all staff providing direct care to students on the topics of administration of medication, transportation policy, behavior management policies or civil rights. The finding at the time of the November 2006 mid-cycle review was that the 2006-2007 In-Service Training Schedule includes training on all required topics. All staff members are required to attend training all required DOE topics. 36 Willie Ross Mid-Cycle Report January 10, 2007 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 12.2 (a) Behavior Management and Restraint Training 28.09(11) 18.05(5) Documentation and Interview The concern at the time of the January 2004 program review was that the Willie Ross Campus Program did not have sufficient numbers of staff trained in physical restraint. The finding at the time of the November 2006 mid-cycle review was that five staff members receive full Crisis Prevention Intervention (CPI) restraint training. They took a refresher course in October 2006 have received current certification. By the end of the 2006-2007 academic year, Willie Ross School plans to have additional staff members trained in the use of restraints. 37 Willie Ross Mid-Cycle Report January 10, 2007 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 12.2 (b) Child Abuse Reporting 18.05(9)(j) Documentation and Interview The concern at the time of the January 2004 program review was that the school did not have written procedures for the reporting of suspected child/student abuse. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School submitted a copy of its policy on reporting abuse or neglect. This policy discusses reporting abuse or neglect of students under age 18 to the Department of Social Services and notifying the Disabled Persons Protection Commission of the suspected abuse or neglect of students age 18 or older. 38 Willie Ross Mid-Cycle Report January 10, 2007 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 12.2 (d) Medication Training 18.05(9)(f)(3) (c) Documentation and interview The concern at the time of the January 2004 program review was that the school had not provided training to its staff member by a physician or registered nurse that included the nature of the medication, potential side effects and any special precautions or requirements. At the time of the November 2006 mid-cycle review, Willie Ross submitted documentation that it has planned training on medication side effects for February 1, 2007. No staff members are trained in administering medications. Currently no students take medications during the school day. A nurse is on staff every day to administer medications during the school day, if necessary. 39 Willie Ross Mid-Cycle Report January 10, 2007 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 12.2 (g) Interns and Volunteers Training 18.05 (11)(I) Documentation and Interview The concern at the time of the January 2004 program review was that the school did not have a training plan for interns or volunteers. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School for the Deaf has a written policy on Interns and Volunteers that includes information on how they will be provided with supervision and training. 40 Willie Ross Mid-Cycle Report January 10, 2007 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 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) Documentation and Interview This criterion was not evaluated at the time of the January 2004 program review. At the time of the November 2006 mid-cycle review Willie Ross School for the Deaf submitted the name of the staff person responsible for ensuring that all restroom facilities are comparable for both genders. At this time there are no facilities that are separate for any other reason. 41 Willie Ross Mid-Cycle Report January 10, 2007 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 15.1 Parental Involvement and Parents’ Advisory Group 18.05(4)(a) Documentation and Interview The school was found to be fully in compliance with this criterion at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School has developed a written plan for involving parents, has named a staff person to liaison with the Parent Advisory Group (PAG), held PAG meetings and scheduled additional PAG meeting for the spring semester. 42 Willie Ross Mid-Cycle Report January 10, 2007 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 Title VI; EEOA: 20 U.S.C. 1703(f); M.G.L. c. 76, s. 5; 603 CMR 26.02(2) Documentation and Interview This criterion was not evaluated at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School submitted the name and job description of the staff member who provides parents with verbal and written translations into Spanish, procedures for documenting these translations and examples of notices that have been translated. 43 Willie Ross Mid-Cycle Report January 10, 2007 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 15.8 Registering Complaints 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) (Formerly 15.7) Documentation review The concern at the time of the January 2004 program review was that the school had not developed written procedures to be used by students and parents to register complaints regarding the students’ education and care at the school. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School for The Deaf has developed policies and procedures for parents and students to file a complaint. These procedures are written in the Parent Handbook and Policies and Procedures Manual. 44 Willie Ross Mid-Cycle Report January 10, 2007 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 16.1 Health Care Policy and Procedure Manual 18.05(9)(c) 18.05(9)(d) Documentation The concern at the time of the January 2004 program review was that the school did not have a written Health Care Policies and Procedures Manual. The finding at the time of the November 2006 mid-cycle review was that the school now has a separate Health Care Policies and Procedures Manual. 45 Willie Ross Mid-Cycle Report January 10, 2007 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 18.05(9)(f) Documentation and Interview The concern at the time of the January 2004 program review was that the school had not developed written policies and procedures for staff training regarding medications. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School for the Deaf has a written policy that states that staff members do not administer medications to students; only a nurse may administer medications, including over the counter medications. 46 Willie Ross Mid-Cycle Report January 10, 2007 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 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 concern at the time of the January 2004 program review was that the school did not have a policy on the administration of antipsychotic medications. Submit a revised policy on administration of antipsychotic medication to the Department of Education by February 28, 2007. 16.6 Documentation and Interview Administration of Antipsychotic Medication 18.05(9)(f)(9) The finding at the time of the November 2006 mid-cycle review was that the school’s policy on the administration of anti-psychotic medication does not include all required elements. 47 Willie Ross Mid-Cycle Report January 10, 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 16.7 Preventive Health Care 18.05(9)(f)(9) (h) Documentation and Interview The concern at the time of the January 2004 program review was that the school’s written plan for providing preventative health care was not sufficient. It did not include procedures when dealing with a staff member or student with a communicable disease, protecting students from allergens or providing students with information on family planning. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School for the Deaf has developed policies in its Policy and Procedure Manual on procedures to deal with staff members or students with communicable diseases, students with allergies and providing students with information on family planning. 48 Willie Ross Mid-Cycle Report January 10, 2007 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 16.10 Meningococcal Disease and Vaccination MGL, Chapter 76, s. 15D 105 CMR 220.700 Not Applicable This is a new criterion that was not evaluated at the time of the January 2004 program review. The finding at the time of the November 2006 mid-cycle review was that Willie Ross School is approved as a day program and is not required to have a policy on Meningococcal Disease and Vaccination, although following advice from the Department of Health, the school did send information to parents on this topic. 49 Willie Ross Mid-Cycle Report January 10, 2007 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 17.1 Transportation Safety 28.09(11)(b) Documentation Interview and Personnel Record The concern at the time of the January 2004 program review was that the school had not ensured that all persons who operate a school owned vehicle received in-service training on overall transportation safety. At the time of the November 2006 mid-cycle review, Willie Ross School for the Deaf submitted an agenda and sign-in sheet for its staff training on transportation policies. A review of personnel records indicates that a current driver’s license on file for each staff member who drives students in school owned vehicles. 50 Willie Ross Mid-Cycle Report January 10, 2007 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 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 was found to be fully in compliance with this criterion at the time of the January 2004 program review. Submit a revised student record face sheet to the Department of Education by February 28, 2007 that includes all required elements. 18.2 Student Record Review and Interview Student Records 28.09(10) MGL c. 71, s. 34H 603 CMR 23.00 The finding at the time of the November 2006 mid-cycle review was that the face sheet does not include all required elements. Family Educational Rights and Privacy Act (FERPA) 51 Willie Ross Mid-Cycle Report January 10, 2007