Massachusetts Department of Elementary and Secondary Education 75 Pleasant Street, Malden, Massachusetts 02148-4906 Telephone: (781) 338-3700 TTY: N.E.T. Relay 1-800-439-2370 December 6, 2012 Elizabeth Folcarelli, Executive Director Youth Opportunities Upheld, Inc. Day and Cottage Hill Academy Residential Programs 81 Plantation Street Worcester, MA 01604 Re: Mid-cycle Review and Verification of previous Program Review Corrective Action Plan Dear Ms. Folcarelli: Enclosed is the Department of Elementary and Secondary Education’s (“Department”) Midcycle Report based upon the Mid-cycle review conducted in your private school programs in November, 2012. This Mid-cycle Review Report contains the Department's findings regarding the implementation status and effectiveness of corrective steps taken in response to your previous Program Review Report issued on September 1, 2010. This report also includes a report on the status of implementation for new state or federal special education requirements enacted since your programs last Program Review. We are pleased to indicate that the Department has found your programs approved Corrective Action Plan to be substantially implemented and effective in remedying previously identified noncompliance issues. Additionally, we have determined that your programs are in substantial compliance with any new state or federal special education requirements enacted since your last Program Review. You and your entire staff are to be congratulated for your efforts in implementing all necessary improvements. Your programs will now receive an updated status of “Full Approval.” This approval shall remain in effect for three (3) years and 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 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 program’s next regularly scheduled Program Review Page 1 of 2 several months before it is to occur. At this time we anticipate the next routine monitoring visit to occur sometime during the 2015-2016 school year, unless the Department determines that there is some reason to schedule this visit earlier. Please be advised that the attached Department Approval Certificate must be conspicuously posted in a public place within the program as required by 603 CMR 28.09. Your staff's cooperation throughout these follow-up monitoring activities is appreciated. Should you require additional clarification of information included in our report, please do not hesitate to contact the Onsite Team Chairperson at 781-338-3719. Sincerely, Amy B. Krukonis, Mid-cycle Review Chairperson Program Quality Assurance Services Darlene Lynch, Director Program Quality Assurance Services c: Mitchell D. Chester, Ed.D., Commissioner of Elementary and Secondary Education Michael Keegan, Chairperson, Board of Directors Kristin Mayotte, Local Program Review Coordinator Encl.: Mid-cycle Review Report Full Private School Approval Certificate, Expiration Date: August 31, 2016 Page 2 of 2 MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION PRIVATE SCHOOL MID-CYCLE REVIEW Youth Opportunities Upheld, Inc. Day Program Cottage Hill Academy Residential Program MID-CYCLE REVIEW REPORT Previous Program Review Corrective Action Plan Submitted on October 4, 2010 Progress Reports Submitted on December 15, 2010; January 18, 2011; April 19, 2011 Mid-cycle Onsite Visit Conducted on November 27-28, 2012 Date of this Report: December 6, 2012 Youth Opportunities Upheld, Inc., Day and Cottage Hill Residential Programs, Mid-cycle Review Report December 6, 2012 Page 1 of 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 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Selected Approved Private School Program Mid-cycle Review Criteria 2.2 Approvals, Licenses, Certificates of Inspection 18.04(1); 28.09(2)(b)(5); 28.09(5) (b); 28.09(6) (b, c) Documentation Youth Opportunities Upheld, Inc. (“YOU, Inc.”) day and residential programs have current licenses, approvals and certificates of inspection by state and local agencies as required. 2.3 EEC Licensure 102 CMR 3.00 (Residential Programs only) Documentation YOU, Inc.’s Cottage Hill Academy Residential Program has a current, full license from the Department of Early Education and Care as required. Youth Opportunities Upheld, Inc., Day and Cottage Hill Residential Programs, Mid-cycle Review Report December 6, 2012 Page 2 of 11 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic 6.1 Daily Instructional Hours 603 CMR 27.04 & 6.4 School Days Per Year Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Documentation YOU, Inc. day and residential programs submitted documentation that verifies the required number of school days and the required number of instructional hours are being offered to all students. Documentation Student Record Review Interviews YOU, Inc. day and residential programs have current IEP’s for each enrolled Massachusetts student that have been issued by the responsible public school district and consented to and 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 603 CMR 27.05(2); 28.09(9)(a) 8.5 Current IEP & Student Roster 28.09(5)(a) Youth Opportunities Upheld, Inc., Day and Cottage Hill Residential Programs, Mid-cycle Review Report December 6, 2012 Page 3 of 11 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation 11.3 Educational Administrator Qualifications 28.09(5)(a); 28.09(7)(a); 603 CMR 44.00 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 Documentation Interviews dated by the student’s parent(s) as required. YOU, Inc. day and residential programs have a designated Educational Administrator who possesses the required qualifications to serve in this position. Youth Opportunities Upheld, Inc., Day and Cottage Hill Residential Programs, Mid-cycle Review Report December 6, 2012 Page 4 of 11 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic 11.4 Teachers (Special Education Teachers and Regular Education Teachers) Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification 28.09(7)(d) Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Documentation Interviews 18.05(11)(f); 28.09(5)(a); 28.09(7)(b, c); 34 CFR 300.321 11.5 Related Services Staff Comments Regarding Corrective Action Plan Implementation Documentation At the time of the 2010 Program Review, one teacher at the YOU, Inc. Cottage Hill Residential Program was not appropriately licensed as a special educator. YOU, Inc. day and residential programs now have teachers who are appropriately licensed or on approved waivers in grade and subject areas as required, which are appropriate to meet the needs of the student population. At the time of the 2010 Program Review, documentation review indicated two clinicians at the YOU, Inc. Cottage Hill Youth Opportunities Upheld, Inc., Day and Cottage Hill Residential Programs, Mid-cycle Review Report December 6, 2012 Page 5 of 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 Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Residential Program were not licensed by the Massachusetts State Board of Registration as required. In addition, three clinicians in the day program were not licensed by the Massachusetts State Board of Registration as required. 11.6 Master Staff Roster 28.09(7) Documentation YOU, Inc. day and residential programs now have appropriately certified, licensed or registered related services staff as required. YOU, Inc. day and residential programs maintain a Master Staff Roster which includes all staff positions within the program and that corresponds to the last approved Program Youth Opportunities Upheld, Inc., Day and Cottage Hill Residential Programs, Mid-cycle Review Report December 6, 2012 Page 6 of 11 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Budget as required. 19 Anti-Hazing Documentation Student Record Review Documentation Interviews M.G.L. c. 269, §§ 17 through 19 20 Bullying Prevention and Intervention M.G.L. c. 71, s. YOU, Inc. day and residential programs submitted copies of student handbooks distributed to students and documented students’ receipt of a copy of the school program’s antihazing disciplinary policy approved by the program’s Board of Directors for every secondary age student enrolled full-time, and every student group, and/or student team as required. YOU, Inc. day and residential programs submitted a description of how it amended its student admissions materials/handbook to contain Youth Opportunities Upheld, Inc., Day and Cottage Hill Residential Programs, Mid-cycle Review Report December 6, 2012 Page 7 of 11 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting an age-appropriate summary of its Bullying Prevention and Intervention Plan; a description of how it was distributed; and a description of the professional development plan developed by the program for all staff and provided evidence of its implementation including dates, format used, and sign-in sheets indicating staff attendance. 37H, as amended by Chapter 92 of the Acts of 2010. M.G.L. c. 71, s. 37O(e)(1) & (2). M.G.L. c. 71, s. 370(d). Identified Areas of Non-Compliance from the 2009-2010 Program Review or Other Areas of Concern 8.8 IEP – Progress Student Record Review At the time of the 2010 Program Review, a review of Youth Opportunities Upheld, Inc., Day and Cottage Hill Residential Programs, Mid-cycle Review Report December 6, 2012 Page 8 of 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 9.1(a) Student Separation Resulting from Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Interviews Reports 28.07(3); 34 CFR 300.320(a) (3)(i, ii) Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Documentation Student Record Review student records indicated progress reports did not always include information on the student’s progress toward the annual goals and benchmarks in the IEP. During the Mid-cycle Review, a review of student records and interviews indicate that progress reports at YOU, Inc. day and residential programs now include information on the student’s progress toward the annual goals and benchmarks in the IEP as required. At the time of the 2010 Program Review, documentation review Youth Opportunities Upheld, Inc., Day and Cottage Hill Residential Programs, Mid-cycle Review Report December 6, 2012 Page 9 of 11 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation 18.05(5)(i); 18.05(6, 7); 46.02(5)(b) 12.1 New Staff Orientation and Training Findings Regarding Incomplete Implementation of Approved Corrective Action Plan or Identification of Additional Issues of Noncompliance Interviews Behavior Management Corrective Action Plan Determined to be Not Fully Implemented or Additional Issues Identified Staff Record Review Interviews indicated that the logs used to track time out-of-class did not include who approved a student being out-of-class in a “processing room” over 30 minutes and who monitored the student during these times. During the Mid-cycle Review, documentation, student record review and interviews indicate time out logs now include who approved a student being out of class for over 30 minutes and who monitored the student during these times as required. At the time of the 2010 Program Review, the Department was unable to verify through staff record Youth Opportunities Upheld, Inc., Day and Cottage Hill Residential Programs, Mid-cycle Review Report December 6, 2012 Page 10 of 11 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Criterion Number and Topic Implementation Status of Requirements or Corrective Action Plan Determined to be Substantially Implemented Method(s) of Verification Comments Regarding Corrective Action Plan Implementation 18.05(11)(g, i); 28.09(7)(f) 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 reviews that all new staff received the required trainings prior to being assigned direct care duties with students. During the Mid-cycle Review, staff record review and interviews indicate at YOU, Inc. day and residential programs a tracking system specific to new staff orientation is in place to ensure that all new staff receive the required trainings prior to being assigned direct care duties with students. Staff record review indicated that the trainings are also documented in all new staff records. Youth Opportunities Upheld, Inc., Day and Cottage Hill Residential Programs, Mid-cycle Review Report December 6, 2012 Page 11 of 11 Further Corrective Action Ordered by the Department of Elementary and Secondary Education and Timelines for Implementation and Further Progress Reporting Commonwealth of Massachusetts Department of Elementary and Secondary Education YOUTH OPPORTUNITIES UPHELD, INC. Day Program A PRIVATE SPECIAL EDUCATION PROGRAM OPERATED PURSUANT TO 603 CMR 18.00 AND 28.09 130 Elm Street, Millbury, MA 01527 Program Rate Based on: 54 Students Approved Enrollment: 35 Students Day Program Summer Program Residential Program 10 month program 11 month program 12 month program APPROVED STUDENT:LICENSED EDUCATOR RATIO:8:1 APPROVED STUDENT:LICENSED EDUCATOR:AIDE RATIO: Not Applicable APPROVAL STATUS Full Expires on: August 31, 2016 The current approval is a result of a Mid-cycle Review conducted in the 2012-2013 school year and the next review is scheduled for the 2015-2016 school year. AMY B. KRUKONIS, EDUCATIONAL SPECIALIST, PROGRAM QUALITY ASSURANCE SERVICES NINA M. MARCHESE, SUPERVISOR, PROGRAM QUALITY ASSURANCE SERVICES DARLENE A. LYNCH, DIRECTOR, PROGRAM QUALITY ASSURANCE SERVICES DATE ISSUED: 12/06/2012 Commonwealth of Massachusetts Department of Elementary and Secondary Education YOUTH OPPORTUNITIES UPHELD, INC. Cottage Hill Residential Program A PRIVATE SPECIAL EDUCATION PROGRAM OPERATED PURSUANT TO 603 CMR 18.00 AND 28.09 83 Hospital Road, Baldwinville, MA 01436 Program Rate Based on: 19 Students Approved Enrollment: 19 Students Day Program Summer Program Residential Program 10 month program 11 month program 12 month program APPROVED STUDENT:LICENSED EDUCATOR RATIO: 6:1 APPROVED STUDENT:LICENSED EDUCATOR:AIDE RATIO: Not Applicable APPROVAL STATUS Full Expires on: August 31, 2016 The current approval is a result of a Mid-cycle Review conducted in the 2012-2013 school year and the next review is scheduled for the 2015-2016 school year. AMY B. KRUKONIS, EDUCATIONAL SPECIALIST, PROGRAM QUALITY ASSURANCE SERVICES NINA M. MARCHESE, SUPERVISOR, PROGRAM QUALITY ASSURANCE SERVICES DARLENE A. LYNCH, DIRECTOR, PROGRAM QUALITY ASSURANCE SERVICES DATE ISSUED: 12/06/2012