Assessment/Accountability
Program Quality Assurance Services
Compliance and Monitoring

McAuley Nazareth Home for Boys Notification of Probationary Approval

August 18, 2005

Sr. Janet Ballentine
McAuley Nazareth Home for Boys
77 Mulberry Street
Leicester, MA 01524

VIA FACSIMILE and Certified U.S. Mail

Re: McAuley Nazareth Home for Boys
Notification of Probationary Approval

Dear Sr. Janet:

Following a Program Review conducted during the week of May 16, 2005 as well as a follow-up meeting held at the Department on June 29, 2005, the Department of Elementary and Secondary Education (the "Department") issued a letter of Pending Sanctions dated July 19, 2005. The issues summarized in this letter addressed serious concerns dealing with supervision, inconsistent implementation of policies and procedures, curriculum, staffing and staff training. During a follow-up site visit to the School yesterday to discuss progress made on addressing the various elements of the Corrective Action Plan, a serious situation involving an unsupervised student was observed. At approximately 11:30 a.m., student (___) was observed sleeping on the floor of the time-out room located in the main building. There were no staff supervising this student. As you know, the Department had brought a similar matter to the school's attention as a result of its recent oversight activities. Despite the assurance of the school that that matter of noncompliance would be effectively addressed, the inability of the school to genuinely acknowledge and correct persistent issues of supervision continue.

Based upon the information gathered through this review process and pursuant to 603 CMR 28.09(4), the Department has determined that McAuley Nazareth Home has compromised its ability to provide a safe, healthy and appropriate educational environment for its enrolled students. As a result, the Department is providing written notice of the probationary approval status of McAuley Nazareth Home. The circumstances that caused the Department to take such actions and the actions necessary to correct the problem are outlined below and must be addressed by September 15, 2005.

1. McAuley Nazareth Home is not in compliance with 603 CMR 28.09(7) and 603 CMR 18.03(1)(a). McAuley Nazareth Home does not provide appropriate supervision of students while they are engaged in any school related activity on or off school grounds. During the on-site visit yesterday, a student was observed lying on the floor, sleeping, in the time-out room, unsupervised. The Department considers this a serious incident that clearly threatens the health, safety and well being of students enrolled in the program. The student had no access to the curriculum or academics, constituting a removal from the classroom, which is an in-house suspension. When concern was expressed to Bill Cavanaugh, Program Director, he excused the situation and made no attempt to address this serious issue. He denied that the student was in an in-house suspension. He made no attempt to ensure Department staff that supervision of this student would be forthcoming. Kim Pare, Education Administrator, said she would stay with the student until a staff person returned, for coverage. In addition to the Department's concerns regarding lack of student supervision, we are equally concerned with the lack of action, lack of knowledge about an in-house suspension, and any type of acknowledgement of the severity of the situation f by McAuley Nazareth staff.

2. When the Department called you to discuss the situation, it appeared as if you did not understand the serious nature of this situation. You stated that staff have determined that there are some boys in your program who do not require supervision. We must reiterate the clear requirements of 603 CMR 18.03 (1)(a) that state "The School shall at all times provide appropriate supervision of students while they are engaged in any school related activity on or off school grounds."

Required Corrective Action and Documentation:

• A detailed explanation addressing the reasons for student ______'s presence in the time-out room, why he was sleeping and why he was left unsupervised.
• Supervision schedules for all administrators, professional and direct care staff including who is responsible for supervision and the dates and times staff are supervised.
• List of all current staff (Teaching Staff, Direct Care Supervisors and Direct Care Staff) specifying positions. Day Shift schedules for July and August. These schedules must include staff names, positions, and specific hours to be worked.
• The July and August logs of students removed from the classroom during the school day due to behavioral issues including student initials, times of return, and the reason for return.
• Written coverage plan for staff absences.
• A review of the following training topics for all staff must be completed by August 31, 2005. McAuley Nazareth Home must submit the training agenda, name and position of the person providing the training, and a sign-in sheet for staff present.
  • Behavior Management Policies and Procedures used by the Program, including suspensions.
  • Review of required student: staff ratios
  • Review of requirements for providing appropriate supervision to students while they are engaged in any school related activity on and off school grounds
• Administrative review and sign off by the Executive Director of all incident reports sent in to the Department.
• An administrative review of McAuley Nazareth Home's current Policies and Procedures dealing with Discipline and Behavior Management to ensure that such policy is appropriate to meet the needs of the population being served.
• Job descriptions for all administrative positions.
• Student admissions policies and procedures that include written admission criteria and a complete and thorough description of the admissions process.

As stated above, the Department has placed McAuley Nazareth Home on a Probationary Approval status based on serious concerns regarding the ability of the School to provide a safe, healthy and appropriate educational environment to enrolled students as outlined in 603 CMR 28.09(4)(a). Specifically, the Department is concerned with McAuley Nazareth Home's ability to appropriately supervise students at all times.

In consideration of the above referenced findings and consistent with Board of Education regulations [603 CMR 28.09(4)], within two (2) school days of receipt of notice from the Department placing the Program's approval on probation, McAuley Nazareth Home must provide notification to the parents of all Massachusetts enrolled students, all Massachusetts school districts with enrolled students, and officials of Massachusetts human service agencies or agencies of other states with responsibility of any students at the school. This notification must state that McAuley Nazareth Home has been assigned probationary status for the above stated reasons. A copy of this letter and a list of all recipients must be submitted to the Department for approval prior to distribution.

In addition, McAuley Nazareth Home must submit to the Department a Corrective Action Plan that fully describes the immediate steps the school will take to address the citation outlined. This Corrective Action Plan must include a detailed description outlining the steps to be taken, persons responsible for implementation, and specific timelines for correction of these problems. The Corrective Action Plan and required documentation must be received in the Department no later than 3:00 p.m. on Thursday September 15, 2005.

The Department is notifying McAuley Nazareth Home of its intent to prohibit acceptance of any additional eligible students if the Corrective Action Plan and required documentation is not found to be acceptable by the Department. Following the Department's review of the Corrective Action Plan or when the issue giving rise to the probationary status is resolved, whichever is sooner, the Department may reinstate the provisional approval status of the program or withdraw approval. The Department will provide written notification of its action to McAuley Nazareth Home.

Please note that the Department will conduct both announced and unannounced site visits to McAuley Nazareth Home to observe the current program and to verify any corrective actions approved by the Department. It is our desire to work positively and collaboratively with McAuley Nazareth Home to ensure compliance with Department requirements and to support the school in its efforts to meet the challenging needs of the students it serves. If you have any questions regarding the contents of this letter, please contact Betsy Holcombe at 781-338-3717.

Sincerely,

Betsy Holcombe
Liaison
Program Quality Assurance Services

Caryn N. Goldberg
Coordinator of Private School Approval
Program Quality Assurance Services

John D. Stager
Administrator
Program Quality Assurance Services