MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION Program Quality Assurance Services COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Charter School or District: Richmond CPR Onsite Year: 2011-2012 Program Area: Special Education All corrective action must be fully implemented and all noncompliance corrected as soon as possible and no later than one year from the issuance of the Coordinated Program Review Final Report dated 05/26/2012. Mandatory One-Year Compliance Date: 05/26/2013 Summary of Required Corrective Action Plans in this Report Criterion SE 18A Criterion Title IEP development and content SE 18B Determination of placement; provision of IEP to parent SE 24 SE 32 Notice to parent regarding proposal or refusal to initiate or change the identification, evaluation, or educational placement of the child or the provision of FAPE Parent advisory council for special education SE 56 Special education programs and services are evaluated CR 11A Designation of coordinator(s); grievance procedures CR 12A Annual and continuous notification concerning nondiscrimination and coordinators CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Partially Implemented Criterion CR 14 CR 24 Criterion Title Counseling and counseling materials free from bias and stereotypes Use of physical restraint on any student enrolled in a publicly-funded education program Curriculum review CR 25 Institutional self-evaluation CR 17A CPR Rating Partially Implemented Partially Implemented Partially Implemented Partially Implemented COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18A IEP development and content Partially Implemented Department CPR Findings: A review of student records, documentation and staff interviews indicate that the district did not document in the IEP the skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing for students on the autism spectrum or for students whose disability may make them vulnerable to such behaviors. Description of Corrective Action: Parents receive rough drafts of IEP at meeting. The completed IEP will be sent in the mail within 5 days of the meeting. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education / Jenevra Strock Completion: 05/26/2013 Evidence of Completion of the Corrective Action: The IEP will be signed by the Director of Education within the 5 days of the meeting and dated and recorded in the ESPED system for tracking. Description of Internal Monitoring Procedures: The Director of Special Education will inform the IEP liason when the completed IEP is due and will make sure that the timeline is kept. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: SE 18A IEP development and content Corrective Action Plan Status: Approved Status Date: 08/22/2012 Basis for Partial Approval or Disapproval: See the district's CAP for 18B, where it responded to 18A in error. It responded to SE 18A in SE18B. The district submitted a procedure to ensure that IEPs are issued within 5 days of the IEP Team meeting. Department Order of Corrective Action: Required Elements of Progress Report(s): Circulate a memo to all appropriate staff explaining that for students on the autism spectrum or for students whose disability may make them vulnerable to bullying, harassment, or teasing, the IEP must address the skills and proficiencies needed to avoid and respond to those issues and submit a copy of the document initialed by staff who received it by October 12, 2012. Submit the results of an internal review of all IEPs developed since correction action to verify that the district addressed the issues of bullying, harrassment or teasing and include the number of IEPs reviewed, the number in compliance, the root cause of any non-compliance and the corrective actions the district will take to remedy any noncompliance, by February 15, 2013. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 3 Progress Report Due Date(s): 10/12/2012 02/15/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 4 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 18B Determination of placement; provision of IEP to parent Partially Implemented Department CPR Findings: A review of student records and interviews indicated that the district did not always provide the parent with the proposed IEP and placement within the required timelines. Description of Corrective Action: At the IEP meeting, a document wil be signed stating that bullying has been discussed: ruled out or a plan designed. It will also be noted on IEP draft. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education / Jenevra Strock Completion: 05/26/2013 Evidence of Completion of the Corrective Action: The IEP draft will document the bullying discussion and be signed by the parent. The determination sheet will also be filled in. Description of Internal Monitoring Procedures: The Director of Education will review all documents to see if all issues, including bullying, have been addressed. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved SE 18B Determination of placement; Status Date: 08/27/2012 provision of IEP to parent Basis for Partial Approval or Disapproval: See the district's CAP for 18A, where it responded to 18B in error. The district submitted a procedure to document that it discusses the bullying issue during the IEP meeting Department Order of Corrective Action: Required Elements of Progress Report(s): Conduct an analysis of IEPs from the past year to determine why parents are not routinely being provided with the proposed IEP and placement within the required timelines and submit a description of the root causes of the noncompliance, the steps the district will take to correct the root cause(s) and the proposed timeline for implementation of corrective action by October 12, 2012. Submit the results of an administrative review of all IEPs conducted since corrective action to determine if timelines were met and include the number of IEPs reviewed, the number in compliance, the root cause of any non-compliance and the corrective actions the district will take to remedy any non-compliance, by February 15, 2013. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): 10/12/2012 02/15/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 5 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 6 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 24 Notice to parent regarding proposal or refusal to initiate or Partially Implemented change the identification, evaluation, or educational placement of the child or the provision of FAPE Department CPR Findings: Student record review and interviews indicate that the district did not always send the Notice of Proposed School District Action (N-1) with the IEP to parents with a description of the action proposed, an explanation of why the agency is making the proposal, a description of other options that the district considered and reasons why those options were rejected, a description of evaluation procedures, tests, records, or reports the district used as a basis for the proposed action, and a description of any other factors that were relevant to the district's proposal. Description of Corrective Action: The Director of Special Education will be responsible for filling out the N-1 page after each IEP meeting. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education / Jenevra Strock Completion: 10/31/2012 Evidence of Completion of the Corrective Action: The IEP will reflect the completion of the N-1 for every IEp. Description of Internal Monitoring Procedures: The Special Education Director will be responsible for filling out the N-1 page after each IEP meeting. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 24 Notice to parent regarding Approved proposal or refusal to initiate or change Status Date: 08/28/2012 the identification, evaluation, or educational placement of the child or the provision of FAPE Basis for Partial Approval or Disapproval: The Special Education director is the IEP team chair for all IEP team meetings and completes and sends out all N1s, but there is no internal mechanism to ensure that the task is always done. Department Order of Corrective Action: Please provide a plan in the event that the Special Education administrator is unavailable to chair the meeting and cannot issue the N1 notice. Required Elements of Progress Report(s): Submit a description of the procedure the district will use and identify the persons involved to ensure that the district always sends the Notice of Proposed School District Action (N-1) with the IEP, by October 12, 2012. Submit the results of an internal review of all IEPs developed since correction action to verify that the district sent the Notice of Proposed School District Action (N-1) that includes all content requirements with the IEP to parents and include the number of IEPs reviewed, the number in compliance, the root cause of any non-compliance and the corrective actions the district will take to remedy any non-compliance, by February 15, MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 7 2013. *Please note when conducting internal monitoring the district must maintain the following documentation and make it available to the Department upon request: a) List of student names and grade levels for the records reviewed; b) Date of the review; c) Name of person(s) who conducted the review, with their role(s) and signature(s). Progress Report Due Date(s): 10/12/2012 02/15/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 8 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 32 Parent advisory council for special education Partially Implemented Department CPR Findings: A review of documentation and interviews indicated that for the past two years, the district has scheduled PAC meetings and invited parents but was not successful in establishing a parent advisory council on special education. The district also conducted an annual workshop on the rights of students and their parents and guardians under the state and federal special education laws. Description of Corrective Action: The Director of Special Education will send out a survey to each Special Education parent. That survey will ask questions concerning the time/dates of PAC meetings, whether the parent is willing to be on the Council, and ask for input about various aspects of the special education programs we offer. Then we will go over the data. Using that data, we will invite parents to attend a PAC meeting where we can set up a Council with officers and set a schedule to address overseeing program reviews. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education / Jenevra Strock Completion: 04/30/2013 Evidence of Completion of the Corrective Action: The surveys received back will be compiled and reviewed to direct our PAC meetings. Description of Internal Monitoring Procedures: The Director of Special Education will review the surveys and revolve the PAC meetings around the findings. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 32 Parent advisory council for special Approved education Status Date: 08/28/2012 Basis for Partial Approval or Disapproval: The district's proposal does not articulate that it will be necessary for the PAC to develop by-laws for operation. Department Order of Corrective Action: The district will assist in the development of by-laws for the operation of the Special Education Parent Advisory Council. Required Elements of Progress Report(s): Submit a copy of the survey the district will send to parents regarding the establishment of a PAC, by October 12, 2012. Submit the results of the survey and a description of the district's efforts to establish a PAC. Include copies of: 1. the PAC officer list 2. the PAC Bylaws 3. School committee agendas and minutes pertaining to consultation with the PAC, Agendas of PAC training sessions or meetings conducted by the district, documentation of other district efforts to support the PAC, by February 15, 2013. Progress Report Due Date(s): 10/12/2012 02/15/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 9 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 10 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: SE 56 Special education programs and services are evaluated Partially Implemented Department CPR Findings: A review of documentation and staff interviews indicated that the district does not regularly evaluate its special education programs and services. Description of Corrective Action: With the support of the PAC, the Special Education staff will meet twice a year to review two programs or services. The team will meet by November 30 and February 26th each year. Title/Role(s) of responsible Persons: Expected Date of Director of Special Education / Jenevra Strock Completion: 04/30/2013 Evidence of Completion of the Corrective Action: Each PAC meeting will be documented by invitation, meeting notes and member sign in sheets. Description of Internal Monitoring Procedures: The Director of Special Education will produce and send out the PAC meeting invitations, write the meeting notes and provide the sing in sheets for each meeting. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially SE 56 Special education programs and Approved services are evaluated Status Date: 08/28/2012 Basis for Partial Approval or Disapproval: While the role of the PAC includes assisting the district in the evaluation of special education programs, the district must ensure that its programs are regularly evaluated and should not fail to conduct evaluation activities if the district experiences difficulties in establishing an operational Parent Advisory Council. Department Order of Corrective Action: Ensure the regular evaluation of district special education programs. Required Elements of Progress Report(s): Identify the programs scheduled for evaluation and include the methodologies and timelines for the evaluation. Submit a copy of the PAC meeting invitations, agenda that identifies the special education programs that will be evaluated, sign-in sheet, and materials by October 12, 2012. Submit a copy of the evaluation report that includes methods, findings and recommendations by February 15, 2013. Progress Report Due Date(s): 10/12/2012 02/15/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 11 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 11A Designation of coordinator(s); grievance procedures Partially Implemented Department CPR Findings: A review of documents and interviews indicated that the district has not adopted and published procedures providing for prompt and equitable resolution of complaints alleging discrimination based on sex or disability for students and for employees. Description of Corrective Action: Coordinators for the Title IX, Section 504 and Title II have been identified. The district is in the planning stages of adopting and publishing a grievance procedure for students and staff to resolve complaints of discrimination based on gender or disability. An adopted plan is expected to be implemented by fall 2012. Title/Role(s) of responsible Persons: Expected Date of Principal / Dr. Karin Deyo Completion: 10/31/2012 Evidence of Completion of the Corrective Action: The Principal will post the grievance procedures on the school website. Description of Internal Monitoring Procedures: The Principal will verify that the grievance procedures are on the website and inform staff and students at the beginning of the school year of its location. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 11A Designation of coordinator(s); Status Date: 08/28/2012 grievance procedures Basis for Partial Approval or Disapproval: The district identified coordinators for Title IX, Title II and Section 504 and in the process of developing a grievance procedure. Department Order of Corrective Action: Required Elements of Progress Report(s): Submit a copy of the new grievance procedures for staff and students to resolve complaints of discrimination based on gender or disability and the names of the coordinators for Title IX, Section 504 and Title II, by October 12, 2012. Progress Report Due Date(s): 10/12/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 12 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 12A Annual and continuous notification concerning Partially Implemented nondiscrimination and coordinators Department CPR Findings: A review of documentation and interviews indicated that district notices, written materials and other media do not specifically state that the district does not discriminate on the basis of race, color, national origin, sex, disability, religion, or sexual orientation. Description of Corrective Action: 1. The Richmond School does not offer vocational educational programming. At the point that this may become a consideration, a plan will be formulated to address the issue. 2. Notifications for students and staff regarding non-discrimination needs review for assurance that the standard is met. A review of all documentation will take place in the Fall 2012 to ensure we are meeting the legal standard. 3. All materials (documents, email signatures and web site information) will be reviewed to ensure a non-discrimination statement is clear. This correction will be made in Fall 2012. Title/Role(s) of responsible Persons: Expected Date of Principal / Dr. Karin Deyo Completion: 10/31/2012 Evidence of Completion of the Corrective Action: All items (documents, email signatures and web site information) will have a nondiscrimination statement. Description of Internal Monitoring Procedures: The Principal will monitor materials bi-annually. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 12A Annual and continuous Status Date: 08/28/2012 notification concerning nondiscrimination and coordinators Basis for Partial Approval or Disapproval: The district submitted a plan to ensure that a non-discrimination statement is included on all appropriate materials. Department Order of Corrective Action: Required Elements of Progress Report(s): Submit a sample notice that specifically states that the district does not discriminate on the basis of race, color, national origin, sex, disability, religion, gender identity or sexual orientation and a list of materials and publications that contain the notice by October 12, 2012. Progress Report Due Date(s): 10/12/2012 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 13 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 14 Counseling and counseling materials free from bias and Partially Implemented stereotypes Department CPR Findings: A review of documentation indicated that the district does not have procedures to ensure that counseling and counseling materials are free from bias and stereotypes on the basis of race, color, sex, religion, national origin, sexual orientation, disability, and homelessness. Description of Corrective Action: A complete review of programming and services offered to students will be addressed in the Fall 2012. Counseling services, limited English opportunities and testing will be reviewed for bias and opportunity for all individuals. Title/Role(s) of responsible Persons: Expected Date of Principal / Dr. Karin Deyo Completion: 10/31/2012 Evidence of Completion of the Corrective Action: All handouts and policies will be free from bias and stereotypes. Description of Internal Monitoring Procedures: The Principal will monitor materials bi-annualy. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Partially CR 14 Counseling and counseling Approved materials free from bias and stereotypes Status Date: 06/26/2012 Basis for Partial Approval or Disapproval: The district does not articulate its procedure for reviewing counseling and counseling materials. Department Order of Corrective Action: Develop procedures to ensure that counseling and counseling materials are free from bias and stereotypes on the basis of race, color, sex, religion, national origin, sexual orientation, disability, gender identity and homelessness. Required Elements of Progress Report(s): Submit a description of the district's procedures for ensuring academic counseling and counseling materials are free from bias and stereotyping on the basis of race, color, sex, religion, national origin, sexual orientation, disability, and homelessness, by October 12, 2012. Submit a copy of the results of the district's review of counseling and counseling materials and the changes made, if any, by February 15, 2013. Progress Report Due Date(s): 10/12/2012 02/15/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 14 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 17A Use of physical restraint on any student enrolled in a Partially Implemented publicly-funded education program Department CPR Findings: A review of documentation and interviews indicated that the district has not developed written restraint procedures, or consistently provided training to all staff on the use of restraint within the first month of each school year and, for employees hired after the school year begins, within a month of their employment. Description of Corrective Action: Restraint training will happen within a month of starting school. All employees will be provided training. Documentation will be kept. All new employees will be provided training within a month of hire. A policy for school restraints will be developed by the school staff and presented to the school committee for review by December 2012. Included in the policy will be written procedures, safeguards and reporting to ensure the standard is met. Title/Role(s) of responsible Persons: Expected Date of Principal / Dr. Karin Deyo Completion: 04/30/2013 Evidence of Completion of the Corrective Action: A roster of employees participating in restraint training will be kept. The policy will be available for review by each employee. Description of Internal Monitoring Procedures: The Principal will verify with the restraint facilitator made available to employees the dates of training. The Principal will review the roster and verify all employees have participated. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: Corrective Action Plan Status: Approved CR 17A Use of physical restraint on any Status Date: 08/28/2012 student enrolled in a publicly-funded education program Basis for Partial Approval or Disapproval: The district will develop restraint procedures and provide the required restraint training for all staff. Department Order of Corrective Action: Required Elements of Progress Report(s): Provide a draft of the district's newly developed written restraint procedures and evidence of staff training on the use of restraint for all staff (agenda, sign-in sheets, materials) by October 12, 2012. Provide a copy of the district's restraint policy that was approved by the school committee and evidence of restraint training that was provided to new employees, if any, within a month of hire, by February 13, 2013. Progress Report Due Date(s): 10/12/2012 02/15/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 15 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 16 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 24 Curriculum review Partially Implemented Department CPR Findings: According to interviews and a review of documents, the district does not have procedures for individual teachers to review educational materials for simplistic and demeaning generalizations, lacking intellectual merit, on the basis of race, color, sex, religion, national origin and sexual orientation. Description of Corrective Action: A curriculum review has begun in the Spring 2012. A committee of 6 teachers has been identified to review the curriculum and all materials within the school. A complete review is expected by Spring 2013. A new curriculum hire will facilitate the process. Library materials will be reviewed by the school media specialist. Title/Role(s) of responsible Persons: Expected Date of Principal / Dr. Karin Deyo Completion: 04/30/2013 Evidence of Completion of the Corrective Action: The committee will keep a list of dates and times of meetings and of materials reviewed. Description of Internal Monitoring Procedures: The Principal will review the committee's notes. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 24 Curriculum review Corrective Action Plan Status: Approved Status Date: 08/28/2012 Basis for Partial Approval or Disapproval: The district submitted a plan to review its curriculum and materials. Department Order of Corrective Action: Required Elements of Progress Report(s): Submit a copy of procedures the teachers use to review the curriculum and materials and a brief summary of work it has completed by October 12, 2012. Submit a copy of the completed review and any activities, discussions and/or supplementary materials that the district has used or developed to provide balance and context for any stereotypes depicted in the educational materials, by February 15, 2013. Progress Report Due Date(s): 10/12/2012 02/15/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 17 COORDINATED PROGRAM REVIEW CORRECTIVE ACTION PLAN Criterion & Topic: CPR Rating: CR 25 Institutional self-evaluation Partially Implemented Department CPR Findings: A review of documentation and interviews indicated that the district has not reviewed all aspects of its K-8 program annually to ensure that all students, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, disability, or housing status, have equal access to all programs, including athletics and other extracurricular activities as a part of that process. Description of Corrective Action: A PreK-8 evaluation of programming will be incorporated into the curriculum work annually. Access will be available to all programs no matter the circumstance or disability of any individual. Title/Role(s) of responsible Persons: Expected Date of Principal / Dr. Karin Deyo Completion: 10/31/2012 Evidence of Completion of the Corrective Action: The curriculum committee's notes will address the discussion around PreK-6 availability to all programs. Description of Internal Monitoring Procedures: The Principal will review the committee's notes. CORRECTIVE ACTION PLAN APPROVAL SECTION Criterion: CR 25 Institutional self-evaluation Corrective Action Plan Status: Approved Status Date: 08/28/2012 Basis for Partial Approval or Disapproval: The district submitted a plan to review all aspects of its K-8 program annually. Department Order of Corrective Action: Required Elements of Progress Report(s): Submit a copy of procedures the district will use to evaluate all aspects of its K-12 program to ensure that all students, regardless of race, color, sex, religion, national origin, limited English proficiency, sexual orientation, gender identity, disability, or housing status, have equal access to all programs, including athletics and other extracurricular activities, by October 12, 2012. Submit a copy of the evaluation and any changes that the district plans to make as a result of the findings, by February 15, 2013. Progress Report Due Date(s): 10/12/2012 02/15/2013 MA Department of Elementary & Secondary Education , Program Quality Assurance Services Richmond CPR Corrective Action Plan 18