Delaware DEPARTMENT OF EDUCATION guar, puning, P40, rs Townsend Building s r eet of Fdveation 401 Federal Stet Suite 2 oe: (302) 735-4000 Department Dover, Delaware 19901-3639 Yorn hi DOE WEBSITE: hipvww doe kI2.de.08 (302) 739-4654 of Education MEMORAND! Date: November 26, 2019 TO: Richard Gregg, Superintendent Christina School District FROM: Mary Ann Mieczkowski Director, Exceptional esources Special Education Compliance Monitoring 2019-2020 Report and Instructions As you are aware, the Department of Education (“DOE”) is responsible for monitoring local education agencies (“LEAs”) for special education compliance. Your LEA was identified for monitoring in 2019-2020 due to identified issues at Glasgow High School. Enclosed with this memorandum is a Monitoring Report summarizing the DOE’s findings for your LEA. This ‘memorandum provides an overview of the local responsibilities for immediate corrective action. A team from the Exceptional Children Resources Group will meet with you and administrators from Glasgow High School on Thursday, December 5, 2019 at 9:00 am to discuss the findings, immediate corrective actions and requirements of a Compliance Agreement between Christina School District and the DOE. DOE's Monitoring Activities In the Office of Special Education Programs (“OSEP”) 09-02 memo, Federal DOE outlined requirements for states to conduct monitoring of special education records in two phases which DOE refers to as “Prong 1” and “Prong 2.” DOE monitors use a protocol to review student files in multiple regulatory areas, including igibility determination, individualized education program (“IEP”) development, least restrictive environment (“LRE”), secondary transition, and IEP meeting participants. ‘The Monitoring Report describes any findings of noncompliance based on the protocol at both the LEA and student levels. ‘The findings trigger different levels of required corrective action. If, for ‘example, noncompliance is found at the individual student level, the LEA must correct the student records as soon as possible. “1 DIAWARE DEFARTMENT OF EDUCATION 1 AN EQUAL OPPORTUNITY EMPLOYER 1 BOES NOT BISCRIINATE OV THE BASIS OF RACE, COLOR, RELIGION, NATIONAL ORI, SEX SEXUALChristina School District Education Compliance Monitoring 2019-2020 Additional corrective actions will also be required, such as staff training, due to the total entage of compliance for a particular regulatory item. A. Corrective Action Plan ‘The DOE requires LEA Level Corrective Action for any area that is below 90% compliant, The percentage levels for your LEA are found in the On-site Monitoring Corrective Action Plan document. Before starting any corrective actions, however, the LEA must conduct a Root Cause Analysis to identify the specific reasons the problem exists within the LEA. Depending on the reasons identified, the LEA should then tailor specific action steps to remedy the problem. Corrective actions can include, but are not limited to, self-audits and LEA review of student records, review of compliance data by teacher/school, specific trainings for targeted staff, and review of policies and practices at the LEA and school levels. Your staff should discuss plans and technical assistance options with the DOE team assigned to your LEA. ‘The LEA’s signed Corrective Action Plan will be due to DOE on or before December 31, 2019. Note that the DOE is requiring each LEA to provide training to staff in the areas in which compliance is below 90%. The training should be specifically developed by each LEA to ensure staff will properly implement the regulations. “Training” can include: (a) presentations to staff by an expert or consultant in special education regulations; (2) distribution of written materials to staff; and/or (3) use of technical assistance documents and professional development modules sanctioned and approved by the U.S. Department of Education. ‘The DOE team will monitor completion of the Corrective Action Plan developed by the LEA. We request LEAs complete corrective action plans no later than June 15, 2020 and submit supporting documentation. B. Individual Student Corrections (Prong 1) As mentioned, all noncompliance must be corrected at the individual student level, and is described in Section 3 of the Monitoring Report. The LEA is responsible for submitting Section 3 of the Monitoring Report documenting completion of all individual student corrections to the DOE no later than April 15,2020. The DOE will review the individual student records to verify completion of required corrections. Note that the correction of IEPs is not required if: (a) the student is no longer enrolled in the LEA; (b) the student was dismissed from receiving special education services; or (c) the student no longer attends school due to graduation or other reasons. ‘The Monitoring Report contains a section for your LEA to report when these circumstances occur.Christina School District, Special Education Compliance Monitoring 2019-2020 Page 3 C. Systemic Compliance (Prong 2) To verify regulatory areas found noncompliant in Prong 1 are now compliant across the system, DOE will review randomly selected student files for IEP meetings held after June 15, 2020. This will allow time for professional development or technical assistance to staff for areas found to be noncompliant. The number of additional records reviewed will depend upon the percentage level of compliance at the LEA and other factors. Summary In closing, we are scheduled to meet with you on Thursday, December 5, 2019 at 9:00 am, We hope that this memorandum is helpful to you. As always, we appreciate the cooperation displayed by your staff throughout the monitoring process. Following is a review of the timeline for actions due to the DOE: 1. Completed and signed LEA Level Corrective Action Plan | December 31, 2019 due to DOE. 2. Individual student corrections completed | April 15, 2020 3, Completion of all corrective actions June 15, 2020 As your LEA works through its corrective action steps, please be sure to direct your questions and comments to Pam Bauman, your liaison or myself, Mary Ann Mieczkowski, Director of Exceptional Children Resources. Thank you and we look forward to working with you throughout the year. MAMUS:jp ce: Susan S, Bunting, Ed.D, Seeretary of Education Monica Gant, Ph.D., Associate Secretary ‘Norven Lasorsa, Assistant Superintendent Harold Ingram, Principal, Glasgow High School Christine Getugi, Assistant Principal, Glasgow High School Dale Matusevieh, Education Associate, Exceptional Children Resources Pam Bauman, Education Associate, Exceptional Children Resources