TEA report on Irving ISD

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Irving Independent School District 057-912,2013-2014 Texas Education Agency Division of Program Monitoring and Interventions Preliminary On-site Report of Findings Section I: Overview: Overall History & Background The Irving Independent School District (ISO) was identified for an on-site review due to the identification of substantial, imminent, or ongoing risks across programs monitored by the Performance-Based Monitoring Analysis System (PBMAS), as reflected in current and/or longitudinal data. For 2013-2014, Irving ISO was staged for interventions at stage 4 in special education; stage 3 in bilingual education/English as a second language (BE/ESL); stage 2 in No Child Left Behind (NCLB); and stage 2 in data validation monitoring (DVM) - discipline. The major concerns identified by the 2013 PBMAS report included: performance of students in the BE/ESL program; performance of students with disabilities; performance of migrant students; Title I, Part A diploma rate; and special education placements in instructional settings 40/41. In the 2013 state accountability rating system, Irving ISD and 28 campuses Met Standards but failed to meet state standards for one or more system safeguards. Additionally, Nimitz High School (HS), Keyes Elementary (EL), Schulze EL, Pierce Early Childhood Center, Wheeler Transitional and Development Center, and Wheeler Transitional and Development Secondary Center were rated 1 st Year Improvement Required (IP). Report Topics in Section II: Findings Systemic Integrated Issues Affecting Student Performance > Administrative Leadership and Organization > Curncu urn and nstruction > Special Education Student Performance > Least Restrictive Environment Special Education Representation > Special Education Non-Comphance Bilingual Education/English as a Second Language - Student Performance > Bilingual Education/English as a Second Language - Non-Comphance

description

The Texas Education Agency released this report in October 2014, after auditing Irving ISD the previous spring.

Transcript of TEA report on Irving ISD

Page 1: TEA report on Irving ISD

Irving Independent School District057-912,2013-2014

Texas Education AgencyDivision of Program Monitoring and Interventions

Preliminary On-site Report of Findings

Section I: Overview: Overall History & Background

The Irving Independent School District (ISO) was identified for an on-site review due to the identification ofsubstantial, imminent, or ongoing risks across programs monitored by the Performance-Based MonitoringAnalysis System (PBMAS), as reflected in current and/or longitudinal data. For 2013-2014, Irving ISO was stagedfor interventions at stage 4 in special education; stage 3 in bilingual education/English as a second language(BE/ESL); stage 2 in No Child Left Behind (NCLB); and stage 2 in data validation monitoring (DVM) - discipline.The major concerns identified by the 2013 PBMAS report included:

• performance of students in the BE/ESL program;• performance of students with disabilities;• performance of migrant students;• Title I, Part A diploma rate; and• special education placements in instructional settings 40/41.

In the 2013 state accountability rating system, Irving ISD and 28 campuses Met Standards but failed to meetstate standards for one or more system safeguards. Additionally, Nimitz High School (HS), Keyes Elementary(EL), Schulze EL, Pierce Early Childhood Center, Wheeler Transitional and Development Center, and WheelerTransitional and Development Secondary Center were rated 1st Year Improvement Required (IP).

Report Topics in Section II: Findings

Systemic Integrated Issues Affecting Student Performance

> Administrative Leadership and Organization

> Curncu urn and nstruction

> Special Education Student Performance

> Least Restrictive Environment

Special Education Representation

> Special Education Non-Comphance

Bilingual Education/English as a Second Language - Student Performance

> Bilingual Education/English as a Second Language - Non-Comphance

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Irving Independent School District057-912,2013-2014

Single Program Areas

Migrant Program

Support for Improvement Required Campuses

Data Validation Monitoring - Discipline

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Section II: Findings

Systemic Integrated Issues Affecting Student Performance

> Administrative Leadership and Organization

At the time of the on-site visit, the superintendent was in his third month as superintendent in the district. Theagency team learned that the superintendent's leadership team was not in place, and he was still evaluatingcurrent staff and looking to fill vacancies. The loca! education agency's (LEA's) school board's expectations forthe superintendent were for his team to be in place within the year.

During interviews with the superintendent, the team learned that there were 27 departments housed at centraloffice. The superintendent shared that his challenge was to know who the central office administrators were andto determine if they had the same focus for student success and achievement. The superintendent held monthlymeetings with the central office staff to develop the district focus. His work with the staff included developing aplan to link central office support to campuses while still holding the campus and campus leadershipaccountable.

Through the superintendent's interview, the agency team learned that the first layer of support for the IRcampuses began with the elementary and secondary division directors. The expectations were for the divisiondirectors to be on the campuses daily walking with principals, providing instructional and non-instructionalsupport, and overseeing the content coordinators work and support on the campuses. The AssistantSuperintendent for Teaching and Learning conducted data walks to identify good instruction and pacing of thecurriculum in the classrooms. Also, the superintendent visited campuses weekly to see classrooms and theprincipals, with more frequent visits to the IR campuses. Campus principals had a direct line of communication tothe superintendent and central office for support.

Additionally, the superintendent identified for the team some of his findings found during his first 90 days assuperintendent:

» District systems were not able to keep up with the district's growth;* There was a lack of an appropriate district focus on individual student growth and psycho-social needs;» Campuses added programs and staff to resolve problems without sustainability;* Central office needed to ask the right questions of campus leadership;* There was a lack of daily campus visits, which are important to program evaluation;* There was a silo approach to support from central office to the campus level;* The curriculum was changing yearly for the last three years; and* The research and development team had data housed in Eduphoria but it was not used to drive

instruction.

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Systemic Integrated Issues Affecting Student Performance

The agency team interviewed central office staff and learned that in recent years there had been a divisionamong the staff at central office. The focus was more on the adults and not on the students. There was a lack ofcommunication and collaboration between campuses and central office, resulting in a lack of instructionalconsistency. It was reported to the team that there were a number of turnovers in central office staff with severalvacancies still unfilled at the time of the on-site visit. The team determined that the previous central officedivision, lack of central office campus support, inconsistent communication, and lack of collaborative decisionmaking were causal factors contributing to low student performance. During the on-site visit, it was evident to theteam that the superintendent was working to build relationships, his leadership team, and create systems forcentral office support for campuses.

Recommendations and Required Actions:

1. Establish a climate of trust and collaborative leadership that shares common goals and workstogether to achieve the goals. Establish systems and processes for program directors and their staffto collaborate with one another and campus principals to address needs of students identified acrossprogram areas.

2. Continue to build the capacity of the central office staff to support campuses. Develop processes andsystems to communicate efficiently and effectively from central office to the campus level. Implementa monitoring system to routinely evaluate the effectiveness of developed processes.

> Curriculum and Instruction

Through central office staff, campus leadership, and teacher interviews, the agency team learned that the LEAhad implemented several curriculum systems in the past. At the time of the on-site visit, the district hadcontracted with the former district director of teaching and learning as an outside consultant to assist classroomteachers and curriculum specialists in the development and writing of the curriculum. The team learned thatthere was an inconsistency in the selection of teachers used in the writing of the curriculum. While someteachers on campuses identified as IR were losing instructional time when being pulled from classrooms eachsix weeks, other teachers with similar expertise on campuses identified as Met Standard were not being utilized.The team determined the practice of pulling teachers from the IR campuses, where there was the greatest needfor quality time and instruction, was a causal factor contributing to low student performance.

The team learned that the curriculum the district was writing was standards-based. This was the first year ofimplementation of the district's developed curriculum. It was a resource of scope and sequence, activities, andaccommodations for ELLs and students with disabilities. At the time of the visit, the curriculum was deployedprior to each unit with lesson plans designed to build on the foundation and assessments to be developed in thefollowing year. Teachers were able to access the curriculum through Engrade, a district data source, campusprofessional learning communities (PLC), department meetings, and trainings conducted by district coordinators.

District support for the curriculum varied among the campuses. The team learned some campuses receivedsupport from the content, ESL, and special education coordinators through training and walk-throughs. On othercampuses, principals shared that they had a difficult time getting the coordinators to visit their campuses. Centraloffice elementary and secondary division directors visited campuses to work with principals, and the assistantsuperintendent for teaching and learning conducted data walks observing best practices. In addition, centraloffice staff conducted peer learning data walks with teachers to observe good instruction and calibration walk-throughs to ensure appropriate instructional pacing.

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Section II: Findings

Systemic Integrated Issues Affecting Student Performance

Through the curriculum writing process, the special education department had developed a vertical andhorizontal alignment for special education modified curriculum for resource classes. To assist teachers withunderstanding the district written curriculum, including the scope and sequence, the special educationdepartment had added two special education instructional coaches in the area of math and English/languagearts. Special education instructional coaches provided training to assist special education teachers andadministrators in understanding the Texas Essential Knowledge and Skills (TEKS) curriculum and scope andsequence. Additionally, the team learned that teacher and administrator turnover in the district had impacted theimplementation of the curriculum with fidelity. District staff shared with the team that teachers and administratorsemployed by the district received their training and experience with the district and then ieft for otheropportunities in the surrounding communities.

The team learned through central office staff interviews that the district used a Unit Comparison Chart to aligncurriculums from the special education resource classes with the general education programs. The chart wasused to help ensure that students with disabilities in the resource setting were receiving instruction on the samegrade level TEKS as students in the general education setting. Since the comparison chart was early in its initialimplementation, data was not available to measure the effectiveness of this resource.

Campus-level support for the curriculum varied from the academic leads that are the department chairs at thehigh schools to academic specialists at the middle and elementary schools. Through a directive from centraloffice, department chairs taught half the day and provided instructional support to their campus the other half ofthe day. No additional funding to support this position was provided, and the high school campuses had toabsorb the teaching assignment into other content area classes. The academic specialist position, which did nothave any classes, served as a new teacher mentor, modeled lessons, co-taught with teachers, assisted in theimplementation of the curriculum, and assisted in the administration of assessments.

During the district leadership team (DLT) meeting, the agency team learned that vertical and horizontalalignment across the curriculum, alignment of the curriculum with STAAR objectives, and a completedcurriculum map were areas of concern impacting teacher instruction. The DLT felt confident teachers wereempowered to make data-driven decisions regarding instruction in the classroom and faithful implementation ofthe improvement plan was ensured by campus administration. The DLT also believed, while teachers were moreaware of students' needs, true collaboration across program areas and campuses was imperative andacknowledged the district was working toward this goal.

The agency team determined that the implementation of several curriculum approaches the last several yearswith inconsistent support from central office was a causal factor contributing to low student performance. Theteam recognized that new systems and support were being implemented through collaboration across programareas as central office staff continued to work to meet the needs of the campuses.

Recommendations and Required Actions:

3. Evaluate the selection process of teachers being utilized to assist in writing the curriculum to take intoconsideration the need of the campus and loss of core content instructional time for students with thegreatest need.

4. Identify needs and provide targeted professional development to offer the knowledge and skillsteachers need for using the district-developed curriculum. Implement systems for monitoring theimplementation of the training and the curriculum.

5. Evaluate support of the curriculum to ensure consistent central office support to the campus level.Implement systems to monitor the implementation of the support.

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Section !!: Findings

Systemic Integrated Issues Affecting Student Performance

6. Implement a system for vertical planning, communication, and collaboration across campuses andprogram areas.

Special Education Student Performance

2013 PBMAS data on state assessments for students with disabilities indicated performance concerns on theSTAAR 3-8 and end-of-course (EOC) exams. The agency team learned through interviews with the specialeducation director that a causal factor contributing to poor student performance on state assessments was a lackof rigor in developing a targeted accelerated learning/intensive program of instruction for students who were notsuccessful on a STAAR administration.

The LEA used the case manager model for providing support for students with disabilities. The team learnedthrough staff interviews that the special education teacher was assigned students to monitor. The teacher wasresponsible for all relevant paper work for the student, contacting parents, and ensuring the schedule of serviceswas accurate.

The district has experienced an increase in the number of students with disabilities taking the STAAR Alternativestate assessment, interviews with the special education director revealed to the team that students with anintellectual disability had remained steady; however, the district had seen an increase in the number of studentswith autism. The special education director stated that with the use of the state assessment criteria document,the district was monitoring their assessment determinations to ensure the correct assessment was provided foreach student.

Recommendations and Required Actions:

7. Evaluate the intensive programs of instruction for students with disabilities to determine if theprograms are meeting the needs of students who have not been successful on state assessments.

8. Evaluate the results of monitoring assessment determinations and provide training for staff in the useof the state assessment criteria document, including changes for the 2014-2015 school year.

Least Restrictive Environment

The agency team learned through central office staff interviews that the LEA offered inclusion, resource, andself-contained settings to provide academic support for students with disabilities. Staff interviews, documentreviews, and campus visits revealed to the agency team that the LEA addressed the least restrictiveenvironment for students with disabilities through the use of the co-teach model in the inclusion setting. Newteachers to Irving ISO received mandatory three-hour co-teach training while teachers who were returning to thedistrict received one-hour co-teach refresher training each year. The special education department haddeveloped a walk-through document to be used with the professional development appraisal system (PDAS) tomonitor the co-teaching model. The data collected from the walk-throughs indicated that 10% support strategiesfor English language learners (ELL) and special education students were being observed. The special educationdirector reported that the data indicated the special education teacher was being used more in a support rolethan a true co-teach model. The team, through interviews with principals, general and special educationteachers, and classroom observations, supports the LEA's findings.

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Section II: Findings

Systemic integrated Issues Affecting Student Performance

Additionally, the LEA offered a more restrictive setting at the Wheeler Transitional and Development Center(WTDC). The WTDC is a separate campus for students with disabilities with challenging behaviors. The centerprovides support from temporary interventions to teaching the student more appropriate school behavior andbetter ways of coping, as well as continuing the academic program outlined in the students' individual educationprogram (IEP). The LEA was in the process of transitioning the Wheeler Center from a campus or a placementfacility to a program for students with disabilities as the result of an outside review of the Transition Center inMarch 2013. Key findings from the review were:

• There had been an increase in the number of part-time students at WTDC;• Most of the students had emotional problems or were on the autism spectrum; however, students with

other disabilities were in attendance;• The longer a student was enrolled at WTDC, the less likely the student was to be dismissed;• Long-term placements resulted in student and parent resistance to returning to the home campus;• A multidisciplinary team considered entry and exit to WTDC with clear and appropriate pre-placement

steps specified for campuses to complete for placement consideration;• Lead principals attended entry and exit admission, review, and dismissal (ARD) committee meetings; and• Occasionally the administrator requested the exiting student be returned to another campus rather than

their assigned campus,

The review recommended the following actions:

• Eliminate the practice of placing students for a short time after the development of the behaviorintervention plan (BIP);

• Eliminate full-time and long-term placements for students;• Change the focus of the interventions from maintaining and remediating academic deficits to a targeted,

intense effort to change the behavior and attitudes of the students;• Consider eliminating the practice of placing 10th through 12th grade students; and• Use project-based learning as the academic context for behavior training.

Through interviews, document reviews, and classroom observations the team learned that not all of therecommendations had been implemented. The team discovered a second administrator had been added to thecampus to strengthen the academic component. The team concluded academics were not being fullyemphasized and teachers could not speak to professional development training they received for best practicesor where the students were academically. The team did find the teachers were very well versed on the strategiesthey were implementing in their classrooms to assist students with behaviors and attitudes.

The agency team was able to observe the implementation of several of the review recommendations including atiered system associated with the response to interventions (Rtl) for behaviors, the continuum of services forstudents with challenging behaviors, and the establishment of the distinct role of WTDC in context of theredesign continuum.

While on-site, district personnel shared with the agency team that there were plans to transition WTDC from acampus to a program of support.

Recommendations and Required Actions:

9. Analyze the current continuum of services at all campuses for effectiveness and develop an actionplan to address the areas of need.

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Section II: Findings

Systemic Integrated Issues Affecting Student Performance

10. Develop a plan for WTDC's transition from a campus to a program of support that includes howstudents with disabilities' academic needs and requirements will be met.

11. Evaluate the effectiveness of the transition of the Wheeler Center from a campus to a program ofsupport for students with disabilities and develop a plan to address the deficiencies.

> Special Education Representation

A review of the 2013 PBMAS data indicated a disproportionate number of African-American students wererepresented in special education. The agency team learned through interviews with the special educationdirector that the LEA was monitoring this indicator and the data had been shared with the diagnosticians. Theteam determined through staff interviews and campus visits that the implementation of the Rtl process variedfrom campus to campus. The Rtl for behavior was the focus for the district in the 2013-2014 school year witheach campus professional learning committee (PLC) meeting 5-6 times a year with a special education teacherpresent to facilitate behavior interventions.

The agency team learned that the LEA had implemented the use of the initial referral log to ensure they met therequirements of the new state timelines which was monitored through the special education director's office.Further, the team learned through interviews with centra! office staff, administrators, and teachers for studentsidentified as ELLs and special education that there was documented collaboration in ARD committee meetings.Through the use of an ARD agenda, principals were provided prompting questions for discussions regardingeducational and behavioral planning for students with disabilities who were also ELLs.

Recommendations and Required Actions:

12. Evaluate the LEA's behavioral Rtl process, including identification, interventions and supports, andspecial education referrals for effectiveness; revise the process as needed, to include staff training,implementation, and monitoring.

13. Review referrals of African-American students to special education. Identify the reasons studentswere referred and the interventions and supports that were provided to them prior to referral. Providetraining in areas of need and monitor implementation.

> Special Education Non-Compliance

Specifically, for students receiving services in a special education class, the LEA was not documenting thefrequency and duration of that service. Additionally, for students receiving inclusion support, the specialeducation service was listed as an accommodation and was not clearly specified as a special education service.The lack of specificity in the frequency, duration, and location of inclusion and related services is aviolation of 34 Code of Federal Regulations (CFR) §300.320 (a) (7).

Recommendations and Required Actions:

14. Revise policies, procedures, and operating guidelines to ensure the services, including frequency andduration, provided to students with disabilities are documented according to federal guidelines.

15. Train staff on the policies, procedures, and operating guidelines to ensure appropriate documentationof service frequency and duration as determined by the IEP.

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Section II: Findings

Systemic Integrated Issues Affecting Student Performance

16. Convene ARD committees or conduct ARD amendments for students to document frequency,duration, and location of special services.

17. Develop a monitoring system that includes regular folder reviews to verify that students withdisabilities are receiving their services as determined by the student's IEP,

Additionally, through staff interviews and the review of student folders and class schedules, the agency teamlearned that for some students, their IEP indicated instruction in core academic subjects by a special educationteacher. The team discovered some teachers were not highly qualified in the core academic subject they wereteaching. The failure to provide special education teachers who are highly qualified in their area ofassignment is a violation of 34 CFR §300.18(d).

Recommendations and Required Actions:

18. Evaluate certifications or highly qualified status of special education teachers who teach academiccore subject areas to determine if each is highly qualified in the area of their area of assignment.

19. Develop a system to ensure that students with disabilities are provided services specified in theirlEPs by certified and, when appropriate, highly qualified staff.

20. Convene ARD committee meetings for students instructed by special education teachers who werenot highly qualified in the area of their assignment to determine if students were denied a freeappropriate public education (FARE) and to consider compensatory services, if appropriate. Track theprovision of compensatory services.

Bilingual Education/English as a Second Language Student Performance

The agency team learned through central office staff interviews that the BE/ESL program was implementingseveral program models to provide instruction for ELLs. There were 15 elementary campuses using the late exitmodel, 4 elementary campuses using the dual two-way model, and one elementary campus using the one-waydual language model. The middle schools and high schools were content-based programs using the shelteredinstruction model to serve their ELLs. The staff shared with the team that campuses had changed their model ofinstruction frequently in the past with little support from central office. In addition, the district was implementingdifferent curriculums each of the last two years. To compensate for this, the LEA established a BE task force toreview research-based programs to determine which model would best meet the district's needs. The districtwas considering transitioning to a 50/50 program model with central office support.

2013 PBMAS data on state assessment for BE/ESL students indicated performance concerns on the STAAR 3-8and EOC exams. The world language director was in her first full year in the district. She inherited a program inwhich students' scores were regressing and there was a lack of written guidelines and procedures fordepartmental processes. PBMAS longitudinal data reflected the LEA was a stage 3 in BE/ESL in 2013, whereinthe previous three years, the LEA was not staged. The team learned through central office staff interviews that inan effort to address the academic low performance of ELL students, the world language department

• developed guidelines and procedures;» provided campuses with targeted supplemental support;• began to have conversations with students about expectations;• conducted round table meetings with parents in the fall and spring;• conducted campus walk-throughs with the director and her staff;• presented student case studies to campus PLCs; and• provided after-school support through Journey, a career path program.

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Section II: Findings

Systemic Integrated Issues Affecting Student Performance

in addition, instructional support for teachers was led by ESL teachers and academic specialists. The agencyteam determined that the inconsistent implementation of a BE/ESL program model and a lack of district focus onthe BE/ESL program were causal factors contributing to low student performance.

The LEA had requested an exception and a waiver during the last two years for their BE/ESL program. Throughstaff interviews, the team learned that the LEA had provided English Language Proficiency System (ELPS) anddifferentiated and sheltered instruction training for teachers in an effort to remove the waivers and build staffcapacity.

Through staff interviews, the agency team learned that the LEA transitioned their ELLs between campuses bysending a representative from the receiving campus to the LPAC of the sending campus. Grades andinterventions were exchanged and in some instances, the BE teachers looped with their students to the nextcampus to minimize regression during transition.

Recommendations and Required Actions:

21, Determine the BE/ESL program model the district will implement for instructional support for ELLstudents.

22, Determine, provide, and document the necessary training to implement the new BE/ESL programmodel.

23, Develop and implement a system to monitor and provide feedback to campuses regarding theprogram model implementation.

> Bilingual Education/English as a Second Language Non-Compliance

Through student folder reviews, the agency team found that the language proficiency assessment committee(LPAC) records were incomplete. Documents such as the parent consent for entry into the BE/ESL program ordenial of services were missing for some students. Failure to provide in the student's permanent recorddocumentation of all actions impacting the English Language Learner is a violation of 19 TAG §89.1220(I).

The director of world language showed the agency team newly developed guidelines and procedures for theidentification of ELLs and program placement. The team acknowledges that the LEA was conducting a completeaudit of the BE/ESL records, correcting any documentation noncompliance, and reviewing ELL identificationprocesses.

In addition, the LEA last conducted an annual BE/ESL program evaluation in 2010. Upon arrival of the new worldlanguage director in the spring of 2013, a program evaluation had been completed and presented to the schooldistrict board of trustees.

Recommendations and Required Actions:

24. Revise policies, procedures, and operating guidelines to ensure that the LPAC is retainingappropriate documentation of its actions in accordance with state guidelines. Create a monitoringsystem to verify implementation and provide feedback to campuses.

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Section II: Findings

Systemic Integrated issues Affecting Student Performance

25. Ensure the implementation of the newly developed guidelines and procedures for identifying andplacing ELLs into the appropriate program of instruction.

26. Provide and document training for the staff on the procedures and guidelines developed, includingtraining for all LPAC committee members on their role and responsibilities. Develop a system tomonitor the implementation of LEA procedures and guidelines and to provide feedback to campusesregarding the implementation.

Section II: Findings

Single Program Areas

> Migrant Program

The migrant education program (MEP) is designed to assist migrant students in overcoming the challenges oflanguage, mobility, and other barriers associated with a migratory lifestyle. The agency team learned throughstaff interviews that migrant students must complete a yearly enrollment packet containing a family survey andspecific questions to assist the migrant program staff in determining eligibility. A local migrant recruiter conductsface-to-face interviews with parents to also determine eligibility for the MEP.

Through staff interviews, the team discovered that during the 2012-2013 school year, approximately 100migrant students attended Irving ISO schools, and the number of migrant students had declined to 50. The lossof student enrollment resulted in a nearly 50 percent reduction of federal district funding to support the MEP,and the loss of funding resulted in the loss of several staff positions throughout the district.

Based upon 2013 PBMAS data, the performance of migrant students on the STAAR grades 3-8 and EOC stateassessments fell below PBMAS standards. District staff reported to the team that the in-school migrant studenttutorial program was cut due to the loss of funding. The staff also shared that migrant students performed betteron state assessments during the 2011-2012 school year due to the in-school tutorial program focusing on theindividual needs of migrant students. At the time of the on-site visit, migrant students were offered the sameopportunities as all students to attend after-school tutorials. It was reported to the team that most migrantstudents did not attend the after-school tutorials because of job responsibilities or having to take care of youngersiblings. In addition, student performance logs were maintained and used to monitor the monthly academicprogress of migrant students in previous years. Conferences were held with students failing to make academicprogress and parents were contacted. In 2013-2014 with the loss of funding and staff, student performance logsfor migrant students were only maintained during the second semester.

The agency team learned through staff interviews that the LEA had not developed district policies andprocedures for the operation of the migrant program. However, the new state and federal compliancecoordinator had begun developing policies and procedures for the consistent and supportive implementation ofthe MEP.

Recommendations and Required Actions:

27. Review the current practice of after-school tutorials and the impact it has on migrant students.Develop a plan to provide support meeting the individual needs of migrant students.

28. Develop district policies and procedures for the migrant program, provide training for the staff, andimplement a process for monitoring the program's effectiveness.

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Section II: Findings

Single Program Areas

Support for improvement Required Campuses

In the 2013 state accountability rating system, Nimitz HS, Keyes Elementary EL, Schulze EL, Pierce EarlyChildhood Center, Wheeler Transitional and Development Center, and Wheeler Transitional and DevelopmentSecondary Center were rated 1st Year IR. While on-site, the agency team visited all seven IR campuses,conducted teacher interviews, facilitated an IR principal meeting, and met with the campus intervention team(CIT) and learned that the district had not made the IR campuses a priority. No additional funds, instructionalsupplies, materials, nor staff were provided. IR campuses were expected to use existing campus fundsbudgeted for the 2013-2014 school year for additional support. For the IR campuses, staff vacancies were aconcern. One campus reported they were able to complete their staff in late August, prior to the start of school.Furthermore, with enrollment projections changing slightly for 2014-2015, the current human resource plancalled for cutting four to five core content teachers from a campus already struggling academically and rated IR.The team concluded that the district lacked a full understanding of the needs and resources needed forprioritizing and providing support for a campus rated IR.

Recommendations and Required Actions:

29. Develop and implement a plan to prioritize, support, staff, and fund resources needed to assist IRcampuses to improve student performance.

Section II: Findings

Data Validation Monitoring - Discipline

Although the LEA documented an extensive administrative training for student discipline coding prior to andduring the 2012-2013 school year, agency team interviews with administration and a review of 2012-2013student discipline documentation revealed that written procedures were inadequate to ensure accurate studentdiscipline coding.

The agency team reviewed student files related to the following 2012-2013 student discipline data validationindicators;

• #1: Length Of Out-Of-School Suspension;• #2: Length Of In-School Suspension; and• #7 African-American Discretionary DAEP Placements.

Data reviewed for the school year 2012-2013 was submitted as a part of the PEIMS Summer Submission 2013.Of the files reviewed, two were coded correctly based on documentation maintained by the district, and twowere not coded appropriately based on a lack of documentation.

Additionally, the team reviewed folders for 2013-2014 with the LEA staff that were in electronic format, for whichthe LEA could not produce documents following the PEIMS Data Standards. Errors noted included:

• Inappropriate disciplinary code assignments based on Appendix E of the PEIMS Data Standards;• Insufficient discipline record retention;• Inconsistencies in discipline documentation standards at the campus level; and

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Section II: Findings

Data validation Monitoring - Discipline

• Missing dates and signatures on electronic documents, discipline referrals, and administrativefindings/assignment documentation.

Recommendations and Required Actions:

30. Review and revise current discipline procedures and submit a written procedures manual whichincludes documentation standards and consequences for noncompliance with PEIMS DataStandards and TEC Chapter 37.

31. Review current data programs to ensure auditable documents that include electronic signatures withtime and date stamps.

32. Develop a process implemented at the campus level to ensure and validate that discipline coding issupported by appropriate documentation. Develop a system to monitor the implementation of thisprocess at the campus level and share feedback with campus administration.

33. Conduct an analysis to determine which campuses are contributing to the disproportionate African-American discretionary DAEP placements and develop an action plan of support to those campuses.

34. Develop a DVM corrective action plan (CAP) to address coding and or procedures noted in thisreport and submit validation of completion of each activity.

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Section 111: Next Steps

The LEA will:> Revise the targeted improvement plan to include the development and implementation of all systems

activities listed as recommendations and required actions in this report as well as 2014 state accountabilityratings and PBMAS received in August;

> Develop a corrective action plan (CAP) that outlines steps and procedures the LEA will take to correct allfindings of noncompliance, which are indicated in the report with bolded print;

> Inform the board of trustees in a public meeting of the noncompliance with statutory requirements identifiedin this report, and of actions the district will take to correct the noncompliance;

> Report to the TEA each month of the implementation and progress of improvement activities throughout thedistrict. This reporting will consist of written, as well as oral descriptions of the data and implementation ofactivities; and

> Submit the targeted improvement plan with CAP to the TEA by November 21, 2014.

The targeted improvement plan and progress reports must be submitted through the Intervention Stage andActivity Manager (ISAM) application within the Texas Education Agency Secure Environment (TEASE)according to the due dates listed above. The TEASE link is; https://sequin.tea.state.tx.us/apps/iogon.asp.Instructions regarding the use of ISAM can be found under the How Do I section of the monitoring link on theProgram Monitoring and interventions website at the following link: http://www.tea.state.tx.us/pmi.

Required Corrective Actions for Noncompliance Findings:

The LEA is required to correct any noncompliance finding as soon as possible, but in no case may thecorrection take longer than one calendar year from the date of notification of noncompliance. Failure tocorrect noncompliance within required timelines will result in elevated interventions or sanctions asreferenced in Texas Education Code (TEC), Chapter 39, Subchapter E; 19 Texas Administrative Code(TAG) §89.1076, Interventions and Sanctions, §97.1072, Residential Facility Monitoring: Determinations,Investigations, and Sanctions.

Corrective actions must be completed within one year of receipt of findings.

The agency also will require documentation verifying that:

> Policies and procedures, including operating guidelines and practices, have been changed, as necessary,and implemented as written;

> The LEA has notified the public of any changes to policies and procedures, including operating guidelinesand practices, related to disproportionality, discipline, and/or child find issues, as appropriate to the LEA;

> Decision-making frameworks/guidelines have been implemented;> The LEA has systems to ensure that students with disabilities are receiving all special education and related

services consistent with the child's needs; and> The LEA conducts ARD committee meetings as necessary to ensure the provision of a free appropriate

public education to the students in question and considers compensatory services, if appropriate to thestudents' individual circumstances.

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