MASSACHUSETTS DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION
Program Quality Assurance Services
COORDINATED PROGRAM REVIEW

CORRECTIVE ACTION PLAN

Charter School or District: Northborough

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 09/26/2012.

Mandatory One-Year Compliance Date: 09/26/2013

Summary of Required Corrective Action Plans in this Report

Criterion / Criterion Title / CPR Rating
SE 2 / Required and optional assessments / Partially Implemented
SE 9 / Timeline for determination of eligibility and provision of documentation to parent / Partially Implemented
SE 14 / Review and revision of IEPs / Partially Implemented
SE 18B / Determination of placement; provision of IEP to parent / Partially Implemented
SE 29 / Communications are in English and primary language of home / Partially Implemented
SE 55 / Special education facilities and classrooms / Partially Implemented
CR 7 / Information to be translated into languages other than English / Partially Implemented
CR 23 / Comparability of facilities / Partially Implemented
COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Criterion & Topic:
SE 2 Required and optional assessments / CPR Rating:
Partially Implemented
Department CPR Findings:
A review of student records and interviews with staff members indicated that the district did not consistently complete the educational assessment; specifically, information on the history of the student's educational progress in the general curriculum was missing.
Description of Corrective Action:
The District will create a procedure that details who is responsible for completing the Educational Assessment forms (A and B). 2. A training will be provided for all staff responsible for completing these assessments. 3. In five months, the District will implement an informal records review to assess whether or not students' files have appropriately completed Educational Assessments A and B.
Title/Role(s) of responsible Persons:
Director of Student Support Services-Barbara Goodman / Expected Date of Completion:
03/01/2013
Evidence of Completion of the Corrective Action:
The District will submit at attendance sheet and agenda for the training implemented on Educational Assessments A and B. 2. The District will submit sample Educational Assessment Forms A and B completed after the training. 3) The District will submit a summary of the informal record review as part of the Corrective Action Plan.
Description of Internal Monitoring Procedures:
1. The District's special education secretary will review each student's evaluation packet when it is returned to the special education office and record receipt of each Educational Assessment form. 2. The District's Special Education Coordinator, under the supervision of the special education administrators, will review the content of the forms for compliance.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 2 Required and optional assessments / Corrective Action Plan Status: Approved
Status Date:11/05/2012
Basis for Partial Approval or Disapproval:
The district will develop a procedure and identify staff responsible to complete the student's history in the general curriculum for Educational Assessment A. Identified staff will receive training to complete the Educational Assessment A for any student receiving eligibility determination for an initial or re-evaluation. The district will conduct internal monitoring to determine whether the procedure and training are effective and result in completed Educational Assessment As in student records.
Department Order of Corrective Action:
Required Elements of Progress Report(s):
The district will provide a narrative description of their new procedures related to the completion of Educational Assessment A along with evidence of staff training on the procedures, which will include but not be limited to a training agenda, attendance sheet and copies of the materials presented. Include a copy of the actual procedure for documenting a student's educational history in the general curriculum. Please submit this to the Department by January 9, 2013.
Submit the description of the internal oversight and tracking system and identify the person(s) responsible for the oversight, including the date of the system's implementation. Submit this information by January 9, 2013.
Subsequent to the completion of training activities, submit the results of an administrative review of ten student records sampled across grade levels for the completion and inclusion of Educational Assessment A for initial and re-evaluation meetings. Indicate the number of records reviewed, the number found to be compliant, and an explanation of the root cause for any continued noncompliance and a description of additional corrective actions taken by the district to address any identified noncompliance. Please submit this to the Department by May 29, 2013.
*Please note when conducting administrative 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):
01/09/2013
05/29/2013

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MA Department of Elementary & Secondary Education,Program Quality Assurance Services

Northborough CPR Corrective Action Plan

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 demonstrated that the district does not consistently, within forty five school working days after receipt of the parent's written consent to an initial evaluation or a re-evaluation, determine whether the student is eligible for special education and provide the parent either a proposed IEP and proposed placement or a written explanation of the finding of no eligibility.
Description of Corrective Action:
The District needs to assess the root cause of the timeline delays in order to analyze why parents reported that they were not receiving confirmation of eligibility for special education services within the required 45 day timeline for initial and three year re-evaluations. A training will be implemented for all staff responsible for assessing students in response to parents' written consent for evaluation. The training will review the timeline requirements connected to the initial evaluation and re-evaluation processes. The district will monitor timelines for all students by conducting an informal records review for all students who are involved in assessments to determine eligibility for special education.
Title/Role(s) of responsible Persons:
Director of Student Support Services-Barbara Goodman / Expected Date of Completion:
03/01/2013
Evidence of Completion of the Corrective Action:
The District needs to assess the root cause of the timeline delays in order to analyze why parents reported that they were not receiving confirmation of eligibility for special education services within the required 45 day timeline for initial and three year re-evaluations. A training will be implemented for all staff responsible for assessing students in response to parents' written consent for evaluation. The training will review the timeline requirements connected to the initial evaluation and re-evaluation processes. The district will monitor timelines for all students by conducting an informal records review for all students who are involved in assessments to determine eligibility for special education.
Description of Internal Monitoring Procedures:
The District needs to assess the root cause of the timeline delays in order to analyze why parents reported that they were not receiving confirmation of eligibility for special education services within the required 45 day timeline for initial and three year re-evaluations. A training will be implemented for all staff responsible for assessing students in response to parents' written consent for evaluation. The training will review the timeline requirements connected to the initial evaluation and re-evaluation processes. The district will monitor timelines for all students by conducting an informal records review for all students who are involved in assessments to determine eligibility for special education.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 9 Timeline for determination of eligibility and provision of documentation to parent / Corrective Action Plan Status: Partially Approved
Status Date:11/05/2012
Basis for Partial Approval or Disapproval:
The district will conduct a root cause analysis to determine why the district does not consistently convene IEP meetings 45 school working days after receipt of the consent signed by the parent. The root cause analysis may indicate that a different response than training is needed to bring the district in compliance. Also, please note that parents are not required to request an assessment in writing.
Department Order of Corrective Action:
The results of the root cause analysis must determine what actions the district will take to correct the delay in convening eligibility determination meetings within 45 school working days from the date of receipt of the signed consent form. The district must examine all areas related to the eligibility determination process for the root cause analysis, including but not limited to the district's current tracking system, personnel responsiveness to timelines in completing assessments, and processing paperwork for the Team meeting.
Required Elements of Progress Report(s):
Please submit a detailed narrative of the root cause(s) of the noncompliance and the steps the district has taken to address those issues related to the 45 day timeline. As part of this, submit a description of the internal oversight and tracking system. Please identify the person(s) responsible for oversight of these activities, as well as the training provided to the person(s) responsible for oversight. Please submit this report by January 9, 2013.
Include the agenda, signed attendance sheets, indicating the title and role of staff and the name and title of the presenter. Please submit this report by January 9, 2013.
Subsequent to the training, please conduct a review of student records. Select a sample of 10-15 student records representative of preschool, elementary, middle school and out of district placements with the most recent IEP activity either an initial evaluation to determine eligibility, or a re-evaluation. Review the records to determine whether the 45 day timeline has been met. Submit the number of student records reviewed by school level, the number of records that complied with the requirements and for any record found in continued noncompliance, determine the root cause(s) for the noncompliance and provide the district's plan to remedy the identified noncompliance to ensure 100% compliance with this criterion. This progress report is due May 29, 2013.
The district must maintain the following documentation and make it available to the Department upon request: a) List of student names, building names and grade levels of the records reviewed; b) the date of the review; c) Name(s) of the person(s) who conducted the review, their role(s) and signatures(s).
Progress Report Due Date(s):
01/09/2013
05/29/2013

1

MA Department of Elementary & Secondary Education,Program Quality Assurance Services

Northborough CPR Corrective Action Plan

COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Criterion & Topic:
SE 14 Review and revision of IEPs / CPR Rating:
Partially Implemented
Department CPR Findings:
Interviews with staff members and parent surveys indicated that the district is not consistently convening an annual Team meeting on or before the anniversary date of the IEP. Specifically, interviews indicated that when the parent is accompanied by an advocate, the district requires an administrator to attend the Team meeting, which sometimes results in rescheduling of the Team meeting to convene beyond the anniversary date of the IEP.
Description of Corrective Action:
The District will retrain Special Education staff on the regulations for convening the Team within 45 working school days of parents' consent to evaluate and the scheduling of these meetings when an advocate will be present. Timelines will be monitored for initial and re-evaluation meetings for compliance. The District will complete a record review of all initial and re-evaluation meetings. In five months an informal record review will be completed to review attendance sheets for meetings that an advocate attended and the date of the meetings.
Title/Role(s) of responsible Persons:
Director of Student Support Services-Barbara Goodman / Expected Date of Completion:
03/01/2013
Evidence of Completion of the Corrective Action:
The District will submit sample attendance sheets for meetings that an advocate attended.
The District will submit the attendance sheet from the staff training on timelines.
The District will write a summary of the informal record review as part of the Corrective Action Plan.
Description of Internal Monitoring Procedures:
The Director of Student Support Services and the Assistant Director of Student Support Services will oversee the process for compliance.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 14 Review and revision of IEPs / Corrective Action Plan Status: Partially Approved
Status Date:11/13/2012
Basis for Partial Approval or Disapproval:
The district proposes actions to address eligibility timelines; however, this finding concerns timeliness of convening annual reviews to revise IEPs. The district does address training of special education staff when advocates will be present at IEP meetings, and an administrative review is included as part of the corrective action plan.
Department Order of Corrective Action:
The district must conduct a root cause analysis to determine why IEPs are exceeding the anniversary date to determine what course to take for a corrective action.
Required Elements of Progress Report(s):
Provide a detailed narrative description of the root cause(s) of the noncompliance and the steps the district has taken to address those issues related to IEP meetings for annual timelines. As part of this, submit a description of the internal oversight and tracking system. Please identify the person(s) responsible for oversight of these activities. And the training provided to the persons responsible for oversight. Include the agenda, signed attendance sheets, indicating title/role of staff and the name and title of the presenter. Please submit this report by January 9, 2013.
Subsequent to the training, please conduct a review of student records. Select a sample of 15-20 student records representative of preschool, elementary, middle school levels and out of district placements with the most recent IEP annual review to determine whether the Team met before the anniversary date of the IEP. Review the records to determine whether the Team met before the IEP expired. Submit the number of student records reviewed by school level, the number of records that complied with the requirements and for any record found in continued noncompliance, determine the root cause(s) of the noncompliance and provide the district's plan to remedy the identified noncompliance to ensure 100% compliance with this criterion.
The district must maintain the following documentation and make it available to the Department onsite upon request: a) List of student names, building names and grade levels of the records reviewed: b) the date of the review: c) Name(s) of the person(s) who conducted the review, their role(s) and their signature(s). This progress report is due May 29, 2013.
Progress Report Due Date(s):
01/09/2013
05/29/2013

1

MA Department of Elementary & Secondary Education,Program Quality Assurance Services

Northborough CPR Corrective Action Plan

COORDINATED PROGRAM REVIEW
CORRECTIVE ACTION PLAN
Criterion & Topic:
SE 18B Determination of placement; provision of IEP to parent / CPR Rating:
Partially Implemented
Department CPR Findings:
Student records, parent surveys and staff interviews indicated that the parent is not always provided with two copies of the proposed IEP and placement immediately following the Team meeting.
Description of Corrective Action:
At the time of the CPRF records review, it appeared that the District was not sending two copies of its' proposed IEP to parents. Although the District's special education secretary began this practice in the fall of 2010, this was not documented in students' N1s until the spring of 2011. For Corrective Action, the District will ensure that all staff, including the secretary, continues to comply with the requirement of documenting that two copies of the IEP are sent home for the parents' consideration. A training will be implemented to all staff as a reminder of this requirement. This issue will also be addressed at the special education secretaries meeting held in the fall of 2012. An informal record review will be implemented to ensure that each student's N1 states that two copies of the proposed IEP is sent to the parent.
Title/Role(s) of responsible Persons:
Director of Student Support Services-Barbara Goodman / Expected Date of Completion:
03/01/2013
Evidence of Completion of the Corrective Action:
The District will submit an agenda and attendance sheet for the staff training and secretaries' meeting. 2) The District will submit a summary of the informal record review As part of the Corrective Action Plan.
Description of Internal Monitoring Procedures:
1. The District's special education secretary will review each student's IEP packet when it is returned to the special education office and record that two copies of each student's proposed IEP is sent to the parent. 2) The District's special education coordinator will review each student's N1 to ensure that liaisons are documenting that two copies of the proposed IEP are being sent to the parent.
CORRECTIVE ACTION PLAN APPROVAL SECTION
Criterion:
SE 18B Determination of placement; provision of IEP to parent / Corrective Action Plan Status: Partially Approved
Status Date:11/05/2012
Basis for Partial Approval or Disapproval:
The district has implemented a corrective action for ensuring that parents receive two copies of the IEP once it has been proposed. The district did not provide a remedy for their failure to propose IEPs immediately following the Team meeting.
Department Order of Corrective Action:
Provide the district's procedure for sending parents proposed IEPs immediately. Please note that if the district provides a detailed summary to the parent at the conclusion of the Team meeting, which includes goal areas, accommodations, and a service delivery grid, the district has two weeks to propose the IEP. If the district does not provide a summary, the IEP must be proposed within 3-5 working days. Please see the Department's guidance on the immediate standard at
Required Elements of Progress Report(s):
Please submit a copy of the training agenda and sign-in sheet as evidence that training was provided to special education staff and secretaries regarding the regulation that the district must always provide the parent with two (2) copies of the proposed IEP and proposed placement along with the required notice.
In order to address the immediate standard of IEP provision, provide the district's procedure, an agenda and sign-in sheets for the appropriate staff by January 9, 2013.
Subsequent to the training, submit the results of an administrative review from a sample of student records from all levels (preschool, elementary, middle, high, out-of-district) for evidence that the district provides the parent with two (2) copies of the proposed IEP and proposed placement along with the required notice immediately following the development of the IEP. Indicate the number of records reviewed and the number found to be compliant. For all records not in compliance with this criterion, determine the root cause(s) of the noncompliance and provide the district's plan to remedy the noncompliance to ensure 100% compliance with this criterion by May 29, 2013.
The district must maintain the following documentation and make it available to the Department onsite upon request: a) List of student names, building names and grade levels of the records reviewed: b) the date of the review: c) Name(s) of the person(s) who conducted the review, their role(s) and their signature(s).
Progress Report Due Date(s):
01/09/2013
05/29/2013

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