CONTINUOUS IMPROVEMENT AND FOCUSED MONITORING PROCESS
DIVISION OF EDUCATIONAL IMPROVEMENT AND ASSISTANCE
OFFICE OF STUDENT AND SCHOOL PERFORMANCE
FOCUSED MONITORING COMPONENT
DATE OF ON-SITE MONITORING: FEBRUARY 13-17, 2006
SUMMARY OF FINDINGS
LAFAYETTE PARISH SCHOOL SYSTEM
DR. JAMES H. EASTON, SUPERINTENDENT
SUSAN CHIQUELIN, DIRECTOR OF SPECIAL EDUCATION
ON-SITE TEAM LEADER
DONNIE FAYE HULL
ON-SITE TEAM MEMBERS
DJUNA AMBEAU
BONNIE BUCKELEW
TONI FRIERSON
MOLLIE LYNN
ALPHONSE NOEL
CAROL WELCH
OVERVIEW
A team of seven monitors conducted an on-site compliance monitoring visit in Lafayette Parish
School System on February 13-17, 2006, as a component of the Continuous Improvement and
Focused Monitoring Process (CIFMP). Lafayette Parish School System was initially selected in
December 2004 for the 2005 calendar year CIFMP state monitoring cycle, under the focused
category of on-site monitoring, because of its composite score on the state performance indicator
labeled Exit. The composite score is based on the percentage of special education students
exiting with positive outcomes and the percentage of special education students exiting with
negative outcomes. The monitoring trip was originally planned for September 2005 and was then
postponed to February 2006 due to the statewide impact of Hurricanes Katrina and Rita.
The focused monitoring component of the state’s CIFMP involves four steps:
1.
2.
3.
4.
Develop compliance hypotheses based on available data.
Develop investigative methodologies to test the hypotheses.
Conduct investigation.
Draw conclusions regarding compliance with statutory and regulatory
requirements.
Current demographic and performance information pertaining to Lafayette Parish School System
can be found in the State Special Education Data Profile 2005 publication and the school
system’s annual special education performance profile located on the Louisiana Department of
Education’s (LDE) website at: http://www.louisianaschools.net/lde/specialp/2115.html.
The CIFMP monitoring team uses a variety of monitoring-related investigative strategies,
methods and activities prior to and during the on-site visit. Examples of the records reviewed in
relation to the Lafayette Parish on-site visit include the following: 100 student records, including
random and purposeful reviews of students’ IEPs; 17 individual evaluation reports; report cards;
class schedules; local education agency Special Education Policies and Procedures Handbook
and forms currently in use; disciplinary records at school sites and central office; records of
professional development activities; and complaint logs maintained by the Louisiana Department
of Education. Interviews were conducted with 35 school-based personnel, including
administrators and teachers in 19 schools, and with five central office personnel. Classroom
observations were conducted in five elementary, five middle, four high and five alternative
schools.
Parental Involvement in Monitoring
Lafayette Parish School System and the LDE mailed parent surveys to approximately 20% of
exceptional students’ homes prior to the monitoring team’s on-site visit. The results of the 172
returned surveys were compiled with the help of Families Helping Families of Southwest
Louisiana (FHFSWLA) Resource Center, and issues of concern to parents were investigated
during the on-site visit of Lafayette Parish School System. A parent focus group meeting, held
on February 13, 2006, was facilitated by the monitoring team member from the FHFSWLA
resource center and was attended by 50 parents. This meeting was only open to parents and
monitoring team members. Follow-up telephone interviews were also conducted. Comments
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from the parent surveys and notes taken during the parent meeting were also considered in the
investigative process.
Special State-Mandated Monitoring Activities
The Louisiana State Legislature mandates that compliance monitoring efforts include collection
of information concerning services provided to special education students. The following
information collected during the on-site monitoring of the Lafayette Parish School System has
been provided for the 2005-2006 Performance Indicator Report:

Percent of youth aged 16 and above with an IEP that includes coordinated, measurable,
annual IEP goals and transition services that will reasonably enable the student to meet
the post-secondary goals: 38% (9 out of 24 records reviewed).

Percent of students actually monitored at alternative schools whose records show they are
receiving all of the services in their Individual Education Program: 100% (16 out of 16).
Special Federally Mandated Monitoring Activities
The U.S. Department of Education requires that states, as part of their general supervision
responsibilities, monitor the performance of local education agencies in the monitoring priority
area of disproportionate representation of racial and ethnic groups in special education and
related services, to the extent the representation is the result of inappropriate identification.
Louisiana uses a risk ratio for analysis of disproportionality. For the purposes of monitoring,
Louisiana’s CIFMP Steering Committee has chosen to use a risk ratio equal to or greater than 1.5
(> 1.5 is considered disproportionate representation) for African-American students identified as
having a disability according to the school system’s annual child count. The monitoring team
reviewed the LEA’s performance profile and reviewed Lafayette Parish’s risk ratio figures for
African-American students identified as having mild mental disabilities, specific learning
disabilities, and emotional disturbance. To that end, the monitoring team reviewed recent
evaluation records of 17 students completed during the 2005-06 school year who, through
individual evaluation, were identified as meeting criteria for eligibility for the following
exceptionalities: Mental Disability-Mildly Impaired, Emotional Disturbance, Specific Learning
Disability and Other Health Impairment.
CONLCUSIONS OF THE ON-SITE MONITORING TEAM
In regard to the 2005 Louisiana focused monitoring priority indicator of Exit, one of the areas
that the monitoring team investigated was the accessibility of the GED/Skills Options Program to
students with disabilities. A review of the enrollment records for GED/Skills Options Program
revealed that 97 students with disabilities are currently enrolled in the program, 18 of whom are
participating in work experience and 79 are attending vocational classes. A purposeful review of
the state department of education record, The Options Program Transcript, revealed that the
number of Lafayette Parish students with disabilities who completed the Options programs for
the past three years has increased from four during the 2002-03 school year to 29 in the 2004-05
school year.
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The monitoring team members also looked at IEP records of students 16 years of age and older.
The on-site monitoring team found evidence of non-compliance in the area of transition services
through review of these students’ IEP records. In addition, the monitoring team’s review of the
IEPs of younger students revealed areas of non-compliance in the areas of healthcare plans,
behavioral supports, and documentation of progress toward achievement of IEP goals.
The team investigated whether the LEA’s discipline policies, procedures and programs could be
having a negative effect on Lafayette’s Exit data. The Lafayette Parish Performance Profile for
school year 2004-2005 when compared with that of 2003-2004 shows that Lafayette Parish has a
reduced percent of students dropping out (29.9% reduced to 25.8%) and slight reductions in its
percent of in-school suspensions (16.61% reduced to 16%) and out-of-school suspensions
(25.03% reduced to 23.45%). The monitoring team found evidence of non-compliance in the
school system’s tracking of discipline data. The school system stated that it is already aware of
the problem and is taking measures to achieve accuracy in its discipline tracking system.
For the monitoring priority area of disproportionate representation-identification practices, the
on-site monitoring team’s review of child identification policies, procedures and practices used
by Lafayette Parish led the monitoring team to identify systemic areas of non-compliance in the
area of screening, referral and individual evaluation. However, the team did not conclude that the
LEA’s current practices are contributing to disproportionate representation of racial or ethnic
groups in special education resulting from inappropriate identification.
In summary, evidence of systemic non-compliance was found in the following areas:
 §490. Maintenance of Special Education Student Data (Discipline)


§444. IEP Content:
-Transition Services (444.M.)
-Statements addressing behavior (444.B.1.)
-Individualized Healthcare Plans (B.6.)
-Documentation of Achievement of IEP Objectives and Goals (444.L.1.-2.)
§413./434./435. Screening, Referral and Individual Evaluation
The student-specific findings of non-compliance are included at the end of this report. Those
pages of the report contain confidential information and should be deleted from the report when
copies are made for the general public.
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Findings of Non-Compliance
Lafayette Parish School System
Reg.
Ref. #
490.A.
Description of Finding
Maintenance of Special
Education Student
Data-Discipline
The LEA is not
maintaining and assuring
the accuracy of the
required elements for
each student record.
Supporting Evidence
In a purposeful review of the disciplinary tracking system at the central
office and the disciplinary removals of students with disabilities at 2 schools
revealed the following information:




§444.A.,
B., L., M.
Content of IEPs
Completed IEPs are
lacking the required
content. For example,
IEP teams are not
including on IEPs
The 2 tracking systems (central office and school-based) do not
match with the total number of school offenses and the number
of days of suspension.
18 students at one high school were missing from the central
office tracking system; the students were on the Special
Education Incident Report at the school.
10 students were missing from the Special Education Incident
Report at one middle school, but were on the Incident Report at
the school.
Data from the Student Discipline Report for 9 of 12 students
showed inaccurate information as it relates to the number of days
students are suspended from school.
Comments
The Director of Special
Education stated that an
audit conducted by the
local education agency has
already identified this
problem. The school
system plans to solve the
problem by conducting inservices to address
discipline procedures and
reporting of data to ensure
that the tracking system is
effective, timely and
consistent.
In interviews, 2 special education teachers and 1 regular education teacher
stated that students are sent home for a “cooling off” period, and this is not
counted as a suspension. This was verified by checking the behavioral log
of a student. The parent was called to pick the student up on December 16,
2005. The day was not reported on the discipline tracking report as a day of
suspension.
Transition Services
Purposeful review was conducted of 24 transition IEPs.
15 of 24 IEPs all lacked the following information:


date of student invitation to the transition meeting;
record of invitation of adult agency to the IEP meeting;
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Findings of Non-Compliance
Lafayette Parish School System
Reg.
Ref. #
Description of Finding
statements addressing
special factors such as
health needs and
negative student
behaviors that impede the
student’s learning or that
of others; and IEPs lack
prescribed statements
pertaining to transition
services for students 16
years of age or younger
where appropriate.



Supporting Evidence
documentation of steps taken to obtain agency participation in
planning transition services;
notice to parent indicating that the purpose of the meeting is the
consideration of needed transition services;
record of funding agency invitation to the IEP.
Comments
10 of 24 IEPs had no statement of transition services (including courses of
study) that the students will need to achieve desired post-school results.
6 of 24 IEPs did not have evidence that both student and parents were
notified, at least one year before the student reaches the age of majority, that
all rights will be transferred to the students.
5 of 24 IEPs did not indicate the time and location of the meeting; did not
have a record of informing parents that they may invite other individuals to
the meeting as appropriate; did not include a statement of needed transition
services that is a coordinated set of activities; and did not include a
statement of needed transition services that considers community
experiences.
4 of 24 IEPs did not contain evidence that parents were provided with prior
written notice that graduation with a regular diploma constitutes a change in
placement and that the student no longer is entitled to a free appropriate
public education.
3 of 24 IEPs did not include a statement that needed transition services had
been reviewed at least annually.
1 of 24 IEPs did not include a statement of needed transition services that
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Findings of Non-Compliance
Lafayette Parish School System
Reg.
Ref. #
Description of Finding
Supporting Evidence
considers related services, and did not include a statement that the student
had been informed of his/her rights, at least one year before the student
reached the age of majority, that all rights will be transferred to the student.
Comments
Healthcare Plans
12 of 12 records reviewed for students with medical needs did not have an
individualized healthcare plan attached to the IEP.
Behavioral Issues
3 of the IEPs reviewed had behavior plans that had not been updated.
2 of the IEPs reviewed had no behavior goal in the instructional plan,
although there was evidence that the there were behavior concerns about the
students.
Record of Achievement of Goals and Objectives/Record of Student
Progress
§413.
434.
435.
Screening, Referral and
Individual Evaluation
The school system is not
following all regulations
and applicable state
bulletins in the process of
identifying and not
10 of the IEPs reviewed had no record that the students had achieved
objectives or goals.
17 evaluations were reviewed for students identified with the following
disabilities:
Mental Disability-Mildly Impaired (MMD)-3
Emotional Disturbance (ED)-3
Specific Learning Disability (SLD)-5
Other Health Impairment (OHI)-6
The school district is
commended for providing
many opportunities for
student assistance prior to
referral for an evaluation,
for example, SEAS, CAT,
counseling through SAFE
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Findings of Non-Compliance
Lafayette Parish School System
Reg.
Ref. #
Description of Finding
Supporting Evidence
identifying as exceptional
each student suspected of The cases reviewed included all school-based evaluations completed thus
having a disability.
far this school year that resulted in students being identified as exceptional
under the disability of emotional disturbance or mild mental disability.
5 elementary schools and 1 middle school were visited. Interviews were
conducted with 5 principals, 1 principal-designee, 5 School Building Level
Committee (SBLC) chairpersons, and 3 TAT (Teacher Assistance Team)
chairpersons. Tracking logs were requested from 3 elementary schools and
2 middle schools.
Comments
Schools, tutoring, the
parenting center, Project
Read, Success for All, and
FAST FORWARD.
The following are
recommendations for
improvement:
-Pupil Appraisal 1508
In review of the 17 evaluation reports completed in the 2005-06 school year, integrated evaluation
the following areas of concern were identified:
reports should include
documentation of
 The strategies listed at the beginning of the reports frequently are not systematic intervention for
an appropriate amount of
consistent with the strategies reported within the reports.
 Most reports contain no documentation of specific intervention data: time in the area(s) of
academic or social
baseline, specific research-/evidence-based intervention
behavior of concern:
implemented, frequency/duration of intervention, progress
baseline, progress
monitoring results, use of more than one appropriate intervention.
monitoring, trial of more
 Interventions conducted prior to referral to the SBLC or during the
than one evidence-based
SBLC process are reported only in general terms within the report.
intervention if needed, and
(Example: “The following interventions were implemented and are
analysis of results.
ongoing: preferential seating, small group instruction, individual
tutoring, Project Read instruction, and/or a behavior intervention
-In-service should be
plan.”)
provided on the difference
 Determination of eligibility for SLD and MMD appears to rely
in accommodations,
primarily on results of standardized test results.
modifications and
research-/evidence-based
A review of the records of 1 student determined to have emotional
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Findings of Non-Compliance
Lafayette Parish School System
Reg.
Ref. #
Description of Finding
Supporting Evidence
disturbance revealed the following:
 Hearing was noted to be at risk and clarification of that issue
was not included within the report.
 1 report had no documentation that the behavior intervention
plan was linked to results of the functional behavior
assessment (FBA). The FBA concluded that behavior
appeared to be the result of the student’s frustration over his
inability to express himself so that others could understand
him. The speech and language evaluation supported that
finding, stating that the student has difficulty organizing his
ideas in a logical and concise manner.
 2 reports did not contain rating scales information.
 1 report did not contain the results of the FBA.
A review of the records of 1 student determined to have Mental DisabilitiesMildly Impaired, revealed that there is no explanation of how medical
diagnoses and inattentiveness in the classroom are ruled out as major
contributors to the student’s learning difficulties.
In a review of the records of 3 pre-school level children, the following was
revealed:
 In the records of 1 child determined to have a mental disabilitymildly impaired, there is no explanation of how lack of educational
opportunity and effect of medical conditions were ruled out.
 In 2 of 3 children’s records reviewed, there is no assessment of the
ten life skill areas.
 In 0 of 3 children’s records reviewed, there was no documentation of
systematic intervention on instructional level that determines the
student learns significantly below an average rate.
Comments
interventions.
-Consideration should be
given to involvement of
pupil appraisal staff earlier
in the intervention process
to ensure implementation
and documentation of
appropriate research/evidence-based
interventions and progress
monitoring.
-Teacher Assistance Team
and SBLC tracking should
be analyzed yearly to
assess effectiveness of prereferral intervention and
identify both effective
interventions and areas of
need.
-Tracking information
should include race, type
of intervention and
documentation of
appropriate
implementation of the
interventions for a
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Findings of Non-Compliance
Lafayette Parish School System
Reg.
Ref. #
Description of Finding
Supporting Evidence
Comments
significant period of time.
In 1 report reviewed, the exceptionalities listed on the first page of the
report do not match the exceptionalities listed in the summary.
In 2 of the reports reviewed of students with specific learning disabilities,
there is no signature of the regular education teachers.
In 5 reports for students determined to have emotional disturbance or mental
disability-mildly impaired, there is no documentation of student
observations in different settings.
[Note: Observations conducted by pupil appraisal personnel of the student
in two different settings are required as part of the identification process for
students suspected to have the exceptionality of emotional disturbance.]
In 5 of 6 OHI evaluations, the diagnosed condition was Attention Deficit
Hyperactivity Disorder (ADHD). Generally, these reports lacked clear
documentation that behaviors related to ADHD are the primary cause of the
student’s learning difficulties and lacked documentation of specific
intervention in the area of concern, such as organizational skills, sustained
attention to task, and/or work completion prior to determination of
exceptionality. In 1 report, the student was on-task 90% of the time during
observation and the teacher reported that the student generally is attentive
and completes assignments since beginning to take medication.
In 3 reports of students determined to have OHI (ADHD), there is no
recommendation for counseling/consultation and for a behavior intervention
plan to teach needed organizational, attending, or other needed skills. In 1 of
these reports there is no signature of the school nurse.
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Findings of Non-Compliance
Lafayette Parish School System
Reg.
Ref. #
Description of Finding
Supporting Evidence
There was no evidence of a systematic method for yearly analysis of TAT
and SBLC tracking to assess effectiveness of pre-referral interventions and
to identify effective interventions and appropriate referrals for evaluations.
Comments
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