3/12/2015

TO: Larry Nyland, Superintendent

Seattle Public Schools

FROM: Gayle Pauley, Assistant Superintendent

Special Programs and Federal Accountability

RE: Consolidated Program Review (CPR) 2014-2015 Report

On 3/11/20153/12/2015, a team from the Office of Superintendent of Public Instruction (OSPI) conducted a review of federal and state programs in which your district participates.

This report includes commendations, technical assistance, noncompliant items and actions required.

Your district has 45 calendar days from the date of the exit review to follow up with any action that is required for noncompliant items. Your follow-up due date is 4/27/2015.

Commendations:

Program Commendation Note

10)

Homeless

The district is to be commended on the outstanding improvement in the

McKinney-Vento program in recent years. Creating a systemic approach to

homeless student identification, developing and distributing quality resources

and materials, and continuing to emphasize the importance of identification

and support through staff training are all examples of the improvements noted.

Having a designated point of contact in each building is also a best practice.

Having dedicated staffing to increase capacity for this program has made a

positive and noticeable difference.

14) Civil

Rights

Based on the evidence provided, the district is to be commended for providing

sexual harassment training to staff and adopting a detailed sexual harassment

policy and procedure.

Technical Assistance:

Program Technical Assistance Note

3) Title I,

C

Continue planning efforts to regionalize professional development regarding

migratory lifestyle.

6) Title

II, A

There was a misunderstanding about what types of credits/clock hours needed

to be used to highly qualify elementary education teachers, which led to

many teachers in title 1 buildings being not highly qualified when the

district believed they were.

7) TBIP and

Title III

7.1: Ensure that the letter documenting parent waivers in all schools is

updated to reflect the guidance provided in

http://www2.ed.gov/about/offices/list/ocr/letters/colleague-el-201501.pdf.

7.1: If a parent refuses the annual WELPA, file the written refusal in a way

that is retrievable. 7.8: View the TBIP iGrants training for the 2015-16

school year to ensure that activities funded are allowable.

10)

Homeless

1. Recommend that the district continue to address issues of capacity, an

obvious challenge with a district of this size. 2. Building level staff do

not readily identify the use of the housing questionnaire as a means of

identifying homeless students at the building level. Additional work with

building level staff regarding the consistent use of the housing

questionnaire for every family every year should be a continued area of

focus. 3. Continue to formalize a system to determine the Title I homeless

set-aside each year, based on actual costs of services and supports for

homeless students.

11) Highly

Capable

Item 11.2 - For students who enroll in the district after the summer testing

opportunity in August, the district ID process must include procedures so

that a new enrollee has the opportunity to be identified within 3 months of

enrollment, and, if identified, be provided services during their transition

year. Item 11.3 - Parent/Legal Guardian Permission to Place notice needs to

be revised to explicitly obtain permission to place/initiate services. For

questions, contact the program supervisor for the highly capable program,

Kristina Johnstone. She may be reached at 360-725-4991.

12)

Perkins/CTE

CTE/Perkins - One of the main focus of Perkins IV Act is to provide outreach

and access to special population students. To the extent practicable,

members of the special populations will have equal accesses to CTE course

offerings. Locals, must provide outreach and recruitment methods to students

and parents on what CTE courses are offered. It is highly recommended that

the CTE program office coordinate with the Migrant and Bilingual offices to

present information to parents and students in an effort to increase student

enrollment and reduce barriers in CTE course classes. It is also recommended

that the district utilize local community organizations that provide direct

services to underrepresented population to enhance opportunities for

students to make the connection to future employment.

14) Civil

Rights

***14.3, Annual notification of discrimination complaint procedures: the

annual notification in a student handbook or similar publication must

include enough information for a person to know how to file a complaint:

what information the complaint must include, who and where the complaint

should be sent to, what happens when the district receives the complaint,

and what the district's response will include. IF the entire complaint

process is not included, the summary must also describe where the reader can

access the full complaint process. ***Revisions Necessary to Policies and

Procedures: To comply with OSPIs revised rules (effective Dec. 2014) and

recent guidance by the U.S. Department of Education Office for Civil Rights

(OCR), the district will need to update its nondiscrimination procedures

(3210P and 5010P), sexual harassment procedure (5011P), and HIB procedure

(3207P) as soon as possible. OCR has recently identified compliance concerns

regarding these procedures in other districts. Please ensure that the

district revises each of these procedures to include the requirements listed

in Chapter 392-190 WAC (www.k12.wa.us/equity/Rules.aspx) and in OCRs

guidance on Title IX and Sexual Violence (see question C-5 on page 12:

http://www2.ed.gov/about/offices/list/ocr/docs/qa-201404-title-ix.pdf) and

Harassment and Bullying

(www2.ed.gov/about/offices/list/ocr/letters/colleague-201010.pdf).

***Necessary Revisions to Student & Employee Handbooks: As the school

district updates the above procedures, student handbooks and employee

handbooks should be updated to reflect to the new policies and procedures.

Revisions should be made to topics relating to sexual harassment,

nondiscrimination procedures, and HIB. ***14.4 Sexual Harassment: We

recommend including more information in the student and handbooks on sexual

harassment and who students, parents, and employees may contact if they have

concerns or complaints. This is available in several languages at

http://www.k12.wa.us/Equity/Posters.aspx. ***14.15, Athletics: As the

district is considering how to equally accommodate the interests and

abilities of male and female student athletes, keep in mind that a lack of

resources is not appropriate reasoning for accommodating the interests of

one sex, but not the other.

Noncompliant Items:

Program Numbe

r Description Actions Required

Title II,

A

6.1 Highly

Qualified

Teachers

Following a review of all Title 1 buildings, there are

several teachers who do not appear to meet the federal HQT

requirements. Please provide a date that each of these

teachers will take appropriate test. In addition, please

provide a plan going forward that will ensure the district

will not place non-highly qualified teachers in a Title I

building.

TBIP and

Title III

7.1 Identification Submit the district's updated process for ensuring that

parents are never asked or required to waive ELL services

when they ask to attend their neighborhood school. Submit

an action plan for training enrollment and building ELL

staff on the guidance provided in the "Meeting the Needs

of EL Students Who Opt Out of EL Programs or Particular EL

Services" section of

http://www2.ed.gov/about/offices/list/ocr/letters/colleagu

e-el-201501.pdf. Submit an action plan for ensuring that

the Home Language section of the enrollment form is

completed for each student. Submit an action plan for

reviewing enrollment forms and transfer records to

identify students who potentially have been identified as

ELL in previous districts, so that the Limited English

Proficiency Application in the OSPI EDS system can be

consulted. In this way, the district will ensure

continuous enrollment of eligible students who transfer

from other districts. Submit an action plan for

maintaining current enrollment reporting for TBIP eligible

students who are under a parent waiver. These students

must be reported under program model "P", and program

enrollment must be reported annually until the student is

assessed as having reached English proficiency.

Perkins/C

TE

12.4 Special

Populations

District did not provide the 2014-15 enrollment report for

CTE courses.

Civil

Rights

14.1 Compliance

Coordinators

For each Title IX coordinator and Civil Rights

Compliance/Laws coordinator, please submit a description

of their duties and activities related to their specific

compliance roles. With these descriptions, please clearly

identify who the current designated employee is. Sample

job descriptions are available at

http://www.k12.wa.us/Equity/Districts/ConsolidatedProgramR

eview.aspx.

Civil

Rights

14.2 Nondiscriminat

ion Statement

Please submit an action plan describing how the district

will ensure that all district and building publications

that are widely disseminated to students, parents, and

employees (including newsletters, websites, handbooks, job

announcements, and CTE materials) will include the

district's nondiscrimination statement with the current

coordinator contact information.

Civil

Rights

14.3 Discrimination

Complaint

Procedures

(1) Please submit draft handbook language that informs

students and parents about the discrimination complaint

procedures. Sample handbook language is available at

http://www.k12.wa.us/Equity/Posters.aspx (translations

pending). (2) Please submit an action plan describing how

and when the district will distribute this information to

students and parents annually, such as in a student

handbook, calendar, or other publication (to be

implemented no later than beginning of the 2015-16 school

year).

Fiscal 15.5 Ranking and

Alloction

Olympic Hills Elementary over expended their 13-14 rank

order allocations. This resulted in Olympic Hills having

per pupil expenditures that were higher than the budgeted

per pupil amounts for schools with greater poverty

percentages. Submit an action plan to ensure that rank

order allocations will comply with Title I ranking and

allocating requirements.

If you have any questions or concerns about the information provided in this report or if you need further technical assistance, please use the contact information below. The agency TTY number is (360) 664-3631.

Program Monitor Phone Number

Consolidated Program Review

(360) 725-6100

1 Title I, A Larry Fazzari, Nate Marciochi (360) 725-6100

2 LAP N/A (360) 725-6100

3 Title I, C Sylvia Reyna (360) 725-6147

4 Title I, D N/A (360) 725-6046

5 Title I, G N/A (360) 725-6097

6 Title II, A Hisami Yoshida (360) 725-6340

7 TBIP and Title III Alyssa Westall (360) 725-

6147

8 Gun-Free N/A (360) 725-6044

9 Rural Education N/A (360) 725-6234

10 Homeless Melinda Dyer (360) 725-6050

11 Highly Capable Kristina Johnstone (360) 725-4991

12 Perkins/CTE Phouang Hamilton (360) 725-6245

13 Private Schools N/A (360) 725-6229

14 Civil Rights Sarah Albertson (360) 725-6162

15 Fiscal Jennifer Carrougher, Debra Crawford, Toni Bernethy,

Jamey Gelhar

(360) 725-6104

16 OSSS N/A (360) 725-6424

GP:ar/tm:kl

cc: , CPR Team Lead, Office of Superintendent of Public Instruction

Kevin Corrigan, Fiscal Contact, Seattle Public Schools

Min Yee, CPR Contact, Seattle Public Schools

Sylvia Reyna