Massachusetts Department of
Elementary and Secondary Education
75Pleasant Street, Malden, Massachusetts 02148-4906 Telephone: (781) 338-3700
TTY: N.E.T. Relay 1-800-439-2370
October 25, 2012
Dr. Charles Conroy
Dr. Franklin Perkins School
Day and Residential Programs
971 Main Street
Lancaster, MA 01523
Re: Mid-cycle Review and Verification of previous Program Review Corrective Action Plan
Dear Dr. Conroy:
Enclosed is the Department of Elementary and Secondary Education’s (“Department”) Mid-cycle Report based upon the Mid-cycle review conducted in your private school programs in September, 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 July 22, 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 Plans to be substantially implemented and effective in remedying previously identified noncompliance issues. Additionally, we have determined that your programsare 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 programs’ next regularly scheduled Program Review several months before it is to occur. At this time we anticipate the next routine monitoring visit to occur sometime during the 2015-2016school 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 781-338-3737.
Sincerely,
Paul Bottome, 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
Michel Moran Zide,Ed.D., Chairperson, Board of Directors
David Cook, M.Ed., Local Program Review Coordinator
Encl.:Mid-cycle Review Report
FullPrivate School Approval Certificate, Expiration Date: August 31, 2016
Page 1 of 2
MASSACHUSETTS DEPARTMENT OFELEMENTARY AND SECONDARY EDUCATION
PRIVATE SCHOOL MID-CYCLE REVIEW
Dr. Franklin Perkins School
Dr. Franklin Perkins Day and Residential Programs
MID-CYCLE REVIEW REPORT
Previous Program Review Corrective Action Plan Submitted on August 20, 2010
Progress Reports Submitted on December 10, 2010
Mid-cycleOnsite Visit Conducted on September 28, 2012 and October 1, 2012
Date of this Report:October 25, 2012
CriterionNumber
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 orAdditional 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
Selected Approved Private School Program Mid-cycle Review Criteria
2.2 Approvals, Licenses, Certificates of Inspection18.04(1); 28.09(2)(b)(5); 28.09(5) (b); 28.09(6) (b, c) / / Documentation
Observations / Dr. Franklin Perkins School submitted copies of current licenses, approvals, and certificates of inspection.
2.3 EEC Licensure
102 CMR 3.00
(Residential Programs only) / / Documentation / Dr. Franklin Perkins School submitted a copy of their EEC license.
6.1 Daily Instructional Hours
603 CMR 27.04
6.4 School Days Per Year
603 CMR 27.05(2); 28.09(9)(a) / / Documentation / Dr. Franklin Perkins School submitted a Learning Time Worksheet and Block Schedules documenting that students are receiving the required number of instructional hours and school days as required for a 12 month program.
8.5 Current IEP & Student Roster
28.09(5)(a) / / Documentation / Dr. Franklin Perkins School submitted a Student Roster that contains all of the required elements. All IEPs reviewed had a parent or guardian signature or there was evidence of efforts made by Dr. Franklin Perkins School to obtain a current IEP.
11.3 Educational Administrator Qualifications
28.09(5)(a); 28.09(7)(a);
603 CMR 44.00 / / Documentation
Interviews / Dr. Franklin Perkins School submitted documentation indicating that the Educational Administrator is appropriately licensed as such, and is performing the duties required for this position.
11.4 Teachers
(Special Education Teachers and Regular Education Teachers)18.05(11)(f); 28.09(5)(a); 28.09(7)(b, c); 34 CFR 300.321 / / Documentation / Dr. Franklin Perkins School submitted a teacher roster and all required licensing information that shows that all teachers are appropriately licensed or on approved waivers as required.
11.5 Related Services Staff
28.09(7)(d) / / Documentation / Dr. Franklin Perkins School submitted a copy of their Related Services Staff Roster, as well as all licensing information for all related services staff members, showing that they are appropriately certified, licensed or registered in their professional areas as required.11.6 Master Staff Roster
28.09(7) / / Documentation
Interviews / At the time of the Program Review, areview of documentation revealed that both the Day and Residential Programs did not have the number of Full Time Equivalents for the Special Education Teachers and the Regular Education Teachers per their last ESE approved Program Budgets (Special Circumstances, 2007).In the Residential Program, one of the staff in the Case Worker/Manager Master position,also did not have a Masters degree and, therefore, was not qualified to serve in that position.
For the Mid-cycle Review, Dr. Franklin Perkins School submitted Master Staff Rosters that now correspond to the most recentlyapprovedProgram Budgets.
19 Anti-Hazing
M.G.L. c. 269, §§ 17 through 19 / / Documentation
Student Record Review / Dr. Franklin Perkins School submitted a copy of the anti-hazing disciplinary plan and documentation of each student’s receipt of the school program’s anti-hazing disciplinary policy approved by the program’s Board of Directors.
20 Bullying Prevention and Intervention
M.G.L. c. 71, s. 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). / / Documentation / Dr. Franklin Perkins School submitted a copy of their Bullying Prevention and Intervention Plan, as well as a description of how the Bullying Prevention and Intervention plan was distributed to staff members and students. Additionally, Dr. Franklin Perkins School submitted a description of the professional development plan developed by the program for all staff for the school year and evidence of its implementation.
Identified Areas of Non-Compliance from the 2009-2010 Program Review or Other Areas of Concern
1.2 Program & Student Description , Program Capacity208.09(2)(a)(2)
28.09(2)(B)(2,
3,7) / / Documentation / At the time of the Program Review, documentation revealed that Dr. Franklin Perkins School’s narrative of how physical education and adaptive physical education services were provided did not describe how adaptive physical education was provided when included on a student’s Individual Education Plan.
During the Mid-cycle Review, Dr. Franklin Perkins School submitted documentation that now includes a description of how adaptive physical education is provided when included on a student’s Individual Education Plan.
4.2 Public Information and Postings
28.09(6)(a,b,c,
d,e);
28.09(2)(b(4) / / Observation / At the time of the Program Review, Dr. Franklin Perkins School did not have posted emergency procedures in its educational facilities.
During the Mid-cycle Review, emergency procedures wereseen in educational facilities.
9.4 Physical Restraint (Day Programs Only)
18.05(5); 603 CMR 46.00 / / Documentation / At the time of the Program Review, Dr. Franklin Perkins School submitted a restraint policy that did not include all of the required elements.
During the Mid-cycle Review Dr. Franklin Perkins School submitted their updated restraint policy that now includes all required elements.
10.1 Staffing for Instructional Groupings
28.06(6)(d)
28.09(7)(e) / / Documentation
Observation / At the time of the Program Review, there was not an agreed upon student to licensed teacher and aide ratio. It was determined at that time that the approved ratio for Dr. Franklin Perkins School is 10:1:1.
During the Mid-cycle Review, Dr. Franklin Perkins School submitted block schedules indicating that all classes are within the approved 10:1:1 ratio. This was confirmed during the onsite visit through classroom observations.
12.1 New Staff Orientation and Training
18.05(11)(g,i);
28.09(7)(f) / / Documentation
Staff Records
Interviews / At the time of the Program Review, documentation revealed that Dr. Franklin Perkins School’s written plan for staff orientation did not include all of the required orientation topics specifically by name. Additionally, the Department was not able to verify that new staff members receive all of the required trainings.
During the Mid-cycle Review, Dr. Franklin Perkins School submitted an updated staff orientation schedule which now includes all required topics by name. Additionally, the Department was able to verify that all new staff members receive all of the required orientation trainings through a review of staff records and interviews.
12.2 in-Service Training Plan and Calendar
28.09(7)(f);
28.09(9)(b);
28.09(10);
18.03(3);
18.05(9)(e)(1)
18.05(10)
18.05(11)(h)
Title VI: 42 U.S.C. 200d; 34 CFR 100.3; EEOA: 20 U.S.C. 1703(f); Title IX: 20 U.S.C. 1681; 34 CFR106.31-106.42; M.G.L. c. 76, § 5; 603 CMR 26.00, esp. 26.07(2)(3 / / Documentation
Staff Records
Interviews / At the time of the Program Review, the Department was not able to verify that all staff received annual in-service training on average at least two hours per month. Additionally, the names of the trainings did not always correspond to the required training topics.
During the Mid-cycle Review,the Department was able to verify that staff members receive in-service training for at least two hours per month. Additionally, staff record review indicated that all staff members receive the required annual trainings.
12.2(c) Required Training-CPR Certification
18.05(9)(e) / / Staff Records / At the time of the Program Review, Dr. Franklin Perkins School submitted a training plan that indicated that all staff members were certified in CPR. However, staff records indicated that many certifications had expired.
During the Mid-cycle Review, a review of staff records indicated that all staff members now have current CPR certifications.
15.8 Registering Complaints and Grievances-Parents, Students, and Employees
18.05(1)(b)(16)
Title IX: 20 U.S.C. 1681; 34CFR 106.8; Section 504: 29 U.S.C. 794; 34 CFR 104.7; Title II: 42 U.S.C 12132; 28 CFR 35.107 / / At the time of the Program Review, Dr. Franklin Perkins School submitted documentation that revealed that the school’s written grievance procedures for students alleging discrimination did not state the specific protected categories of discrimination.
During the Mid-cycle Review, Dr. Franklin Perkins School submitted the schools grievance procedures for students,whichnow includes the specific protected categories of discrimination as required.
16.5 Administration of Medication
18.05(9)(e,f) / / Documentation
Student Records / At the time of the Program Review, documentation revealed that Dr. Franklin Perkins Schools’ written policy and procedures regarding the administration of medication did not include that written authorization from a parent to administer medication to a student is renewed annually.
During the Mid-cycle Review, Dr. Franklin Perkins School submitted their updated policy and procedure which now includes a statement that written authorization to administer medication to a student is renewed annually. Additionally, student records verified that parental consent to administer medication is being obtained annually.
16.7 Preventive Health Care
18.05(9)(g)(1); 105 CMR 200.100(B)(1); 105 CMR 200.400(B);
105 CMR 200.400(C);
G.L c. 71, § 57; and
G.L. c. 111, § 111 / / At the time of the Program Review, documentation revealed that Dr. Franklin Perkins School’s policy and procedure for preventive health care did not include that it notifies referring agencies of the introduction of a communicable disease into the programs. Also, student record review and interviews revealed that the Day Program did not make the provision for each student to receive an annual dental examination.
During the Mid-cycle Review, Dr. Franklin Perkins School submitted a revised policy for preventive health care that includes the procedure for the notification of referring agencies in the event of the introduction of a communicable disease into the program. Additionally, a review of student records indicated that Dr. Franklin Perkins School now makes provisions for each student to receive an annual dental examination.
Dr. Franklin Perkins School, Day and Residential Programs Mid-cycle Review Report
October 25, 2012
Page 1 of 19
Commonwealth of Massachusetts
Department of Elementary and Secondary Education
Dr. Franklin Perkins
Dr. Franklin Perkins Residential Program
a PRIVATE SPECIAL EDUCATION PROGRAM operated pursuant to
603 CMR 18.00 and 28.09
971 Main Street
Lancaster, MA 01523
Program Rate Based on: 65 Students
Approved Enrollment: 82 StudentsDay Program / Residential Program
Summer Program / 10 month program / 11 month program / 12 month program
APPROVED STUDENT:LICENSED EDUCATOR RATIO:Not Applicable
APPROVED STUDENT:LICENSED EDUCATOR:AIDE RATIO:10:1:1
APPROVAL STATUS
FULL APPROVAL
Expires on: August 31, 2016
The current approval is a result of a Mid-cycle Reviewconducted in the 2012-2013school year and the next review is scheduled for the 2015-2016 school year.
Paul Bottome, EDUCATIONAL SPECIALIST, Program Quality Assurance Services
nina m. marchese, Supervisor, Program Quality Assurance Services
Darlene A. Lynch, DIRECTOR, Program Quality Assurance Services
Date issued: 10/25/12
Commonwealth of Massachusetts
Department of Elementary and Secondary Education
Dr. Franklin Perkins
Dr. Franklin Perkins Day Program
a PRIVATE SPECIAL EDUCATION PROGRAM operated pursuant to
603 CMR 18.00 and 28.09
971 Main Street
Lancaster, MA 01523
Program Rate Based on: 72Students
Approved Enrollment: 110 StudentsDay Program / Residential Program
Summer Program / 10 month program / 11 month program / 12 month program
APPROVED STUDENT:LICENSED EDUCATOR RATIO:Not Applicable
APPROVED STUDENT:LICENSED EDUCATOR:AIDE RATIO:10:1:1
APPROVAL STATUS
FULL APPROVAL
Expires on: August 31,2016
The current approval is a result of a Mid-cycle Reviewconducted in the 2012-2013school year and the next review is scheduled for the 2015-2016 school year.
Paul Bottome, EDUCATIONAL SPECIALIST, Program Quality Assurance Services
nina m. marchese, Supervisor, Program Quality Assurance Services
Date issued: 10/25/12 / Darlene A. Lynch, DIRECTOR, Program Quality Assurance Services