Central High School Building
                            359 North West Street
                                  P.O. Box 771
                           Jackson, MS 39205-0771
                            Phone (601) 359-3498
                              Fax (601) 359-1829

                                August 12, 2004
                                 Revised Date

                        Focused Monitoring Report
                  on Services for Students with Disabilities

                     Mound Bayou Public School District

                               William Crockett
                           Superintendent of Schools

                              Linda B. Robinson
                         Director of Special Education

Approved by:

Dr. Melody Bounds
State Director of Special Education

                              Mound Bayou Public School District
                            Summary of Focused Monitoring Process

      Statutory Authority for State Department of Education Monitoring
The Individuals with Disabilities Education Act (IDEA) provides federal funds to
assist states in educating children with disabilities and requires each participating
state to ensure that school districts and other publicly funded educational
agencies in the State comply with the requirements of the IDEA and its
implementing regulations. Mississippi State law requires local school districts to
provide appropriate special education and related services, and requires the
Mississippi Department of Education (MDE) to establish, monitor, and enforce
regulations governing special education programs in the Mississippi public
schools and in all institutions wholly or partly supported by the State. The MDE
has adopted regulations implementing those requirements. The Office of Special
Education (OSE) of the Mississippi Department of Education (MDE) supervises
and conducts the focused monitoring process in furtherance of the State’s
obligation under the IDEA and Mississippi law.

                                             The Monitoring Team

The MDE authorized the following team of monitors and consultants to conduct
on-site monitoring in the Mound Bayou Public School District from March 29,
2004 to March 31, 2004:

                                                 Team Leader
                                              Diana P. Rotenberry

                    Team Members                                                   Team Consultants
                    Robert Jenkins                                                 Linda Greaux
                    Marie Lucas                                                    Velva Haynes

1. The IDEA regulations require the State educational agency to ensure that the federal regulatory requirements are
carried out statewide and that all educational programs for children with disabilities in the State are under the general
supervision of the State educational agency and meet the state’s educational standards. 34 CFR Sec. 300.600
2. The Mississippi Department of Education (MDE) is authorized under 37-23-5 of Mississippi Code 1972, to “foster,
inspect, approve and administer a program of education for exceptional children.” It is the responsibility of the Mississippi
Department of Education, Office of Special Education (OSE) to ensure implementation of the mandates of federal and
State laws and regulations regarding the provision of programs, services, and protections to all Mississippi children and
youths with disabilities.
3. The current State special education regulations for Program Improvement Monitoring are included in the Mississippi
Department of Education (MDE) Policies and Procedures Regarding Children with Disabilities under the Individuals with
Disabilities Education Act Amendments of 1997 (IDEA 97), Attachment Z

         Introduction: Mississippi Program Improvement Monitoring

Mississippi Program Improvement Monitoring (MPIM) is a new way of
determining compliance with federal and State special education laws and
regulations while also addressing educational benefit. MPIM emphasizes two
major areas of the Individuals with Disabilities Education Act (IDEA) of 1997:
access to the general curriculum and improved educational performance for
children with disabilities.

While MPIM includes some aspects of traditional monitoring of public schools,
such as on-site visits, file reviews, interviews with staff members, students and
parents, and corrective actions to address findings of noncompliance, it differs
from traditional in other aspects:

   MPIM uses information from the Mississippi Student Information System
    (MSIS) to select districts with wide variances from the state averages on key
    indicators for students with disabilities. These variances cover the most
    important compliance issues, as well as measurable aspects of educational
    Monitoring visits and corrective actions focus on the specific processes
    related to the indicators selected from the District Data Profiles within each
    Enrollment Group. The focus monitoring site-visits are geared toward helping
    districts improve their performance on those specific indicators.

In 2003, a group of stakeholders identified three key focus areas for Mississippi
school districts. The focus areas are:

   Least Restrictive Environment (LRE);
   Disproportionality in the over-identification of Specific Learning Disability
    (SLD); and
   Under-identification of Emotional Disability (EmD).

The methodology and rankings for the selection of districts for focused
monitoring are explained on the Mississippi Department of Education, Office of
Special Education website at www.mde.k12.ms.us/special_education. The site
visit report can be viewed on the Office of Special Education website as well.

                                Selection Criteria

The Mound Bayou Public School District was selected for focused monitoring
during the 2003-04 school year under the following category: Least Restrictive
Environment. Data from the MDE, MSIS Accountability Data System showed
100% of students with disabilities are served outside of the general education
environment for more than 21% of the school day as compared to the State
average of 44.103%.

                                 Additional Data

Other district data reviewed and analyzed prior to or during the on-site visit
included the following:

          Demographic Data from the 2000 Census;
          District Special Education Profile-Yr. 2002-2003;
          Mississippi Report Card- Yr. 2001-2002;
          Mississippi Student Information System (MSIS) Table 3;
          Special Education Post-cutoff Report by Teacher - Yr. 2002-2003;
          Parent Complaints Filed with MDE - Yr. 2002-2003;
          Parent Focus Meeting, March 29, 2004;
          Parent Surveys and Parent Interviews;
          School Discipline Records;
          Administrator/Principal Interviews;
          Special Education Teacher Interviews;
          General Education Teacher Interviews;
          Related Staff Interviews;
          Individualized Education Programs;
          Student Schedules;
          Teacher Schedules;
          Class Rolls; and
          Observations in General and Special Education Classrooms.

                       District Demographic Information

The Mound Bayou School District includes one (1) elementary school and one
(1) high school. The district serves approximately 716 students including 100
students with disabilities. The district employs 64 teachers, of whom eight (8) are
special education teachers, and one (1) is a related service staff to support
students with disabilities. The ethnic makeup of the district is 100% Black. 100%
of students receive free breakfast and lunch.

                              Dates and Sites Visited

   March 29, 2004        Parent Meeting, I.T. Montgomery Elementary School
   March 30, 2004        I.T. Montgomery, John F. Kennedy High, Central Office
   March 31, 2004        I.T. Montgomery, John F. Kennedy High, Central Office

               Team Strategies, Methods, and Activities On-Site

In conducting the on-site visit, the team carried out the following activities:

   Received input from seven (7) parents during Parent Focus Group meeting;
   Reviewed 81 student records which included IEPs, evaluation reports, report
    cards, discipline records, and class schedules;
   Reviewed district professional development activities for 2002-2003, 2003-
   Interviewed three (3) district administrators and program coordinators;
   Interviewed 13 school site personnel in two (2) schools, including regular
    educators, special educators, and principals;
   Conducted on-site interviews with ten (10) parents; and
   Observed the provision of services to students with disabilities in special
    education and regular education classrooms.

        Methodology for Identification of Findings of Noncompliance

The team gathered information from the following sources: (1) parent interviews,
(2) staff interviews, and (3) record reviews which included cumulative student
records, Teacher Support Team (TST) information, standardized test scores,
Local Survey Committee (LSC) documentation, and other documentation
provided by the district. Systemic noncompliance was established when
evidence was gathered from at least two (2) of the above mentioned sources.

A team leader compiled the monitoring team’s on-site findings and submitted
them for review to the MDE, Office of Special Education. A draft of this report
was prepared by the MDE focused monitoring team and has been reviewed,
revised, and approved by the MDE Office of Special Education.

                         Summary of On-Site Findings

The monitoring team found systemic noncompliance in the following areas:

1. Policies and procedures are not adopted and/or followed by the district to
   ensure Least Restrictive Environment requirements are implemented for
   students with disabilities, (i.e., the IEP committee is not determining the
   educational placement of students with disabilities).

2. Sufficient accommodations, modifications and supplementary aids and
   services are not in place to allow students to be successful in the general
   education curriculum.

These findings and supporting evidence are discussed in the section below and
on the pages that follow. The report concludes with a framework for the district
to propose an improvement plan to address the identified areas of

                      ON-SITE FINDING #1
Area of Concern: The IEP Committee Does Not
Determine Educational Placement.

Description of Findings of Noncompliance:

The evidence demonstrates that there is no clear understanding throughout the
district on policies and procedures for LRE and each person’s responsibility for
implementation of LRE requirements. There was a general agreement that
placement decisions are made by one of the following people: the counselor, the
principal, the special education teacher, or the program developer. District-wide,
the placement is incorrectly perceived to be a responsibility of one person,
instead of the IEP committee.

District-wide, there was not a consensus as to the specific individual serving in
the capacity of an agency representative, or the designee in his/her absence.
Generally, regular education teachers are not involved in the actual development
of the IEP or, if attending, had no specific role in determining placement in the
least restrictive environment. One regular education teacher stated “the special
education teacher handles everything.” Parents have limited understanding of
the IEP and the impact on LRE.

Applicable Regulation(s):

Section 330.555

Supporting Evidence:

Interviews with special education teachers confirmed that this change usually
occurs in the counselor’s office and is usually based on courses/class periods
being “full”.

Seven (7) of ten (10) parents interviewed, stated they did not actively participate
in the IEP meeting and were not clear on their role at the IEP meeting.

Seven (7) of thirteen (13) staff members interviewed, stated the most common
reason special education students were unsuccessful in the regular education
classroom was the students’ academic levels.

Comments and Discussion:

Although there was a staff development session on Policies of Special Education
listed on the current staff development plan, it is evident that there is a lack of
awareness of the policies and procedures for implementing the Least Restrictive
Environment for children with disabilities. Neither is there a well-defined
understanding by the staff of who has responsibility for ensuring LRE for students
with disabilities. It was obvious the building level personnel believed that special
education is “handled” by the district program developer. The district should
undertake additional training specific to this area.

                     ON-SITE FINDING #2
Area of Concern: Accommodations, Modifications,
Supplementary Aids and Services are not

Description of Findings of Noncompliance:

The evidence demonstrates that accommodations, modifications, and
supplementary aids and services are not being implemented and/or provided to
students with disabilities, which would allow students to be successful in the
regular education classroom.

Assistive Technology was not addressed on any of the IEPs reviewed by the
team members, although two (2) parents indicated at the Parent Focus Group
meeting that devices were needed in order for their children to be successful.

Applicable Regulation(s):

34 CFR 300.500
34 CFR 300.550b
34 CFR 300.355
34 CFR 300.556

Supporting Evidence:

Seven (7) parents stated they didn’t understand the IEP meeting procedures and
were not asked for input on accommodations, modifications, or supplementary
aids and services. One (1) parent stated that she later purchased a special set
of phonics tapes for her daughter to use in the English class but was told by the
regular teacher “this would be an unfair advantage”. The parent of a high school
student stated transition services for her daughter did not include any preparation
for the SAT or any services for her child to access the next level after high school

Two (2) parents stated that assistive technology devices and related services
such as Occupational Therapy (OT) and Physical Therapy (PT) were needed, but
were not being provided by the district. One (1) parent stated that she took her
child for OT/PT at a medical facility but was not reimbursed by the school district.
Nine (9) of thirteen (13) IEPs reviewed at the elementary school did not address
the accommodations and modifications section. One (1) elementary teacher
interviewed, stated she did provide accommodations such as reduced class
work; however, this was not listed on the IEP and had not been discussed at the

meeting. Two (2) of three (3) regular education teachers interviewed, stated that
accommodations and modifications were rarely addressed at IEP meetings.

Thirteen (13) of thirteen (13) IEPs reviewed at the elementary school did not list
any supplementary aids and services as being needed. The only related service
listed on any IEP is speech therapy.

Comments and Discussion:

Although there is strong evidence that a variety of staff development activities
have been pursued during the past two years, it is evident that all district
personnel would benefit from professional development specifically focused on
the area of least restrictive environment. This training should be ongoing and
must include all aspects of what is required in order to support the special
education student in achieving success in the general curriculum. In addition, the
district should undertake training for parents, especially on the development of
the IEP.
The district should immediately address the issue of the student with the access
problem at the high school.


Description of Findings:

   Two (2) IEPs indicated that placement decisions were administratively
    changed after the IEP meeting without convening the IEP committee or
    providing notice to parents.

   There was very little evidence that Functional Behavioral Assessments (FBA)
    were conducted for students, including those at the secondary level who had
    been placed at the Alternative School for various disciplinary infractions.

   Thirteen (13) of thirteen (13) IEPs reviewed at the high school did not
    completely address the transition services needed for students with
    disabilities to be successful in the least restrictive environment. Six (6) of
    eleven (11) student progress reports reviewed indicated the students were
    failing regular education courses, yet there was no IEP review to address this

   According to one (1) teacher interviewed, one (1) high school student is being
    served on a homebound basis due to a problem with his wheelchair. He has
    been removed from his least restrictive environment for several months.

   Two (2) of two (2) students who had been placed at the Alternative School did
    not receive a functional behavioral assessment at any time during the
    disciplinary process.

   Although these are sufficient opportunities for secondary-level students with
    disabilities to engage in nonacademic classes, the elementary school
    students are not afforded the same opportunities due to the lack of resources
    for additional personnel.

   The self-contained classes at the elementary and high school are not
    addressing the needs of the students.

         Additional Professional Concerns

The MDE/OSE strongly encourages the district to examine the following
concerns and take steps to resolve issues as appropriate:

   Attention should be given to ensuring that IEPs and individual student
    schedules are reflective of each other.

   Several students with disabilities are receiving additional support at private
    programs after school in order to pass their courses.

   There is a discrepancy between the data reported to MSIS and the Student
    Schedule Package (SASSY) used by the district. This area of concern needs
    to be resolved in order to appropriately determine LRE. For instance, all
    students receiving speech therapy services are listed as being “resourced”
    rather than “regular” on the MSIS data sheet, yet the school records indicate
    that these students are actually in regular education classes all day except for
    two (2) 30 minute sessions each week.

                                         Improvement Plan
                                    For Students with Disabilities
                                               In the
                                        Mound Bayou Public
                                           School District

                                                                                     Required Evidence of
Area of Noncompliance    Activities and Resources                  Time-line
                        (The district will propose      (The district will propose
                        improvement plan activities.)   timeline.)

                        (The district will propose      (The district will propose
                        improvement plan activities.)   timeline.)


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