161-914 may23, 2018 2017-2018 formation in ......section 7.021 and 7.028 of the texas education code...

TEATexas Education Agency Commissioner Mike Morath

7707 North Congress Avenue • Austin,Texas 78701-1494 • 512 463-9734 • 512 463-9838 FAX • tea.texas.gov

IMPORTANTMONITORING

IN FORMATIONMay23, 2018

161-9142017-2018

Sent Via EmailDr. A. Marcus Nelson, Superintendent Sheryl .davis(wacoisd . orgWaco Independent School DistrictP.O. Box 27Waco, TX 76703-0027

Dear Dr. Nelson:

The Waco Independent School District (ISD) was selected for participation in a 2017-2018program effectiveness review based on the following areas identified for intervention: stage 4 forspecial education, stage 2 for bilingual education/English as a second language (BE/ESL), stage2 for career and technical education (CTE), and stage 1 for the data validation monitoring (DVM)system for student leaver records and discipline. Additionally, J H Hines Elementary (El) andBrook Avenue El were rated 6th year Improvement Required (IR), Indian Spring Middle, G WCarver Middle and Alta Vista El were rated 5th year IR, and Crestview El was rated 3td year IR inthe 2017 accountability system.

The district was notified that the Texas Education Agency would conduct an on-site visit February12-16, 2018. The purposes of the on-site visit are to examine the origins of the district’s continuinglow performance and program effectiveness concerns across programs and identify systemicconcerns that may be impacting student performance.

The on-site review was conducted in accordance with the procedures posted on the TEA Divisionof School Improvement website at http://www.tea.state.tx.us/si, and under the authority of theSection 7.021 and 7.028 of the Texas Education Code (TEC). Prior to the visit, TEA staff reviewedrelevant data, including documents submitted from Performance-Based Monitoring (PBM)intervention activities. During the visit, agency staff evaluated program effectiveness andconducted individual interviews with district personnel, classroom observations, documentreviews, and student data reviews.

Preliminary findings from the on-site visit are enclosed in a document labeled PreliminaiyOn-site Report of Findings that includes specific issues/trends identified and the requited actions.We request that the Waco ISD review the preliminary findings and required actions contained inthis letter and the enclosed report. Please note that any corrective actions taken after the on-sitevisit will not be reflected in the report; however, the district will document corrective actions takensince the on-site visit in the first progress report. The district has 10 business days in which torespond to the agency findings and required actions before the report of findings becomes final.A Receipt of Preliminary On-site Report of Findings form is enclosed for you to indicate youragreement or disagreement with the findings and required actions.

Dr. A Marcus Nelson, SuperintendentWaco ISD

Waco ISD, with the required participants, will analyze the 2017-2018 targeted improvement planto determine the interventions that were most impactful and need to continue implementing orwere not successful and need to be modified or changed. Next, the district will develop a targetedimprovement plan for 2018-2019 to include the analysis of interventions, issues identified throughthe on-site visit, district required actions, and preliminary 2018 PBMAS data to be submitted tothe agency by October 5, 2018. In addition, the district will develop a corrective action plan (CAP)for all findings of noncompliance identified in the on-site report and submit to the agency by July10, 2018.

The LEA is required to correct any noncompliance items as soon as possible, but in nocase may the correction take longer than one calendar year from the date of notification ofnoncompliance. Failure to correct noncompliance within required timelines will result inelevated interventions or sanctions.

The TEA will monitor the implementation of all improvement activities and continue to follow upwith the LEA on an ongoing basis, review data and evidence of change, and verify implementationof the targeted improvement plan and CAP. The improvement plan and requited actions will bemonitored by the agency’s point of contact (POC) through post visit intervention (PVI) follow up.Additionally, the district must provide written and/or oral updates to TEA once a month regardingimplementation activities undertaken. Decisions about future intervention requirements will bedependent upon district implementation of current intervention requirements, includingimplementation of the improvement plan, and student performance on state measures.

We wish to thank the district and campus administrators for the courtesy extended during theon-site review. If you have questions regarding this letter or the enclosed report, please contactLiz Cronen in the TEA Division of School Improvement at (512) 463-5226 or by e-mail atliz.cronentea.texas.qov. We appreciate your assistance in the implementation of the on-sitereview and your ongoing support of all students.

Sincerely,

C. Lizette RidgewayDirector, Division of School Improvement

CLR/sh

cc: Yolanda Williams, Assistant Superintendent, Waco ISDSheila Whitehead, District and Federal Programs Contact, Waco ISDGrace Benson, BE/ESL Contact, Waco ISDDonna McKethan, CTE Contact, Waco ISDScott McClanahan, Special Education Contact, Waco ISDJerry Maze, Executive Director, Region 12 Education Service Center (ESC)Stephanie Kucera, Performance-Based Monitoring Contact, Region 12 ESCJoe Siedlecki, Associate Commissioner, School Improvement, Innovation & Charters, TEABarbara Kennedy, State Director for BE/ESL, TEATammy Pearcy, Assistant State Director of Special Education

Dr. A Marcus Nelson, SuperintendentWaco ISD

RECEIPT OF PRELIMINARY ON-SITE REPORT OF FINDINGSTexas Education Agency

Division of School Improvement

The district must complete this form by selecting only one of the two options as its response tothe findings as detailed in the enclosed Preliminary On-site Report of Findings.

1. The district agrees with the contents of the report, which becomes final with returnof this receipt.

2. The district is in receipt of and disagrees with the contents of the report and issubmitting those objections in writing. Any disagreement must be accompaniedby all data andlor documentation available and necessary for TEA’sreconsideration of the preliminary findings under 19 Texas AdministrativeCode (TAC) §97.1033(c). The TEA will not consider documentation ofcorrective actions taken after the on-site visit in its reconsideration of thepreliminary report findings.

Failure by the district to respond by the date specified below will be interpreted as agreement withthe report.

Signature of Superintendent Date

Waco Independent School District 161-914Name of School District County-District Number

This Receipt of Preliminary On-site Report of Findings form, and any documentationsubmitted by the district are due to TEA on or before June 8, 2018.

Return this form (by mail, fax or email) and supporting documentation to:

Texas Education AgencyDivision of School Improvement1701 North Congress AvenueAustin, Texas 78701Fax: (512) 463-3136Email: Sldivisionctea.texas.ov

Waco Independent School District161-914, 2017-2018

Texas Education AgencyDivision of School Improvement

Preliminary On-site Report of Findings

Section I: Overview: Overall History & Background

During the week of February 12-16, 2018, the Texas Education Agency (TEA) conducted an on-site review ofthe Waco Independent School District (ISD), due to the identification of substantial, imminent, and ongoing risksacross programs reported in the Performance-Based Monitoring Analysis System (PBMAS). For 2017-201 8,Waco ISD is staged for program interventions at stage 4 for special education, stage 2 for bilingualeducation/English as a second language (BE/ESL) and stage 2 for career and technical education (CTE).Additionally, the district did not meet all its system safeguards, and J H Hines Elementary (El) and BrookAvenue El were rated 6th year Improvement Required (IR), Indian Spring Middle, G W Carver Middle and AltaVista El were rated 5th year IR, and Crestview El was rated 3rd year IR in the 2017 accountability system.

A seven-year history of Waco ISD’s staging in the Performance-Based Monitoring (PBM) intervention systemare outlined as follows:

PBMAS SpecialStaging BEIESL CTE NCLBIESSA Education

201 0-2011 Not Staged 3 1 4 -Onsite

2-Continuing2011-2012 Not Staged Implementation 1-Baseline

4 (Escalated201 2-2013 Not Staged Oversight)- Not Staged 2 (Cl)

Onsite

2013-2014 3-YAO 4-YAO 1-YAO 4-YAO

2014-2015 3-Onsite 2-Onsite 2-Onsite 4 -Onsite

3-Post Visit201 5-2016 Intervention Not Staged-PVI 2-PVI 2-PVI

(PVI)

2016-2017 3 2 1 4

Prior to the February 5-9, 2018 on-site review, TEA’s most recent visit was conducted the week of December 8,2014, and the report was issued April 6, 2015. Based on observations and information gathered from recordsand interviews during that review, the agency team concluded that the district had material, systemic, andpervasive weaknesses in its general education program, and with staff morale, that directly impacted studentsserved through programs monitored by the PBMAS. The TEA also conducted on-site reviews in 2012-2013 forthe CTE and special education programs and for data validation monitoring for leaver records and in 2010-2011for the special education program.

The TEA informed the district of actions necessary to improve outcomes for students. In response to theidentified issues, the district developed an integrated targeted improvement plan (TIP), reflecting the analysis ofissues identified and the required actions. Agency staff worked with the district during the 2015-2016 PVI year

Page 1 of 23


Section I: Overview: Overall History & Background

reviewing implementation of the district’s targeted improvement plan. Many of the initiatives and systemsdiscussed in the 2014-2015 Report of Findings were implemented the following year. A review of 2017 PBMASdata for the district indicates the following significant concerns:

• performance of students served in special education on State of Texas Assessments of AcademicReadiness (STAAR) 3-8 assessments and STAAR End-of-Course (EOC) assessments, and CTEstudents served in special education on the STAAR EOC assessments;

• performance of students formerly served in special education on the STAAR 3-8 assessments;• performance of students receiving BE/ESL services and limited English proficient (LEP) students not

served in BE/ESL programs on STAAR 3-8 assessments, and LEP students and CTE LEP students onSTAAR EOC assessments;

• percent of LEP students in U. S schools’ multiple years who received a Texas English LanguageProficiency Assessment System (TELPAS) Composite Rating of Beginning or Intermediate;

• percent of students in Grades 3-9 served in special education who were tested on STAAR Alternate 2in all subjects applicable to the student’s grade level;

• percent of students ages 3-5 served in special education who were placed in a regular early childhoodprogram;

• percent of students in Grades 7-12 served in special education who dropped out; and the• percent of students served in special education who graduated with a high school diploma in four years.

Through interviews with district administrators and a review of the district’s 2016-2017 Texas AcademicPerformance Report (TAPR), the agency team learned that, during the 201 6-2017 school year, the districtserved a total of 15,058 students. Data indicated that 71.4 % of the district’s student population during the2016-2017 school year was identified as at-risk, a decrease of 4.9% from the prior year, and 85.4% wereidentified as economically disadvantaged. Additionally, 18.6% (2,795) of the student population were Englishlanguage learners (ELLs) who received services through BE/ESL programs. Also, 1,090 students receivedservices through special education.

During the on-site visit, the agency team conducted interviews with district and campus leadership, participatedin a presentation led by the district leadership team (DLT), facilitated campus focus groups (general education,special education, BE/ESL, and CTE teachers, and instructional specialists) at six of the district’s campuses,and conducted student document and data reviews and classroom observations. Through these on-siteactivities, the agency team determined that the following root causes contributed to areas of low studentperformance and effectiveness of programs.

Page 2 of 23


Report Topics in Section II: Contributing Factors Pages

Leadership 3 - 5

Curriculum and Instruction 5 - 8

> Interventions for Struggling Learners 9 - 12

Special Education 12- 19

Least Restrictive Environment (LRE): Ages 3-5 12 - 13

STAAR Alternate 2 Participation Rate 13 - 14

> Discretionary Discipline Removals 14 - 15

> Annual Dropout and Graduation Rate 15 - 17

Special Education Program Stage 4 Intervention Requirement 17

> Special Education Compliance and Noncompliance 17 - 19

Bilingual and English as a Second Language (BE/ESL) 19 - 22

Career and Technical Education (CTE) 22

Section II: LeadershipAt the time of the February 2017-2018 on-site visit, the superintendent was in his first full year of coordinatingthe overall administration of the district. The agency team learned, prior to being onsite, that other significantleadership and organizational changes had recently occurred:

• The assistant superintendent of school improvement position was created.• The assistant superintendent of instruction position was eliminated and two executive directors of

curriculum, elementary and secondary, were established. The executive directors of curriculumoversee the special education and BE/ESL departments.

• The director of special education retired, and the assistant director resigned. At the time of the visit, thetwo special education coordinators were leading the department with close oversight by the twoexecutive directors of curriculum.

The executive directors of curriculum were charged to work directly with content specialists and instructionalcoaches to provide targeted assistance to campuses based upon a tiered approach. The executive directorsalso work directly with campus administrators, instructional specialists and coaches to ensure the curriculum istaught at the expected level and that support to positively impact student achievement is provided. The agencyteam learned post on-site visit (5/2018), that the two special education coordinators who were leading thedepartment with close oversight by the executive directors of special education resigned, and that thedepartment was in the process of undergoing substantial changes, including restructuring.

The superintendent shared that crucial time was spent studying and familiarizing himself with the immediateneeds of the district. He identified challenges that required focused and deliberate attention, that if notaddressed would continue to be detrimental to students:

• low academic and behavioral expectations for students;• a lack of high quality tier 1 instruction;• inability to attract and retain high performing teachers; and• a lack of active and full enqaQement of all stakeholders.

_________

Page 3 of 23


The superintendent also communicated that the present school funding system has also complicated matterswithin the district.

To ensure clear communication and focus, the superintendent implemented structured systems designed tofacilitate communication and expectations of goals and initiatives, and to ensure that all district staff is focusedon teaching and learning:

• At the August 2017 convocation, the superintendent communicated his expectations to all staff.• Weekly cabinet meetings, and monthly director and principal meetings are held to discuss instruction

and operational issues.• Individual meetings with campus principals are facilitated each six-weeks to discuss student outcomes

and operational issues. Evaluation goals are set based on student performance.• Principals are required to provide information to staff during professional learning community (PLC)

and staff meetings.• Expectations and structured systems are also discussed at campus and department meetings.

The superintendent’s clear communication and focus initiative also extended to the families of their studentsand to the community at large:

• The superintendent created an assistant superintendent for student services and family engagementposition.

• Campuses were directed to reestablish parent organizations, to include hosting four campus activitiesduring the school year.

• A district-wide family engagement plan was implemented to include the:o We are Family literacy night;o College in Sight week;o Men of Action and Women of Action events, each focused on engaging positive male and

female role models; and theo Summer Summit, an event to highlight local, district, and state learning opportunities available

during the summer.• To increase family engagement opportunities for Hispanic families, a partnership was created with the

Avance Waco Board.• The superintendent conducted several community meetings and implemented, Let’s Talk! — an on-line

system designed to facilitate and encourage dialogue with stakeholders.

Membership of the DLT is comprised of representatives from BE/ESL, CTE, special education, response tointervention (RtI), dyslexia and testing, general education, Title I, student services, early childhood, HumanResources (HR), communications, technology, and advanced academics. The agency’s team review of thedistrict’s 2017-2018 targeted improvement plan revealed that the DLT identified that there was a lack ofcollaboration and follow-through among and between departments addressing supports for students served inspecial education as the root cause for their poor academic performance. In response, the DLT developed onemeasurable annual goal and several supporting activities addressing increasing the performance of studentsserved in special education through implementation of systemic planning and monitoring processes designedto address professional development (PD), collaboration between CTE, BE/ESL and special educationdepartment leadership, data analysis, instructional service delivery and recruitment of special education andcore content certified teachers. Collaboration between district departments has taken on a greater level ofurgency under the leadership of the new superintendent.

The agency team conducted interviews with campus leadership and facilitated focus groups at six campusesvisited during the on-site visit. Participants were provided with an overview of longitudinal state assessmentperformance data for students served in special education and for ELLs served in BE/ESL and were providedthe opportunity to discuss what they believed or understood to be the root cause(s) of poor performance. Inaddition to the root causes addressed by the DLT, participants also discussed the following with the agencyteam, some being similarly related:

Page 4of23


• students demonstrating low vocabulary, fluency, and comprehension skills;• student mobility within district;• behavioral and emotional needs of students;• lack of sufficient PD in prior years;• failure to ensure that all students with disabilities who need special education services were identified;• not appropriately staffed to provide specialized instruction for students served in special education;• current and prior inclusion support model does not meet the needs of students, multiple variables

discussed;• lack of understanding as how to accommodate for students’ instructional needs;• failure to provide BE at more campuses;• lack of direct instruction in English language acquisition;• lack of content-specific bilingual materials; and• lack of providing a community-based culture where ELLs feel welcome.

During the on-site visit the DLI presented to the agency team information specific to the implementation andreview of the district’s 2016-2017 targeted improvement plan, to include the results and carryover from theprior plan, and development and implementation of the district’s 2017-2018 targeted improvement plan. TheDLT communicated that there was a strong commitment from the board of trustees and district leadership toensure that departmental structures fostered the collaboration required to implement the targeted improvementplan with fidelity. Review of the district improvement plan and the targeted improvement plan indicatealignment of focus.

Required Actions:

1. Analyze and evaluate the current structure of the district’s special education department. Revise asneeded to meet the needs of students. Provide the department’s revised organizational structure toTEA.

2. Analyze the root causes (page 5) identified by campus leadership and staff Determine if additionalstrategies are required to meet the needs of students. Report analysis findings to the TEA.

Section II: Curriculum and InstructionThe agency team learned that Waco ISD adopted the TEKS Resource System (TRS) as the district’scurriculum management system. IRS affords district staff a common language, structure, and process fordelivering curriculum to achieve horizontal and vertical alignment within and across all core content areas. TRSis designed to be used alongside district-approved resources and is customizable to meet the individual needsof students. To accommodate the diversity of learners with significant disabilities, the district has implementedthe Unique Learning System®, a standards-based curriculum, which aligns to the chronological grade-level ofstudents and incorporates three differentiated levels of instruction within each unit.

To improve the rigor and relevance of instruction occurring in the classrooms, district staff developed systemsto ensure that the superintendent’s high-impact curricular non-negotiables, the Super 7, are implemented withfidelity in every classroom: evidence of planning, the posting of a daily objective, daily journaling or notetaking,the teaching of academic vocabulary, the maintenance of a word wall in each classroom, the use of higher-levelquestioning, and evidence of high expectations for all students. In addition to the focus on planning andinstructional practices, a heightened focus was placed on reading and writing instruction.

For the 2017-2018 school year, the district sponsored summer academies for all the core content areas andprovided PD throughout the year to support the district’s initiatives: implementation of the curricular framework,instructional resources, content knowledge and data analysis. The executive directors of curriculum ate activelyin the process of developing a core set of PD sessions that will run on a three-year cycle and be required ofevery teacher, teacher assistant, and administrator.

Page 5 of 23


Horizontal curricular alignment and planning is built into district-level PD sessions and is addressed duringcampus-based PLCs for tested subjects. Content specialists also facilitate meetings to reinforce curricularobjectives, and to verify that teachers have the appropriate resources. District leadership and campus focusgroup participants reported that vertical planning was not commonly implemented across the district, except bythe content specialists. The ability, experience and understanding to facilitate student learning to the levelexpected is usually accomplished through various components, many of which are being implemented in thedistrict. Purposefully including teachers in vertical planning processes is an effective way to increaseinstructional capacity.

To monitor student progress toward reaching state standards, benchmark assessments are givenapproximately every 9 weeks. District leadership reported that in addition to sharing with each campus principaltheir respective campus’ passing rates at each level, they have also provided the progress of students servedthrough special education and those served in BE/ESL programs as compared to the district-wide rates. Dataanalysis is a core component of the district’s PLC framework. Administrators and district-level instructionalsupport specialists work with teachers to determine target areas and to design future instruction that meets theindividual needs of students and the high-stakes testing requirements. Through the analysis of data, planningparticipants identify the TEKS and student expectations that need to be targeted, identify skills and conceptsthat require re-teaching or spiraling back, and determine grouping of students for targeted instruction and/orintervention. The effective use of assessment data by all instructional staff was reported to be at varying levelsof mastery, with specific regard to the interpretation and alignment of individual data to the design of instruction.The agency team evidenced that student assessment data was disaggregated and used to determine the needfor interventions and/or extended learning.

Campus leaders and campus focus group participants reported that special education teachers were in manysituations, not participating in the PLCs. The agency team learned that often instructional schedules andcaseloads did not afford their participation. The implementation of well-designed and structured planningsessions/PLCs has been a proven, research-based strategy that has been recognized to increase teachercollaboration and morale and more importantly, to increase students’ learning and achievement in theclassroom. One of the most important components is the collaboration between all parties. Research indicatesthat the participation of special education teachers in teacher planning sessions yields an interdependencyamong all teachers who engage in routine discussions about standards and essential outcomes. This practicewill afford special education teachers the opportunity to become more attuned to the pace of instruction andwhat is most critically related to the standards being taught. Special education teachers also possess expertisedirectly related to differentiation of instruction and the needs of struggling learners. It is important that the role ofthe special educator in the teacher planning sessions is not overlooked. Purposeful planning to ensure theparticipation of special education teachers in teacher planning sessions/PLCs for the 2018-2019 instructionalyear must be a focused and urgent priority.

Implementation of the curriculum, PLCs, and other district initiatives were reported to be monitored by bothdistrict and campus administrators during walk-throughs, observations, and attendance of PLCs. Contentspecialists, instructional specialists and instructional coaches also conduct visits to classrooms to observeimplementation of the curricular framework and the Super 7, attend PLCs to direct conversations and answerquestions, and provide additional PD, co-teaching or modeling, when required. The superintendent reportedthat the district implements the T-TESS (Texas Teacher Evaluation and Support System) to evaluateinstructional staff. Leadership reported that approximately 8,500 classroom walkthroughs were conductedduring the 2016-2017 school year. District analysis of the 2016-2017 campus-based walkthroughs andobservations indicated a need for improved calibration among campus administrators. In response to the need,additional PD was provided to the campus administrators in August of 2017. District leadership reported thatthe current focus is conducting classroom walkthroughs to evidence implementation of the superintendent’sSuper 7 initiative. All campus administrators interviewed discussed the observation and walkthrough processesimplemented at their respective campus. District leadership reported there were teachers at every campus whowere on a professional growth plan. Campus leadership discussed systems of support in place for teachers ona professional growth plan, provision of PD and support from specialists. Teachers who make minimal or nopogress in their professional growth may not be offered a contract for the next school year.

Page 6 of 23


The superintendent was asked to share with the agency team his current level of satisfaction with thedevelopment, implementation and monitoring of the district’s curricular framework. He reported that district staffare working diligently to implement a proactive literacy growth approach districtwide, and that he fully supportsthe implementation. The superintendent shared that school personnel and the community alike, havecommunicated appreciation for the transformation of the curriculum department. They noted significantimprovement specific to communication and the level of interaction and support received from the department.Campus focus group participants, and district and campus leadership also echoed the same message duringthe agency team’s time onsite. The agency team found that the curricular framework and data analysesprocesses, along with the Super 7 instructional initiatives, are being implemented with a sense of urgency anddue diligence. The district will need to monitor implementation of the newly-developed systems and supportsdesigned to meet the individual needs of students with a continued focused and urgent priority.

The agency team learned through interviews with district and campus leadership and agency team classroomwalkthroughs that while structured systems are in place to verify implementation of the district’s curricularframework, there were varying instructional skill levels observed among the teachers at the campuses visitedthat the district is addressing through the mechanisms previously mentioned, and some noted below. Thedistrict’s 2017 TAPR indicated that 32.9% of instructional staff had 1-5 years of experience, 14.2% werebeginning teachers, with the average years of teaching experience district-wide being 9.4, 1.5 years below thestate average, and the turnover rate was 23.7%, 7.3% above the state average. District and campus leaders,and campus focus group participants, discussed the strategies/activities that have been implemented toaddress the needs of teacher’s newer to the profession and the high teacher turnover rate:

• Each year the district contracts with the Texas Association of School Boards to conduct an employeeclimate survey. The results are shared with the superintendent’s cabinet, principals and directors, andprincipals can focus on areas that require improvement. Additionally, the district’s human resourcesdepartment initiated a task force in 2017 to address what the district could do to retain quality teachers.Feedback was provided to district leadership.

• The district offers competitive compensation plan.• As a direct result of the passing of the Tax Ratification Election, the district hired an additional 200

employees to assist teachers and support the improvement of instruction: coaches for beginningteachers, behavior support staff, reading teachers and coaches and primary literacy paraprofessionals

• All newly hired teachers in place by July 31 participate in a three-day induction program. Teachersreceive targeted PD, some of which include, a framework for understanding poverty, shelteredinstruction strategies, classroom management, reading/writing instruction, amongst others.

• The district implements a mentor program for all teachers new to the profession, SUCCEED, in whichthe teachers are paired with a campus-based mentor teacher. The program provides support throughface-to-face meetings, online assignments and discussion boards, and through observations andfeed back.

• The district’s content specialists, instructional coaches, instructional specialists (district and campuslevel), and instructional technology coordinators also provide support. For secondary teachers new tothe profession, an instructional coach rotates through teachers’ classrooms providing support withplanning, modeling, co-teaching, resource development, goal setting and follow-up, and observation andfeedback.

• The district also provided monetary incentives to teachers:o The STAAR Incentive Plan provided money to teachers for each economically disadvantaged

student who met standard on state assessments.o Teachers who worked at an IR campus were offered a longevity incentive, which was based on

the percentage of students who met standard on the state assessments.o A $10,000 signing bonus was provided to new candidates who elected to work at a 4th year IR

campus. The candidates were required to evidence proven success.

The agency team found that the above-average turnover rate for teachers, coupled with the high percentage ofteachers in the district with five or less years of experience (47.1%), have both been contributing factors thathave directly impacted student performance. The agency team recognizes that the district has strategically andpyrposefully designed and implemented interventions to hire and retain quality teachers, and that the provision

Page 7of23


of targeted, quality PD, the implementation of the Super 7 initiative, and monitoring and adjusting based ondata will need to continue to be a focused and urgent priority.

Research shows that attendance of both students and teachers is a key factor in student achievement. Thedistrict’s 2017 TAPR indicated that the district’s student attendance rate for 2015-2016 was 93.9%, 1.9percentage points below the state rate, 95.8%. District-provided data indicated that the student attendance ratefor 2016-201 7 was 94.54%, an increase of 0.64%. Review of current attendance data by the district indicatedthere had been as much as a full percentage point gain in some weeks; however, the overall attendanceaverage was reported to be flat. District leadership identified possible contributors to the lack of progress inimproving student attendance during the first semester of the 2017-2018 school year:

• In prior years, student attendance was not an area of focus. Campus leadership was in the beginningstages of evaluating their attendance issues at a level that will lead to change.

• The CIS attendance mentoring program and re-alignment of the Justice of the Peace’s caseloads, wasto occur in the spring semester.

• Incidents of students diagnosed with the flu increased this year, and it was the coldest January in thepast several years.

• The district reported unfilled vacancies in the attendance department.

The superintendent has communicated to all district staff that increasing student attendance is a district priority.Attendance data is tracked by each campus and the district. Weekly reports are provided to thesuperintendent’s cabinet and to each principal. To increase student attendance, the district:

• Restructured the supervision of attendance court liaisons and parent campus liaisons to streamlinemonitoring and to enforce truancy prevention measures.

• Worked with the health district to offer flu shot clinics.• Working with community and contracted partnerships for mentoring programs focused on attendance.• Implemented an initial phone call from School Messenger that takes place shortly after school starts to

prompt students who marked as absent to come to school prior to the official attendance time.

Additionally, the agency team reviewed district-provided teacher attendance data and the factors impacting therecent decline, as well as the measures implemented to address the concern. The agency team recognizes thatimplementation of activities designed to positively impact student and teacher attendance is multifaceted, andthat it will take time to implement and monitor systems and processes. The district will need to continueimplementation of the newly-developed systems and supports designed to meet the individual needs ofstudents and teachers, monitoring and adjusting as indicatecJ with a focused and urgent priority.

Required Actions:3. Implement systems designed to monitor implementation of the curriculum and required instructional

strategies to determine if instruction in the classroom meets the needs of students. Review the datacollected to determine if revisions are requited. Additionally, review the district’s vertical planningstructures; determine a structure/structures that would support including teachers in vertical planningprocesses.

4. Implement systems/processes designed to support the participation of special education teachers inteacher planning sessions (PLC5) across the district. Verify through monitoring.

5. Review data collected from the implementation of district/campus-level created activities/strategiesdesigned to increase teacher retention, as well as the systems in place designed to support strugglingand/or teachers at the beginning of their career. Determine if revisions/additions to the designedactivities/strategies are required.

6. Review data collected from the implementation of district and campus-level created activities designedto increase student and teacher attendance. Determine if revisions to the designed activities orprocesses are required.

Page 8 of 23


> Interventions for Struggling Learners

A review of documentation and district and campus staff interviews during the on-site visit revealed that thedistrict provides interventions for students who do not perform satisfactorily on benchmarks, and stateassessments. Tutorials, both before and after school and on some Saturdays, along with remediation classesare offered at the campus level to address academic needs. Administrators and focus group participants ateach campus visited, provided information about supports that were in place on their respective campus tosupport identified students. Additionally, the agency team learned about the district’s partnership with theBaylor University School of Education, Professional Development School (PDS) with six of the district’scampuses: Bell’s Hill Elementary, Hillcrest PDS, Mountainview Elementary and Parkdale Elementary, CesarChavez Middle School and University High School levels. The mission of PDS is professional preparation ofteacher candidates, school and faculty development, inquiry directed at the improvement of practice andenhanced student learning. Teacher education candidates work with mentor teachers and clinical instructors inthe district’s classrooms to enhance the preparation of new teachers and improve education for children.

A review of campus schedules reflected that tutorials were provided, and focus group participants providedinformation about the supports, strategies and initiatives that were in place on their respective campus tosupport struggling learners: implementation of the Super 7 planning and instructional behaviors, positivebehavioral intervention & supports (PBIS), Rtl, Leveled Literacy Intervention (LLI) and use of instructionalsoftware or curriculum-based websites such as, Achieve 3000, Smarty Ants, and iStation. Teachers alsodiscussed pre-teaching vocabulary, using interactive journals, hosting family reading nights, and some teachersdiscussed implementation of small group and pull-out instruction. It must also be noted that a considerablenumber of teachers when asked what initiatives were being implemented at their campus/in their classroom toimprove the academic performance of students with disabilities and/or ELLs, responded by saying, nothingreally, that they did not know, were unsure, or were not aware of any specific initiatives.

While it was evident to the agency team that the district provides interventions for struggling students, thedistrict lacked in many cases, targeted interventions. A review of individualized education programs (lEPs) bythe agency team revealed that admission, review, and dismissal (ARD) committees were not always convenedto develop intensive programs of instruction as required by TEC §28.0213(e) (see section, Special EducationNoncompliance). The agency team expressed concern to the district that students with disabilities whose needsare not being satisfactorily met through universal interventions, may requite more individualized interventions toaddress their needs, and that the lack of targeted individual programs of instruction may have been acontributing factor to the poor performance in the state assessment passing rates. Development andimplementation of targeted intensive programs of instruction for each identified student will need to be afocused and urgent priority of the district.

Rtl is a multi-tiered approach designed to help struggling learners, both academically and/or behaviorally.Students’ progress is to be closely monitored at each stage of intervention to determine the need for furtherresearch-based instruction and/or intervention in general education, in special education, or both. For Rtl towork, the essential components must be implemented rigorously through tiered instruction and intervention,ongoing student assessment and family involvement. The 2014-2015 On-Site Report of Findings documentedthat the Rtl process was not fully implemented and monitored at every campus. Variance in the implementationwith fidelity of the district’s developed system was a concern. As a result, the district was required to: 1.Evaluate the implementation of the Rtl process to determine its effectiveness at each campus. 2. Provideongoing monitoring and support for the full implementation of the Rtl model at all campuses. 3. Evaluate allinterventions programs used with struggling students to determine each programs’ effectiveness in increasingstudent performance.

For the 2017-2018 instructional year, the agency team identified that Waco ISD had the following structures inplace specific to implementation of the district’s multi-tiered Rtl processes, including:

• providing professional development and resources outlining the district’s framework;

Page 9 of 23


• identifying universal screeners in English and Spanish and the required frequency of screening and therespective cut scores (PK-5) to identify students at-risk;

• recommending some interventions to meet the needs of students: iStation, LLI, Pearson MathIntervention and Guided Reading;

• maintaining student-specific documentation in Eduphoria, with secondary campuses also using a Rtlspreadsheet;

• facilitating campus RtI teams; and• informing and involving parents in the process.

District leadership reported that Rtl was being implemented and monitored; however, the level ofimplementation was noted to vary widely from campus to campus. The agency team learned the goal is tostrengthen implementation, understanding, and monitoring on every campus specific to each of the four criticalcomponents: universal screening, research-based interventions at each tier of support, progress monitoring,and data-based decision making. Although data can be accessed through Eduphoria, as well as through theelementary and secondary data sheets submitted to the district coordinator, ease of data entry, data access,and data analysis has been an ongoing concern. The district is currently accepting bids for a systemthat will streamline the entire Rtl process and facilitate tracking of individual interventions. Campus leadershipand focus group participants were asked to outline and then rank the implementation of Rtl at their campus,using a scale from 1-10, with 10 being the highest level of implementation. The average of the campus focusgroup participants’ rankings was 7.5, and the average of the campus leadership’ rankings was 8.29. Ifparticipants ranked implementation below a 7, they were asked to outline what the barriers were toimplementing/monitoring RtI as designed. The following was shared across the campuses visited:

• a lack of consistency and fidelity in implementing and monitoring, little to no collaboration between staff;• not enough staff to provide the interventions for the high number of students that need interventions;• teachers are not always aware of every intervention,• interventions are not always conducive to students’ schedule Rtl is a cumbersome process, it is hard to

make time to do the paperwork;• services are not provided in a timely fashion;• a lack of ownership by teachers;• more progress monitoring is needed;• non-core teachers are not involved in the implementation of RtI;• a lack of parent involvement at the campus;• tutoring after school is for the ‘bubble kids,” not for students with disabilities;• providing transportation for afterschool tutoring is an issue;• materials for Tier 3 are not always available, we do a lot of sharing;• office referrals for behavioral concerns are not processed;• some participants communicated that implementation of Rtl for academics was working, but not for

behavior, and some felt it was working for behavior and not for academics; and• apathy of the students.

Through interviews with district and campus leadership, and through the facilitation of campus focus groups,the agency team concluded that campuses are in various stages of implementing the district’s Rtl processesand procedures designed to address the academic needs of struggling learners across the district, with theelementary campuses implementing the processes more systemically. Both the on-site team and the districtrecognize that the continued provision of PD, and monitoring and adjusting will need to be an urgent andfocused priority.

The agency team identified through review of district and student records, interviews with special educationleadership, campus administrators, and teachers, and through classroom observations during the 2017-2018on-site review, that the district provides the following continuum of services for students with disabilities: inclass support, co-teach (pilot) and pull-out services. Speech, and related services are provided to identified

Page 10 of 23

Waco Independent School District161-914, 2017-201 8

students across the district, and to accommodate learners who need a higher level of structured supports, lifeskills settings and behavior, academic, and social education (BASE) programs for students are available. Topromote rigorous instruction, the district has been working to continue to build support and planning systems forstudents with disabilities to receive instruction in general education classrooms. Inclusion support is providedby both certified special education teachers and paraprofessionals under the direction of a certified specialeducation teacher.

The 2014-2075 On-Site Report of Findings documented that the special education administrative teamemphasized that efforts had been made to increase access to the general education curriculum and classroom.Ongoing training was provided to campus leadership on redefining “resource” as a service, rather than a place.For the 2017-2018 on-site visit, district leadership was asked to provide an update specific to the redefinition of‘resource” as a service, as opposed to a placement. The 2017-2018 on-site agency team learned that thedistrict did not have identified resource classrooms. As the district does not have identified resource classroomspace, finding a location to provide students’ required pull-out services was reported to sometimes beproblematic. The district’s analysis of performance data for students served through special education has ledto the consideration of adding both the use of resource classes and a co-teach model to the district’s continuumof services.

Through interview with campus leaders and the facilitation of campus focus groups, interviewees and focusgroup participants were provided the opportunity to discuss the implementation of in-class support services attheir campus. Through this process, the agency team learned the following:

• As previously reported, not all special education teachers’ schedules afford planning/participation ingrade-level and/or content PLCs. Of the 58 responses received from focus group participants, 15reported that their schedule afforded cooperative planning, 27 reported that their schedule did not, and16 participants reported that they were doing all they could to stay as apprised as possible.

• Paraprofessionals and some special education teachers were reported to lack the content knowledge tobe fully supportive when providing in-class support. In response to being asked if special educationteachers and paraprofessionals attend content-specific PD, 27 participants reported that they do attend,eight reported that they did not, and four communicated that sometimes they participate in content-specific PD.

• In response to being asked if students receive a level of support which will support them in masteringtheir annual goals, as well as meeting standard on state assessments, 20 participants reported that theydo receive the level of support needed, 21 reported that they require a higher level of support then theywere receiving and 11 participants communicated that they do receive the required level of support, butthat the students were so far below grade-level performance that they would not meet standard on stateassessments. Some teachers reported that the inclusion support provider did not always provide theduration of the support required, with some describing the support as “hit or miss,” and others reportedthat the support was being provided during whole group instruction and not during small groupinstruction or independent work, when needed. Several participants also conveyed a strong concernregarding the removal of resource instruction from the continuum of services.

• A concern was shared that special education instructional staff were spread thin at some of thecampuses.

Within the research literature on the implementation and success of in-class support, several common themesemerge that are critical for these service deliveries to be successfully implemented. These themes focus on aneed for communication between teaching and support partners, administrative support, similar philosophies,and planning time. To meet the academic and behavioral needs of students, the district will need to address theconcerns noted above with a focused urgency.

Required Actions:7. Evaluate the district’s Rtl (academic and behavior) structures/systems and guidance

document/handbook revise as indicated, and provide PD to all stakeholders. Implement systems

Page 11 of23


designed to monitor the implementation of the districts Rtl model to determine if the needs of studentsare being met. Review the data collected to determine if revisions are required.

8. Analyze the areas of need/concern identified (page 11) specific to the structure and provision ofinclusion support services by campus staff and include activities/strategies designed to address theneeds/concerns to meet students’ needs in the districts 2018-2019 targeted improvement plan.

9. Conduct an analysis of the district’s:a. current inclusive services and models, and determine what revisions are required to ensure that

students receive their required support.b. continuum of pull-out services and determine what revisions are required to ensure that students

needs are met. Report the findings and determined revisions to TEA.

Section II: Special EducationLeast Restrictive Environment (LRE): Ages 3-5

A longitudinal review of PBMAS data indicates that the percent of students ages 3-5 served in specialeducation who were placed in a regular early childhood program has been a concern for the district for severalyears. A review of 2016 PBMAS data indicate that the percent of students served in special education placed ina regular early childhood program was 21.2 percentage points below the state cut point (30.0%), resulting inthe assignment of a PL 3. For the current reporting year, the percent of students placed in a regular earlychildhood program is 18.9 percentage points below the state cut point, an increase of 2.3 percentage points,resulting in the assignment of a PL 2. District-provided data (January 2018) indicates that the percent ofstudents served in special education placed in a regular general education program is 10.3%, a 0.8% decrease.

A review of Waco ISD’s 2016-2017 TIP revealed that the DLT identified the following as the root causes for sofew students ages 3-5 served in special education receiving programming in a regular early childhood program:

• There is limited access to the LRE for students.• Campus location of PPCD (Preschool Program for Children with Disabilities) programs create barriers to

students’ access to the general education curriculum.The DLT designed activities to increase students’ access to the general education curriculum with their sameage peers. The district reported in the TIP submission of June 22, 2017 that it was determined to implement anew program in conjunction with Head Start/Jumpstart for the 2018-2019 school year.

In response to the agency team’s request to provide an update specific to progress made toward implementingthe new program, the district reported in January that the discussion with Headstart/Jumpstart had stalled. Dataanalysis conducted by the district revealed that performance outcomes for students participating in the existingmodel were poor. In response to the finding, the district eliminated many of these classrooms, and developed atransformation plan that was submitted under House Bill 1842/Senate Bill 1882, which includes increasing earlychildhood education classes, particularly the establishment of a general education PK3 class. The district’sDropout Recovery Plan (DRP) also addresses the expansion of general early education classes and outlinessupporting research.

Through interviews with campus leaders and the facilitation of campus focus groups, interviewees and focusgroup participants at elementary campuses visited were provided the opportunity to discuss the root causes forwhy more students with disabilities ages 3-5 were not served in a regular early childhood program, as well aswhat initiatives were being implemented to increase the percentage of students with disabilities being served ina regular early childhood program. The PBMAS data was reviewed and discussed with the participants prior totheir documenting responses to the questions posed. Findings from focus groups, include the following:

• Focus group participants that fully understood the intent of the questions posed to them identified thetoot cause was due to not being appropriately staffed to provide the level of support required forindividual students’ success in the general education classroom.

Page 12 of 23


• Only a few of the participants could discuss initiatives that were being implemented to address theconcern. Of those who did, community outreach programs were mentioned, and one participantdiscussed the planning that takes place at a student’s ARD committee meeting. Some left it blank ormarked a question mark (?) for their response.

• Focus group participants who interpreted the question as why more students, ages 3-5, were notidentified and being served in special education, documented responses of significant concern:

o Some participants reported that prior to the current school year, they had been informed withinthe district that students younger then 1st grade had not been exposed to enough learningopportunities to determine whether they had a disability, and, thus, were not to be referred forevaluation, unless the student had a clearly obvious physical or cognitive condition.

o Other participants discussed that parents were not informed, and others that the district neededto be mote diligent in educating families about child find.

Participants that shared concerns specific to child find requirements from years prior conveyed that for the2017-2018 school year they had been informed that the district would be revising the policies specific to theevaluation of students suspected of having a disability. Participants also provided examples of how theimplementation of RtI with fidelity at their campuses this year had led to some students younger than 1st gradeage who were suspected of having a disability being referred for evaluation for special education this year.

Through the facilitation of campus focus groups, the agency team learned that Waco ISD did not have in effectpolicies, procedures, and practices to ensure that all children with disabilities who are in need of specialeducation and related services were identified, located and evaluated in prior years. This is in violation of 34Code of Federal Regulations (CFR) §300.111(a)(J)(i). The district’s failure to meet the Individuals withDisabilities Education Act’s (IDEA’s) child find requirements is a serious matter that may have resultedin denying a free and appropriate public education (FAPE) to children who are eligible for specialeducation and related services. All students who are suspected of or for whom the district shouldreasonably suspect of having a disability and the need for specially designed instruction, should bereferred for evaluation timely.

Required Actions: Implement Required Corrective Actions outlined in the section titIed Special EducationCompliance and Noncompliance (p. 19).

> STAAR Alternate 2 Participation RateA longitudinal review of PBMAS data indicates that the percent of students in Grades 3-9 served in specialeducation who were tested on STAAR Alternate 2 in all subjects applicable to the student’s grade level hasbeen above the state cut point (10.0%) for three consecutive years. A review of 2014 PBMAS data reveals thatthe percent of students who were tested on STAAR Alternate was 8.1, 1.9 percentage points below the statecut point, resulting in the assignment of a PLO. A review of the district’s 2015, 2016, and 2017 PBMAS datareveals that the percent of students in Grades 3-9 served in special education who were tested on STAARAlternate 2 in all subjects applicable to the student’s grade level has steadily increased. The 2017 PBMAS dataindicates that the percent of students who were tested on STAAR Alternate 2 in all subject areas is 6.4percentage points above the state cut point, resulting in the assignment of a PL of 2, and it is 8.3 percentagepoints above the district’s 2014 data.

In response to the agency team’s request in pre-visit questions to provide a summary of what the district’scurrent analysis of this data had revealed, the district reported that the number of students served in specialeducation who meet the eligibility criteria for STAAR Alternate 2 had increased, despite the decrease ofstudents served in special education. The district also reported that implementation of the decision-makingprocess in ARD committee meetings was in alignment with state procedures.

Through interview with leadership during the on-site review, the agency team learned that the district’s analysisof the data did not include a review of student IEPs, nor a deeper review of applicable student data, to discern ifthe data was justified or if processes and procedures required review and possible revision.

Page 13 of 23


While onsite, the agency team asked leadership to begin a student-level review of the data. Prior to exiting thedistrict, leadership reported that the review of IEPs revealed that one student previously determined to takeSTAAR Alternate 2 would now be taking STAAR with accommodations.

Required Actions:

10. Waco ISD is required to conduct an analysis of district-level and student data, to include a review of thedistricts processes and procedures for providing the PD, to include a review of the content of the PD,for the following:

a. identification of students for participation in the STAAR Alternate 2 assessment;b. understanding the participation requirements for the STAAR Alternate 2 assessment; andc. informing parents of the participation requirements, to include the student experience,

administration of and the graduation implication.d. The district will report a summary of findings to TEA.

> Discretionary Discipline RemovalsThe 2014-2015 On-Site Report of Findings documented that a significant toot cause of the poor academicprogress for students with disabilities could be attributed to the discretionary discipline removals to thedisciplinary alternative education program (DAEP), in-school suspension (ISS), and out-of-school suspension(OSS). The report also documented that implementing and enforcing consistency in discipline practices fornot only students served through special education, but all students across the district, had been a longitudinalconcern for Waco ISD and has directly impacted student performance for years.

A review of the district’s 2015 and 2016 discretionary placement PBMAS data indicated that the placement rateof students with disabilities to the DAEP was greater that the placement rate of all students, resulting in theassignment of a performance level (PL) 3 for 2015 and a PL 2 in 2016. Additionally, a review of the district’s2016 ISS and OSS discretionary placement PBMAS data indicated that the district had made requiredimprovement (RI) from the assignment of PL 3s in 2015.

A review of the district’s 2016-2017 targeted improvement plan revealed that this concern was in directcorrelation to the lack of implementation of a well-developed Rtl behavior structure that provided systematic,data-driven, research-based, sustainable behavior intervention at all three tiers. In response to the need, thedistrict implemented interventions designed to increase learning time and student performance by reducing therate of discretionary placements to ISS, OSS and the DAEP.

Prior to the 2017-2018 on-site visit, district leadership was asked to provide an update as to the status of theimplementation of the required actions outlined in the 2014-2015 On-Site Report of Findings. The requiredactions included developing a system to monitor the discretionary placements of students, evaluating systemsin place to address behavior as an instructional issue, monitoring classroom discipline during classroomwalkthroughs, evaluating the impact of the behavior interventionists in reducing the number of studentsremoved to discipline placements, and develop a plan for standardizing the structure of the campus andclassroom management strategies at all secondary campuses. The following was learned:

• The district reported they have an ongoing need for discipline data tracking tools to disaggregate andlayer pertinent data. In November of 2017, the superintendent’s cabinet approved a proposal for adistrict RtI system to support both academic and behavioral interventions. At the time of the on-site visit,the district was in the bidding process for a system which would screen, provide interventionsuggestions, progress monitor, and provide data analysis tools.

• Each campus is accountable for monitoring student removals. Student management monitors thediscretionary placements to the DAEP.

• In 2015, the district implemented RESET, a Tier 3 intervention program to support students withsignificant emotional and behavioral challenges. Eighteen of the district’s campuses implement RESET- PASS program. The function of PASS services is to target disruptive and inappropriate behaviors,identify replacement behaviors, and provide the opportunity for practice of appropriate behaviors across

Page 14 of 23

Waco Independent School District161-914, 201 7-2018

school settings. The PASS program implements an intensive monitoring schedule to allow for studentswith behavioral difficulties to participate as fully as possible in the general education environment.

• In 2017 the coordinated early intervening services (CEIS) department was placed with studentmanagement, affording coordination to occur, including district-wide assessment and action planning forPositive Behavioral Intervention and Supports (PBIS) and an instructional approach to behavior for thedisciplinary alternative school.

• For 2017-2018, a social-emotional skills course was added to the daily schedule for every studentplaced at the DAEP.

• PD provided: Conscious Discipline, Restorative Discipline and Classroom Management (Wong). AllElementary campuses use Conscious Discipline, but with widely varying amounts of training andimplementation.

• Special education behavior specialists provide support to campuses for identified students.• The district has contracted with the Baylor School of Social Work and the School of Education to

provide additional support and PD. Waco ISD staff and the Baylor School of Education will use theTiered Fidelity Inventory (TFI) to assess current campus and district PBIS implementation.

• After an analysis of provided services, a need was recognized to add social skills curriculum. Thedistrict has adopted curriculum to address the needs across grade levels: Social Thinking®, Superfiex®:A Superhero Social Thinking Curriculum, Merrell’s Strong TeensTM, Second Step and WhyTry.

The district also noted the following:

• A need for a 3-5-year plan for sustainable PD in classroom management and social-emotional supports.• ISS/OSS/DAEP placements continue to be a common response to behavior issues at many of the

district’s campuses.

As previously reported, focus group participants communicated that the behavioral and emotional needs ofstudents was a root cause for the poor performance. They also conveyed that this root cause was still an areaof concern. Some participants conveyed a need for additional itinerant staff to provide behavior consultativesupport for identified students and/or programs.

Required Actions:77. Develop and implement a sustainable 3-5-year PD plan.72. Provide TEA with a summary of the district’s TEl results and resulting action plan. Monitor

implementation of the plan and provide updates to TEA.

Special Education Annual Dropout and Graduation RateA review of 2017 PBMAS data indicate that the percent of students in Grades 7-12 served in special educationwho dropped out in a given year is 1.7 percentage points above the state cut point (1.8%), resulting in theassignment of a PL 2. A comparison between the district’s 2016 and 2017 data reflect that the dropout ratedecreased by 0.4 percentage points from 2016. Additionally, a review of 2017 PBMAS data reflect that thepercent of students served in special education who graduated with a high school diploma in four years is 13.7percentage points below the state cut point (80.0%), resulting in the assignment of a PL 2. A comparisonbetween the district’s 2016 and 2017 data reflect that the graduation rate increased by 3.0 percentage pointsfrom 2016.

The agency team learned of the following personnel, systems, and programs that support students served inspecial education graduating from high school and successfully transitioning to post-secondary options:

• Each high school campus has a College and Career Readiness (CCR) Counselor to help with transitionto higher education.

• The district’s 18+ Transition Services Center (TSC) employs six paraprofessional job coaches whoassist with transition activities in the classroom and in the community. The district currently has 17community business partner sites.

• Transition fairs are held each year to connect students and their families to resources that help thembuild successful lives after high school.

Page 15 of 23

Waco Independent School District161-914, 201 7-2018

In 2015, a special education social worker was hired to address the unique needs of students andfamilies through social support services. Services include, counseling, connecting families with vitalagencies and providing healthy relationship and self-advocacy training, and providing training webinarsthroughout the year.

• For the 201 6-2017 school year, the district added a special education teacher to the staff at the BrazosHigh School credit recovery center.

• School attendance officers monitor attendance and work with staff and families to keep students inschool.

• Person-centered planning, an on-going problem-solving process that is used to support persons withdisabilities plan for their future is implemented for identified students.

• The district also collaborates with agencies and community programs to meet the needs of students:Texas Workforce Solutions-Vocational Rehabilitation Services (TWS-VRS), Communities in Schools(CIS), Heart of Texas Region MHMR Center, and the Health and Human Services Commission (HHSC),along with others.

o In the summer of 2017, the district launched a new program, Summer Earn and Learn, incollaboration with WJS-VRS and Communities in Schools (CIS) to assist students inestablishing employability skills.

o The district is also collaborating with TWS-VRS to develop, Start 2 Finish, a program for highschool age students that will provide a series of Pre-ETS (Employment Transition Services)trainings that alternate job coaching sessions at community businesses. It is projected to beginin the fall of 2018 and will continue during extended school year (ESY) sessions to provide forstudents who have less flexibility.

Campus focus group participants at secondary campuses visited were provided the opportunity to share withthe agency team the systems and programs that the district implements to support students served throughspecial education graduating from high school in four years, as well as dropout recovery efforts. Findings fromfocus groups, include the following:

• A high number of the middle school focus group participants communicated that they were unaware ofany programs or supports that were available to assist students served through special education insuccessfully graduating from high school. Those that communicated that they were aware of systemsand supports discussed the credit recovery program availabte at Brazos High School, a few mentionedtutoring programs at their campus, one discussed a recent meeting in which students were informed ofoptions available to them in high school, two participants mentioned the AVID program, a couple talkedabout the development of transition plans at ARD committee meetings and the 18+ program, and oneparticipant mentioned that they had a CIS liaison, but that they were not sure if they supported studentsserved in special education. Additionally, two participants noted the PASS (Positive Approach toStudent Success) program as one of the supports for students with emotional and behavioral issues.

• An equally high number of the high school group participants also communicated that they wereunaware of supports or programs that were available to assist students served through specialeducation in successfully graduating from high school. Similar to the middle school focus groupparticipants’ responses, some discussed credit recovery as an option along with extended school year(ESY), and a few noted the role of the ARD committee.

The agency team communicated to district leadership the concern of secondary campus staff at the campusesvisited being largely unaware of the systems and supports that may be accessed to support students setvedthrough special education graduating from high school in four years.

District leadership reported prior to the agency team being onsite in February that the district did not have aformal dropout recovery plan. The agency team learned that the district does address dropout preventionthrough implementation of the McLennan County Uniform Truancy policy and contracted services with CISwhich are individualized to meet the needs of students and families. March 9, 2018, post the TEA PBM on-sitevisit, the district submitted as required due to the high dropout rate, a dropout recovery plan that describes howthe district will use the compensatory education and the high school allotments for the implementation of

Page 16 of 23


research-based dropout prevention strategies. The submitted plan fulfills the requirements outlined in TEC§29.918(d).

Required Actions:

13. Implement the district’s dropout prevention plan; track student data and monitor and evaluate progress;Revise/redesign as indicated. Additionally, develop and implement a system/process that insures thatinstructional and support staff at middle and high school campuses are informed of the systems andsupports that are available to students served through special education in successfully graduating fromhigh school.

> Special Education Program Stage 4 Intervention RequirementDue to the district’s designated 2016-2017 stage 4 for the special education program last year, an internalcompliance review was required of 75 students. Based on a review of special education PBMAS indicator data,Waco ISD was required to review student-specific data for all nine areas of investigation: properly constitutedARD committee meetings, IEP development and implementation, participation in state assessments,certified/highly qualified staff, commensurate school day, LRE, transition services, current evaluation, andbehavior/discipline. The district submitted the required Compliance Review Summary (CR6), February 10,2017 indicating completion of the requirement. The CRS documented that no noncompliance was identifiedduring the review of the 75 student eligibility folders.

As previously documented, for 201 7-2018, the district’s special education program was assigned a stage 4 ofintervention. The Division of School Improvement’s Guidance for Local Education Agencies Participating inPerformance-Based Monitoring Analysis System Interventions documents in Appendix A that districts assigneda stage 4 that were required to conduct an internal compliance review and submit a CR8 in 2016-2017 werenot required to conduct a review in 2017-2018. However, through interview with district leadership during the201 7-2018 on-site review, the agency team learned that there was no evidence or documentation to supportthat the required 2016-2017 internal special education compliance review had been conducted as required.The agency team found that the district did not conduct a purposeful review of student eligibilityfolders and local student and district records to identify any potential noncompliance that may havebeen contributing specific to the deficient performance of students served in special education andother program concerns as outlined in the Division of School Improvement’s Guidance for LocalEducation Agencies Participating in Performance-Based Monitoring Analysis System Interventions.

Required Actions:

14. The Waco lSD is required to fulfill the 2016-2017 Special Education Program Stage 4 interventionrequirement to conduct the internal compliance review of 75 students for all nine areas of investigation:properly constituted ARD committee meetings, IEP development and implementation, participation instate assessments, certified/highly qualified staff commensurate school day, LRE, transition services,current evaluation, and behavior/discipline. The district will report a summary of findings to the agency.

> Special Education Compliance and NoncomplianceA system-wide review of 20 students’ lEPs by the agency team during the on-site review, many of whom hadnot met standard on state assessments, to include students with disabilities who reside in a residential facility(RE), revealed that the district had systems and processes in place to ensure that:

• IEPs are reviewed and revised within annual timeline.• ARD committees develop present levels of performance and functional skills (PLAAFPs), which

describe students’ strengths and weaknesses.• ARD committees considered for students with autism, to the extent practicable, whether peer-reviewed

research-based educational programming practices were needed.• ARD committees appropriately addressed, for students with an auditory impairment, the requirements in

accordance with 34 CER §300.324(a)(2)(iv); 20 United States Code 1414(d)(3)(B)(iv); TEC §29.303,§30.004.

Page 17 of 23


• ARD committees consider extended school year services for individual students.• ARD committees consider strategies, including positive behavioral interventions and supports for

students whose behaviors impede their learning or that of others.• Students have a current full individual evaluation that is not more than 3 years old.• ARD committees address all required least restrictive environment (LRE) considerations.• All general education and special education teachers, related service providers, diagnostic staff and

paraprofessionals are certified or licensed in their area of assignment.• Students who receive services through special education have an instructional day commensurate to

their peers.

The Waco ISD was found to meet state and federal requirements specific to three of nine areas ofinvestigation: LRE, commensurate school day, and certified/highly qualified staff.

A system-wide review of 20 students’ IEPs by the agency team during the on-site review identified the followingareas of noncompliance.

Properly Constituted ARD Committee Meeting:

a) A review of student eligibility folders and staff interviews indicated that, for some students, the districtdid not convene properly constituted ARD committee meetings. Specifically, parents did not participatein ARD committee meetings, and student records reflect that a RE staff member signed as the students’parent. This is in violation of 34 Code of Federal Regulations (CFR) §300.32l(a)(1) and 300.322.

IEP Development and Implementation:

b) A review of IEPs and district records revealed that, for some RE transfer students from within the state,the 30-school day permanent ARD committee meeting was not held within timeline. This is in violationof 34 CFR §300.323(e); 19 Texas Administrative Code (TAC) §89.1050(j)(1).

c) A review of student eligibility folders indicated that, for some students, there was no evidence thatmeasurable annual goals were developed based on all areas of need identified in students’ presentlevels of academic achievement and functional performances (PLAAFPs), or through evaluation. This isin violation of 34 CFR §300.320(a)(2).

d) A review of IEPs and district records and interviews with campus staff revealed that for severalstudents, in-class support was not provided in conformity with students’ IEPs. The failure to implementthe IEP as written is in violation of 34 CFR §300.17(d), 300.101, and 300.323(c)(2).

Current Evaluation:

e) A review of student records revealed that, for some students, the district did not receive informedconsent from the parent before conducting an initial evaluation. Specifically, a RE staff member signedas the student’s parent. The failure to receive informed consent from the parent is in violation of34 CFR §300.300(a)(J)(i).

Participation in State Assessment:

f) As previously documented, for students with disabilities who had not met standard on stateassessments, ARD committees had not been convened to develop intensive programs of instruction foreach assessment where the student did not meet standard. The failure to convene ARD committeesto develop intensive programs of instruction is a violation of Texas Education Code (TEC)§28.0213(e).

Page 180123


g) A review of IEPs revealed that some students had testing accommodations and there was no evidencethat ARD committees took into consideration the accommodations the students routinely received in theclassroom. This is in violation of 19 Texas Administrative Code (TAC) §101.301 3.

BehaviorlDiscipline:

h) A review of lEPs revealed that for some students, a manifestation determination had not beenconducted when a decision was made to change the placement of the students who had engaged inbehavior that violated the code of conduct of the district. This is in violation of 34 CFR §300.530(e).

Transition Services:

i) A review of IEPs revealed that, for some RE students, there was no evidence of parental input for thestudents’ transition planning when the patents were not in attendance at ARD committee meetings.This is in violation of 19 TAC §89.1055(h)(2).

This concludes the findings identified through the review of student IEPs.

Additional noncompliance was identified through the facilitation of campus focus groups:

Child Find:j) As documented in the Least Restrictive Environment (LRE): Ages 3-5 section of this report, through the

facilitation of campus focus groups, the agency team learned that Waco ISD did not have in effectpolicies, procedures, and practices to ensure that all children with disabilities who are in need of specialeducation and related services were identified, located and evaluated in prior years. The district’sfailure to meet the Individuals with Disabilities Education Act’s (IDEA’s) child find requirementsis a serious matter that may have resulted in denying a free and appropriate public education(FAPE) to children who are eligible for special education and related services. All students whoare suspected of or for whom the district should reasonably suspect of having a disability andthe need for specially designed instruction, should be referred for evaluation timely. This is inviolation of 34 Code of Federal Regulations (CFR) §300.111(a)(1)(i).

Required Corrective Actions:

15. Review, and revise as needed, all policies and procedures, including operating guidelines and practicesspecific to each identified area of noncompliance. Conduct PD to all appropriate staff on the revisedoperating guidelines and procedures for each area of identified noncompliance, to include generaleducation stakeholders and campus administrators.

16. Convene ARD committee meetings to address the noncompliance in the lEPs and determine if thenoncompliance denied students a free appropriate public education (FAPE), and considercompensatory sen/ices, as appropriate.

17. Develop and engage in self-monitoring activities, both at the campus and district levels, to ensureongoing compliance. Report findings to the agency on a routine basis.

18. Waco ISD will submit evidence to the agency, within required timeline, that both student-specific andsystemic correction has been made.

Section Il: Bilingual and English as a Second Language (BEIESL)The agency team learned that the district conducted an annual evaluation of the BE/ESL program, as requiredby 19 TAC §89.1265 and presented the findings to the board of trustees the fall of 2017. The presentation tothe board of trustees was recorded and was aired on Waco ISD’s cable channel. Additionally, the findings wereshared with the Parent Advisory Council. The concerns identified were correlated to the data reflected in the

Page 19 of 23


2017 PBMAS report, which indicated that ELLs were not as successful on the state assessments as theirEnglish-speaking peers. In response, the district implemented activities to address the concerns, including:

• providing PD that address academic vocabulary and questioning and comprehension strategies, andphonemic awareness and phonics for the district’s elementary special education teachers whichincluded ways to modify reading instruction for ELLs,

• implementing writing academies (narrative and expository writing);• conducting TELPAS preview sessions to assist teachers with authentic ways to address the four

language domains; and• providing targeted instructional support to ELLs.

Prior to the on-site visit, district review of BE/ESL staffing indicated that the district had sufficient BE/ESLteachers to meet requirement. The district hosts a job fair each year, works with local area universities to recruitteachers, and provides a stipend to all Bilingual and ESL teachers.

The district implements the transitional bilingual/early exit model at the elementary level (PK5th), servingstudents identified as LEP in both English and Spanish, or another language, and transferring the student toEnglish-only instruction, using a 90/10 framework of instruction. This model provides instruction in literacy andacademic content areas through the medium of the student’s first language, along with instruction in Englishoral and academic language development. Exiting of a student to an all-English program of instruction is tooccur no earlier than the end of Grade I or, if the student enrolls in school during or after Grade 1, no earlierthan two years or later than five years after the student enrolls in school.

The district identified implementation of both content-based and pull-out models for its ESL program. Thecontent-based program model serves ELLs in English by providing a full-time certified teacher to providesupplementary instruction for all content area instruction, and the pull-out model serves students in Englishonly, by providing a part-time teacher to provide English language arts instruction, exclusively, while the studentremains in a mainstream instructional arrangement in the remaining content areas.

Additionally, Waco ISD offers a newcomer program at both elementary and secondary levels. Newly arrivedimmigrants, asylees, refugees and their families often need an elevated level of support. To fulfill this need, thedistrict employs an ESL strategist/interventionist who:

• assists with the development of student schedules and lesson planning, and the acquisition ofresources;

• serves as an advocate, when needed; and• coordinates and facilitates parent meetings and the Parent Advisory Council meetings.

The district also has three newcomer specialists that provide direct linguistic and academic push-in or pull-outsupport, along with the ESL strategist/interventionist. Supplemental curricular interventions used include, LLI,Reading Goals for Older Readers (RIGOR), Math Explorers, and ILIT, a digital and blended literacy programthat supports the acceleration of literacy skills and language development.

English language proficiency standards (ELPS) PD was provided to all BE/ESL staff and secondary teachersreceived PD in sheltered instruction strategies. Instructional specialists review lesson plans weekly to verify thatthe ELPS are being implemented, and ELL content specialists observe instruction and provide feedback. Thedistrict reported that the ELL content specialists provide each teacher at the start of the school year with a list ofall ELLs in their classrooms, along with TELPAS scores, years in US schools data, and STAAR scores, whenapplicable. Secondary administrators receive a list of the students in need of the most support based onTELPAS results. ELL content specialists provide elementary campuses with a list of ELLS that includesstudents’ Cognitive Academic Language Proficiency (CALP) scores in both languages. The department’sbilingual evaluator also provides CALP and vocabulary scores to campuses each time a new student registersand throughout the school year as the department conducts formative oral language assessments. The agencyteam learned that the BE/ESL department outlines how to differentiate instruction based on the proficiency ofstudents. Additionally, the district translates district benchmarks and assessments to ensure that students candemonstrate content mastery in their first language, as needed. TELPAS and years in US schools’ data is usedto determine interventions and groupings. Content specialists work with teachers and students to monitor

Page 20 of 23


English language proficiency growth. Monitoring also occurs through review of BE student portfolios, and datafrom benchmark and other assessments. The district developed a flowchart that outlines the responsibilities ofthe BE/ESL department, campus principal, ELL content specialist, teacher and students in ensuring thatstudents receive targeted and intensive instruction when identified as not having met standard on stateassessments and/or not demonstrating sufficient English language proficiency growth.

As previously reported, the district developed activities designed to increase the performance of studentsserved through BE/ESL programs. However, through classroom observations, interviews with district andcampus leadership and campus focus group participants, the agency team identified that ELLs in second gradeand above were not being exited from the transitional bilingual/early exit model, instead they were being placedin a ESL program. The failure to offer students of LEP BE in kindergarten through the elementary gradesis in violation of TEC 29.053(d)(1). Additionally, the district’s 90/JO framework for instruction was not beingimplemented as designed for students served in the transitional bilingual/early exit model classrooms.

Sheltered instruction is an instructional approach that uses various strategies to ensure that grade-levelinstruction provided in English address both content and language objectives. Through sheltered instruction,students master the required essential knowledge and skills and become proficient in the English language.Specific to implementation of the district’s content-based and pull-out ESL models, the agency team noted thatsheltered instruction strategies were implemented in several of the classrooms visited, but not in all of them.The agency team identified that sheltered instruction strategies were not implemented consistently at thecampuses visited.

The district uses the web-based platform, Ellevation, to organize all ELL information and data. The provision ofPD specific to the language proficiency assessment committee (LPAC) was reported to be conducted threetimes each year. The agency team learned that LPAC chairpersons are provided with a list, to includeexamples, of what is required to be documented for each ELL. The district reported that an internal audit ofLPAC documentation was facilitated during the 201 5-2016 school year. The audit was reported to demonstratethat overall, campuses were maintaining the requited LPAC records. The district did identify a few campusesthat requited support. In response, the district implemented use of an end-of-year procedures guidancedocument that campus administrators are to indicate, by signing, that all required information has beendocumented and stored in a secure location.

The agency team reviewed 30 LPAC folders of selected students, many of who had not met the state’sassessment standards, and found the following four required documents/elements missing in some of thefolders reviewed:

• Parental consent/denial• Initial recommendations• Intensive programs of instruction (as previously documented)• LPAC minutes.

The district’s failure to maintain and provide LPAC documentation of all actions impacting the ELL inthe student’s permanent and LPAC folder is a violation of 19 TAC §89.1220. The 2014-2015 Report ofFindings documented that a review of LPAC student documentation while onsite revealed that thedocumentation of intensive program of instruction provided for students who did not perform satisfactorily onstate assessments lacked specificity, and it was difficult to know what students were to receive.

Required Actions:

19. Determine lithe transitional bilingual/early exit model is meeting the needs of the district’s ELLs.Monitor implementation of the district’s 90/10 framework of instruction model and report findings to TEA.

20. Revise the current monitoring process to ensure that the district maintains LPAC documentation of allactions impacting ELLs as required. Monitor the process for compliance and report the summaiy offindings to TEA.

Page 21 of 23


21. Implement systems and processes that ensure that sheltered instruction strategies are implemented ina consistent manner.

Section II: Career and Technical Education (CTE)A review of 2017 PBMAS data indicate performance concerns for CTE students served in special education (allEOC assessments), with LEP (science, ELA), and for CTE students who are economically disadvantaged(ELA). The 2014-2015 On-Site Report of Findings reported that more collaboration was needed to better serveCTE students with disabilities and students who were ELLs. As a result, the district was required to developstrategies and activities for increasing the collaboration of CTE, BE/ESL, and special education teachers toensure the success of students with disabilities and ELLs enrolled in CTE classes.

In addition to the previously outlined district initiatives designed to improve the rigor and relevance of instructionoccurring in classrooms, to include implementation of the Super 7 initiative, the agency team learned thefollowing:

• District level CTE, special education and BE/ESL staff meet to plan and determine PD. CTE teachersreceived PD in how to support reading in the CTE classroom.

• A bilingual specialist provides curricular support to CTE teachers through the translation of materialsand serves as a translator for non-English speaking parents.

• An accommodations manual is provided for CIE teachers.• District CTE teachers participate in a Region 12 Education Service Center (ESC) virtual CTE PLC. The

virtual meetings provide CTE teachers with the opportunity to expand their network and meet otherteachers in the region that teach their same course(s).

The agency team learned through the facilitation of campus focus groups that CTE teachers do not participatein the campus-based core content area PLCs.

Required Actions:

22. Review and evaluate processes and procedures currently in place which support the CTE teachers’access to collaborative planning, data analysis and PD in support of CTE students served in specialeducation, with LEP, and who are economically disadvantaged. Revise processes and procedures, asneeded, to meet the needs of students. Monitor implementation through continued evaluation of theprocesses and procedures, and report findings to TEA.

Section III: Next Steps

The local education agency (LEA) will:Develop the targeted improvement plan to include preliminary 2018 PBMAS data and the development andimplementation of all systems’ activities listed as required actions in this report. Submit the 2018—2019targeted improvement plan to the TEA by October 5, 2018.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. Submit the 201 7—2018targeted improvement plan with CAP to the TEA by July 10, 2018.

> 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.

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/loqon.asp.

Page 22 of 23


Instructions regarding the use of ISAM can be found on the School Improvement website at the following link:http:I/www.tea.texas.qovlsi.

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(TA C) 89. 1076, Interventions and Sanctions, 97. 1072, Residential Facility Monitoring: Determinations,Investigations, and Sanctions, and p97. 1071, Special Program Performance; Intervention Stages, andwill impact a district’s determination status as issued by the Texas Education Agency.

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 necessaryand 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 impiementedThe LEA has systems to ensure that students with disabilities are receiving all special education and relatedseivices consistent with the child’s needs; and

> The LEA conducts ARD committee meetings as necessary to ensure the provision of a free appropriatepublic education to the students in question and considers compensatory services, if appropriate to thestudents’ individual circumstances.

__________

Page 23 of 23

161-914 may23, 2018 2017-2018 formation in ......section 7.021 and 7.028 of the texas education code...

Documents