Program Quality Assurance Services
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Charter School or District: Marblehead
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 09/12/2012.
Mandatory One-Year Compliance Date: 09/11/2013
Summary of Required Corrective Action Plans in this Report
Criterion / Criterion Title / CPR RatingSE 9 / Timeline for determination of eligibility and provision of documentation to parent / Partially Implemented
SE 14 / Review and revision of IEPs / Partially Implemented
SE 18A / IEP development and content / Partially Implemented
SE 18B / Determination of placement; provision of IEP to parent / Partially Implemented
SE 24 / 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 / Partially Implemented
SE 35 / Assistive technology: specialized materials and equipment / Partially Implemented
SE 48 / FAPE (Free, appropriate, public education): Equal opportunity to participate in educational, nonacademic, extracurricular and ancillary programs, as well as participation in regular education / Partially Implemented
CR 3 / Access to a full range of education programs / Partially Implemented
CR 7 / Information to be translated into languages other than English / Partially Implemented
CR 7B / Structured learning time / Partially Implemented
CR 9 / Hiring and employment practices of prospective employers of students / Partially Implemented
CR 10A / Student handbooks and codes of conduct / Partially Implemented
CR 11A / Designation of coordinator(s); grievance procedures / Partially Implemented
CR 12A / Annual and continuous notification concerning nondiscrimination and coordinators / Partially Implemented
CR 16 / Notice to students 16 or over leaving school without a high school diploma, certificate of attainment, or certificate of completion / Partially Implemented
CR 17A / Use of physical restraint on any student enrolled in a publicly-funded education program / Partially Implemented
CR 25 / Institutional self-evaluation / Partially Implemented
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Criterion & Topic:
SE 9 Timeline for determination of eligibility and provision of documentation to parent / CPR Rating:
Partially Implemented
Department CPR Findings:
A review of student records indicated that evaluations are not always conducted within 30 school working days after the receipt of parental consent.
Description of Corrective Action:
The Director will use Special Education Leadership meetings, which take place every other Friday, to review this requirement and to develop a plan to streamline the handling of parental consent so that no time is lost prior to the beginning of the evaluation process. Including principals in this training and awareness will also improve compliance. This will allow us to fully implement this requirement.
Title/Role(s) of responsible Persons:
Director of Student Services, Special Education Chairpersons, Building Principals / Expected Date of Completion:
04/30/2013
Evidence of Completion of the Corrective Action:
Evidence of our Special Education Leadership meeting agenda showing discussion and materials used to improve compliance with this criterion.
Description of Internal Monitoring Procedures:
Director will randomly pull a sampling of initial and reevaluation files at each level to self-assess improvement and compliance with this regulation.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 9 Timeline for determination of eligibility and provision of documentation to parent / Corrective Action Plan Status: Approved
Status Date:11/19/2012
Basis for Partial Approval or Disapproval:
The district proposed a comprehensive plan of corrective action. It will develop a process to streamline the handling of parental consents to ensure compliance with required timelines, as well as provide training to appropriate staff on the revised protocol. The district will then conduct a follow-up administrative record review to ensure 100% compliance.
Department Order of Corrective Action:
Required Elements of Progress Report(s):
By January 11, 2013, the district will submit its plan to streamline and track the receipt of parental consents for evaluations, as well as evidence (agenda, signed attendance sheets, training materials) of training for principals and required special education staff on the revised process.
By April 12, 2013, after the district has implemented all corrective actions, the district will conduct an internal record review to ensure that evaluations are conducted within 30 school working days after the receipt of parental consent. Report the number of evaluation consents received, the number of evaluations that were conducted in 30 school working days, and if any non-compliance is identified, report the steps taken to remedy each individual file. The district will also identify the root cause of the ongoing non-compliance and a plan of action to ensure ongoing compliance.
*Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s).
Progress Report Due Date(s):
01/11/2013
04/12/2013
1
MA Department of Elementary & Secondary Education ,Program Quality Assurance Services
Marblehead CPR Corrective Action Plan
COORDINATED PROGRAM REVIEWCORRECTIVE ACTION PLAN
Criterion & Topic:
SE 14 Review and revision of IEPs / CPR Rating:
Partially Implemented
Department CPR Findings:
A review of student records and staff interviews indicated that IEP Team meetings are not always held prior to the expiration date of the IEP.
Description of Corrective Action:
MPS believed that if both parent and district agreed in writing to hold the IEP Team meeting after the expiration date of the IEP, that this was allowed practice. With this citing, MPS will be increasing our efforts to schedule these meetings with enough advance time so as not to go beyond the IEP expiration date. This will not be a major difficulty now that we are aware of the "no exceptions, even if parent and district agree" opinion.
Title/Role(s) of responsible Persons:
Director of Student Services and Special Education Chairpersons / Expected Date of Completion:
04/30/2013
Evidence of Completion of the Corrective Action:
Evidence will be that from a random sampling of each chairperson's scheduled IEP Team meetings, there will be 100% compliance.
Description of Internal Monitoring Procedures:
The Director will request all special education chairpersons to identify those situations where scheduling seems to be problematic and to schedule those meetings well in advance of the expiration date.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 14 Review and revision of IEPs / Corrective Action Plan Status: Approved
Status Date:11/19/2012
Basis for Partial Approval or Disapproval:
The district proposed a comprehensive plan of corrective action for this criterion. It will develop a tracking process to ensure that annual reviews will be conducted and IEPs will be developed prior to the expiration date of the previous IEP. The district will provide training to appropriate staff on the tracking process and conduct a follow-up administrative tracking review to ensure 100% compliance.
Department Order of Corrective Action:
Required Elements of Progress Report(s):
By January 11, 2013, the district will submit a description of its tracking procedures to ensure that annual review Team meetings are conducted and that IEPs are developed prior to the expiration date of the previous IEP. Submit evidence (agenda, signed attendance sheets, training materials) of training for principals and required special education staff on the revised procedures.
By April 12, 2013, after the district has implemented all corrective actions, the district will conduct an internal review of the tracking data at all levels (elementary, middle school, high school) to ensure that annual reviews are conducted and IEPs are developed prior to the expiration date of the previous IEP. Report the number of annual review Team meetings conducted at each level and the number of annual reviews that had IEPs proposed prior to the expiration date of the previous IEP. If any non-compliance is identified, report the steps taken to remedy each individual file and identify and report the root cause of the ongoing non-compliance with a plan of action to ensure ongoing compliance.
*Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s).
Progress Report Due Date(s):
01/11/2013
04/12/2013
1
MA Department of Elementary & Secondary Education ,Program Quality Assurance Services
Marblehead CPR Corrective Action Plan
COORDINATED PROGRAM REVIEWCORRECTIVE ACTION PLAN
Criterion & Topic:
SE 18A IEP development and content / CPR Rating:
Partially Implemented
Department CPR Findings:
A review of student records indicated that IEP Teams do not reference the specific skills and proficiencies in IEPs that are needed to avoid and respond to bullying, harassment, or teasing for those students whose disability affects their social skills development or are on the autism spectrum.
Description of Corrective Action:
After providing a basic training to all special education chairpersons through our Special Education Leadership meetings, Chairpersons will provide information and training at their monthly department meetings to special education teachers at all levels.
Title/Role(s) of responsible Persons:
Director of Student Services, Special Education Chairpersons, special education teachers / Expected Date of Completion:
04/30/2013
Evidence of Completion of the Corrective Action:
Chairpersons, who chair all special education meetings, will verify through the use of our Team meeting summary sheet, that IEP meetings have discussed this issue and made provisions, where necessary, to avoid and respond to bullying, harassment or teasing students whose disability effects their social development or for those students with an ASD diagnosis.
Description of Internal Monitoring Procedures:
Chairpersons will report back to the Director regarding the provision of training to the teachers, complete with agenda and training materials to insure that all teachers understand this requirement.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 18A IEP development and content / Corrective Action Plan Status: Approved
Status Date:11/19/2012
Basis for Partial Approval or Disapproval:
The district proposed a comprehensive plan of corrective action for this criterion. The district will train required staff on how to reference the specific skills and proficiencies in IEPs that are needed to avoid and respond to bullying, harassment, or teasing, and will conduct an administrative review of student records to ensure 100% compliance.
Department Order of Corrective Action:
Required Elements of Progress Report(s):
By January 11, 2013, the district will submit evidence of staff training (agenda, signed attendance sheets, training materials etc.) that training for special education staff was conducted on how to reference the specific skills and proficiencies in IEPs that are needed to avoid and respond to bullying, harassment, or teasing for those students whose disability affects their social skills development or are on the autism spectrum. For those students whose names were provided to the district as being out of compliance during the record review, submit updated copies of these students' IEPs.
By April 12, 2013, following the district's implementation of all corrective actions, please select a sample of records of students who are on the autism spectrum or whose disability affects their social skills development at each level to verify that the records contain documentation that IEP Teams have considered and specifically addressed the skills and proficiencies needed to avoid and respond to bullying, harassment, or teasing. Report the number of records reviewed at each level and the number of records in compliance. For any records not in compliance with this criterion, provide the results of a root cause analysis of the non-compliance and the specific actions taken by the district to remedy any identified noncompliance.
*Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s).
Progress Report Due Date(s):
01/11/2013
04/12/2013
1
MA Department of Elementary & Secondary Education ,Program Quality Assurance Services
Marblehead CPR Corrective Action Plan
COORDINATED PROGRAM REVIEWCORRECTIVE ACTION PLAN
Criterion & Topic:
SE 18B Determination of placement; provision of IEP to parent / CPR Rating:
Partially Implemented
Department CPR Findings:
A review of student records indicated that at all school levels and for students in out-of- district placements, parents are not always provided with the proposed IEP and placement immediately following the development of the IEP.
Description of Corrective Action:
The Director, in collaboration with Special Education Chairpersons, at monthly Special Education department meetings at all levels, will provide training to special education teachers, related service providers and any other person responsible for a component of the IEP document regarding the need to provide the IEP to parents as soon after the development as possible but no later than 10 days after the IEP development meeting. MPS will continue to give parents a TEAM summary sheet at the end of the meeting so that parents understand what services/changes were being proposed at the IEP meeting and [new] include an expected date that parent(s) can expect to receive the IEP proposal. Principals will also be included in the trainings to stress the importance of their signing the proposed IEPs in a timely manner so that they can be delivered to parents.
Title/Role(s) of responsible Persons:
Director of Student Services, Special Education Chairpersons, Principals / Expected Date of Completion:
06/30/2013
Evidence of Completion of the Corrective Action:
It will be evident that our efforts to meet this requirement will be complete when training has been conducted at all levels and that we are in 100% compliance with parents receiving the proposed IEP immediately but no more than 10 days after the IEP meeting date.
Description of Internal Monitoring Procedures:
Through a random sampling comparison between Team summary sheets, with date IEP is expected to be delivered, and actual delivery date, the Director and Special Education Chairpersons will monitor progress towards completion.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 18B Determination of placement; provision of IEP to parent / Corrective Action Plan Status: Approved
Status Date:11/19/2012
Basis for Partial Approval or Disapproval:
The district proposed a comprehensive plan of corrective action for this criterion. The district will develop a tracking process to ensure that proposed IEPs and placements for all out-of-district students are provided to parents immediately following the development of the IEP. The district will provide training to appropriate staff on the tracking process and will conduct a follow-up administrative record review to ensure 100% compliance.
Department Order of Corrective Action:
Required Elements of Progress Report(s):
By January 11, 2013, the district will submit evidence (agenda, signed attendance sheets, training materials etc.) that training for special education staff was conducted on the provision of IEPs to parent.
By April 12, 2013, following the district's implementation of all corrective actions, conduct an internal review of the tracking data for students in out-of-district placements at each level (elementary, MS, & HS). Report the number of IEP Team meetings held (annual reviews & re-evals) requiring the development of IEPs, and the number of parents who received proposed IEPs and placements immediately following the Team meeting. For any records not in compliance, report the root cause analysis of the ongoing non-compliance, the district's plan to remedy the noncompliance and the specific corrective actions taken by the district to remedy any identified noncompliance in specific student records.
*Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s).
Progress Report Due Date(s):
01/11/2013
04/12/2013
1
MA Department of Elementary & Secondary Education ,Program Quality Assurance Services
Marblehead CPR Corrective Action Plan
COORDINATED PROGRAM REVIEWCORRECTIVE ACTION PLAN
Criterion & Topic:
SE 24 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 / CPR Rating:
Partially Implemented
Department CPR Findings:
A review of student records indicated that at the preschool, elementary, and high school levels the district's Notices of Proposed Action (N1) did not always include the following four required elements:
1. An explanation of why the agency proposed or refused to take the action. 2. A description of any other options that the agency considered and the reasons why those options were rejected. 3. A description of each evaluation procedure, test, record, or report the agency used as a basis for the proposed or refused action. 4. A description of any other factors relevant to the agency's proposal or refusal. In addition, the district does not always provide parents with notice documenting the district's actions when proposing home/ hospital services; conducting manifestation determination meetings or IEP team meetings regarding a change of placement.
Description of Corrective Action:
At the preschool, elementary and high school levels, the District will fully comply with this requirement, through additional training of Special Education Chairpersons, who are primarily responsible for the completion of N1's This training will take place at one or more Special Education Leadership meetings which take place two times per month during the school year.
Title/Role(s) of responsible Persons:
Special Education Chairpersons with review by Director of Student Services / Expected Date of Completion:
06/30/2013
Evidence of Completion of the Corrective Action:
We will know that we are in full compliance with this criterion when 100% of the situations requiring an N1 are completed, answering all of the required questions. Random samples of N1's will be utilized and reported on.
Description of Internal Monitoring Procedures:
As Director, I have also made the decision to require the use of the question format (through our web-based IEP program) rather than the paragraph, to assist in guiding Chairs to improve their N1 writing. The Special Education Chairs and I will use individual meeting times to monitor compliance.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 24 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 / Corrective Action Plan Status: Approved
Status Date:11/19/2012
Basis for Partial Approval or Disapproval:
The district proposed a comprehensive plan of corrective action for this criterion. The district will conduct training on the requirements of N1 notices; procedures for notifying and documenting the district's actions when proposing home/hospital services to parents; and procedures for conducting manifestation determination meetings or IEP Team meetings regarding a change of placement. The district will also conduct a follow-up administrative record review to ensure 100% compliance.
Department Order of Corrective Action:
Required Elements of Progress Report(s):
By January 11, 2013, the district will submit evidence (agenda, signed attendance sheets, training materials, etc.)that training was conducted for special education staff on the requirements for writing comprehensive Notices of Proposed School District Action (N1) forms.
By April 12, 2013, following the district's implementation of all corrective actions, conduct an internal record review at each level (elementary, MS, & HS). Report the number of records reviewed and the number that contained comprehensive N1 forms that addressed all required elements: 1. An explanation of why the agency proposed or refused to take the action. 2. A description of any other options that the agency considered and the reasons why those options were rejected. 3. A description of each evaluation procedure, test, record, or report the agency used as a basis for the proposed or refused action. 4. A description of any other factors relevant to the agency's proposal or refusal. For any records not in compliance, report the root cause analysis of the ongoing non-compliance, the district's plan to remedy the non-compliance and the specific corrective actions taken by the district to remedy any identified noncompliance in specific student records.
*Please note that when 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 record review; b) Date of the review; c) Name of person(s) who conducted the review, their roles(s), and their signature(s).
Progress Report Due Date(s):
01/11/2013
04/12/2013
1