Private School Coordinated Program Review System
As one part of its Accountability System, the Department of Elementary and Secondary Education oversees compliance with education requirements in private day and residential special education programs through the Massachusetts Private Special Education School Program Review System. This program oversight system addresses selected monitoring requirements of 603 CMR 28.09, "Approval of Public and Private Day and Residential Special Education School Programs," and 603 CMR 18.00, "Program and Safety Standards for Approved Public or Private Day and Residential Special Education School Programs." The Program Review System additionally encompasses selected requirements contained in 603 CMR 28.00, "Massachusetts Special Education Regulations," as well as IDEA-2004, M.G.L. c. 71B and civil rights provisions that are pertinent to Approved Private School Programs.
The Department's 2012-2013 approved private school program schedule of Program and Mid-cycle Reviews is posted on the Department's website at Approved Special Education Private School Program Review Six-Year Monitoring Cycle webpage.
Web-based Approach to Monitoring
The Department piloted a new web-based approach to comprehensive monitoring in the 2010-2011 school year. Currently, every Program Review and Mid-cycle Review is conducted using this approach. The web-based monitoring system (WBMS) allows both programs and the Department to submit, review and exchange documents and information through the Department's security portal. This new approach combines familiar elements from the standard Program Review and Mid-cycle Review procedures in combination with new features that strengthen accountability and oversight on a continuous basis.
The program review criteria selected for each WBMS Program Review begins with the agency conducting a self-assessment by private school programs across all monitoring criteria. For Mid-cycle Reviews a subset of the monitoring criteria are self-assessed by private school programs, along with any criteria that resulted in a prior finding of noncompliance and any new monitoring criteria. Office of Approved Special Education Schools (OASES), through its desk review procedures, then examines the self-assessment submissions and determines which criteria will be followed up on through onsite verification activities.
Depending upon the scope of onsite activities that have been identified based on the Department's desk review of the agency's self-assessment, a 2-3 member Department team will conduct a 2-3 day onsite Program Review. Mid-cycle Review teams consist of 1-2 members and the onsite is 1-2 days.
Self-Assessment Phase: This is a requirement for all agencies participating in the web-based monitoring system and is completed in the year prior to the onsite review.
Agency review by private school program of documentation for required elements including document uploads.
Agency review by private school program of a sample of student records selected and a sample of staff records selected.
Upon completion of these portions of the self-assessment, it is submitted to the Department for review.
Desk Review Phase:
The chairperson assigned to each agency reviews the responses by the private school program to questions regarding the critical elements for appropriate policies, procedures, and practices, as well as actual documents and data submissions by criteria. The student record review data, staff record review data, and explanatory comments are examined. The outcome of this review, along with 3-year trend data from the Problem Resolution System, and required notifications to the Department, is used to determine the scope and nature of the Department's onsite activities.
Onsite Verification Phase:
This includes activities selected from the following:
Interviews of administrative, instructional, and other staff consistent with those criteria selected for onsite verification.
Interviews of parent representatives and other telephone interviews as requested by other parents or members of the general public.
Review of student records and staff records: The Department selects a sample of student and staff records from those the agency reviewed by the private school program as part of its self-assessment to verify the accuracy of the data. The Department also conducts an independent review of a sample of student and staff records that reflect activities conducted since the beginning of the school year. The onsite team will conduct this review, using standard Department procedures, to determine whether procedural and programmatic requirements have been implemented.
Surveys of parents of students with disabilities: Parents of students with disabilities whose files are selected for the record review, as well as the parents of an equal number of other students with disabilities, are sent a survey that solicits information regarding their experiences with the agency's implementation of special education, related services, and procedural requirements.
Observation of classrooms and other facilities: The onsite team visits a sample of classrooms and other school facilities used in the delivery of programs and services to determine general levels of compliance with program requirements.
The report will be based on a review of the written documentation regarding the operation of the school's programs and the information gathered from the Onsite Verification Phase. A Draft Report of Comments will be issued via the WBMS. Agencies may respond to the factual accuracy of the report within 10 business days.
A Final Report will then be issued via the WBMS and in hard copy. Detailed findings for each program area describe determinations of the Department about the implementation status of each requirement (criterion) reviewed. The Department's Approved Private School Program Review Final Reports are posted on the Department's website at Private School Program Review Reports webpage and the Mid-cycle Review Reports are posted at Recently Published Mid-cycle Private School Program Review Follow-up Monitoring Reports webpage.
Response to Program Review Final Report findings:
Where criteria are found not to be fully implemented, the private school program is required to propose corrective actions, within 20 business days of receipt of the final report, to bring those areas into compliance with the respective statutes or regulations. A program is required to incorporate the required corrective activities into its updated Application for Approval as required by 603 C.M.R. Section 28.09. Additionally, a program is encouraged to incorporate any required corrective action as approved by the Department into its internal improvement plans, including the program's professional development plans. In Mid-cycle Reviews after the Mid-cycle review Report is issued the program enters progress report information directly into the WBMS for any criteria found not to be fully implemented and for this reason no corrective action plan is created.
Upon issuance of the Final Report, the program will receive an updated approval status. For programs receiving a "Full Approval," this approval will remain in effect for three (3) years expiring on August 31st of the third year of approval. This approval 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," as well as the Department's approval of all required corrective action plans. The Department may change this approval status at any point during the three-year period if circumstances arise that warrant such a change. For Approved Private School Programs receiving a "Provisional Approval" or "Probationary Approval," the Department will clearly indicate the reasons for the reduced approval, along with timelines for compliance and an expiration date of the approval status. The Department will review all required Corrective Action Plans and issue written determinations regarding approval or disapproval of each corrective action plan activity.
Note: For programs undergoing Program Reconstruction, Special Circumstances or Extraordinary Relief, even if the program has substantially met all of the requirements for a Full Approval, the program will remain on Provisional Approval until the completion of the Program Reconstruction, Special Circumstances or Extraordinary Relief process.