3/12/2015

TO: Larry Nyland, Superintendent

Seattle Public Schools

FROM: Gayle Pauley, Assistant Superintendent

Special Programs and Federal Accountability
RE: Consolidated Program Review (CPR) 2014-2015 Report

On 3/11/20153/12/2015, a team from the Office of Superintendent of Public Instruction (OSPI) conducted a review of
federal and state programs in which your district participates.
This report includes commendations, technical assistance, noncompliant items and actions required.

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

Program

Commendation Note

10)
Homeless

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

McKinney-Vento program in recent years. Creating a systemic approach to
homeless student identification, developing and distributing quality resources
and materials, and continuing to emphasize the importance of identification
and support through staff training are all examples of the improvements noted.
Having a designated point of contact in each building is also a best practice.
Having dedicated staffing to increase capacity for this program has made a
positive and noticeable difference.

14) Civil
Rights

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

sexual harassment training to staff and adopting a detailed sexual harassment
policy and procedure.

Technical Assistance:

Program

Technical Assistance Note

3) Title I,
C

Continue planning efforts to regionalize professional development regarding

migratory lifestyle.

6) Title
II, A

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

to be used to highly qualify elementary education teachers, which led to
many teachers in title 1 buildings being not highly qualified when the
district believed they were.

7) TBIP and
Title III

7.1: Ensure that the letter documenting parent waivers in all schools is
updated to reflect the guidance provided in
http://www2.ed.gov/about/offices/list/ocr/letters/colleague-el-201501.pdf.
7.1: If a parent refuses the annual WELPA, file the written refusal in a way
that is retrievable. 7.8: View the TBIP iGrants training for the 2015-16
school year to ensure that activities funded are allowable.

10)
Homeless

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

obvious challenge with a district of this size. 2. Building level staff do
not readily identify the use of the housing questionnaire as a means of
identifying homeless students at the building level. Additional work with
building level staff regarding the consistent use of the housing
questionnaire for every family every year should be a continued area of
focus. 3. Continue to formalize a system to determine the Title I homeless
set-aside each year, based on actual costs of services and supports for
homeless students.

11) Highly
Capable

Item 11.2 - For students who enroll in the district after the summer testing
opportunity in August, the district ID process must include procedures so
that a new enrollee has the opportunity to be identified within 3 months of
enrollment, and, if identified, be provided services during their transition
year. Item 11.3 - Parent/Legal Guardian Permission to Place notice needs to
be revised to explicitly obtain permission to place/initiate services. For
questions, contact the program supervisor for the highly capable program,
Kristina Johnstone. She may be reached at 360-725-4991.

12)
Perkins/CTE

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

and access to special population students. To the extent practicable,
members of the special populations will have equal accesses to CTE course
offerings. Locals, must provide outreach and recruitment methods to students
and parents on what CTE courses are offered. It is highly recommended that
the CTE program office coordinate with the Migrant and Bilingual offices to
present information to parents and students in an effort to increase student
enrollment and reduce barriers in CTE course classes. It is also recommended
that the district utilize local community organizations that provide direct
services to underrepresented population to enhance opportunities for
students to make the connection to future employment.

14) Civil
Rights

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

annual notification in a student handbook or similar publication must
include enough information for a person to know how to file a complaint:
what information the complaint must include, who and where the complaint
should be sent to, what happens when the district receives the complaint,
and what the district's response will include. IF the entire complaint
process is not included, the summary must also describe where the reader can
access the full complaint process. ***Revisions Necessary to Policies and
Procedures: To comply with OSPIs revised rules (effective Dec. 2014) and
recent guidance by the U.S. Department of Education Office for Civil Rights
(OCR), the district will need to update its nondiscrimination procedures
(3210P and 5010P), sexual harassment procedure (5011P), and HIB procedure
(3207P) as soon as possible. OCR has recently identified compliance concerns
regarding these procedures in other districts. Please ensure that the
district revises each of these procedures to include the requirements listed
in Chapter 392-190 WAC (www.k12.wa.us/equity/Rules.aspx) and in OCRs
guidance on Title IX and Sexual Violence (see question C-5 on page 12:

http://www2.ed.gov/about/offices/list/ocr/docs/qa-201404-title-ix.pdf) and
Harassment and Bullying
(www2.ed.gov/about/offices/list/ocr/letters/colleague-201010.pdf).
***Necessary Revisions to Student & Employee Handbooks: As the school
district updates the above procedures, student handbooks and employee
handbooks should be updated to reflect to the new policies and procedures.
Revisions should be made to topics relating to sexual harassment,
nondiscrimination procedures, and HIB. ***14.4 Sexual Harassment: We
recommend including more information in the student and handbooks on sexual
harassment and who students, parents, and employees may contact if they have
concerns or complaints. This is available in several languages at
http://www.k12.wa.us/Equity/Posters.aspx. ***14.15, Athletics: As the
district is considering how to equally accommodate the interests and
abilities of male and female student athletes, keep in mind that a lack of
resources is not appropriate reasoning for accommodating the interests of
one sex, but not the other.

Noncompliant Items:

Program

Numbe
Description
r

Actions Required

Title II, 6.1

A

Highly
Qualified
Teachers

TBIP and 7.1

Title III

Identification Submit the district's updated process for ensuring that

parents are never asked or required to waive ELL services
when they ask to attend their neighborhood school. Submit
an action plan for training enrollment and building ELL
staff on the guidance provided in the "Meeting the Needs
of EL Students Who Opt Out of EL Programs or Particular EL
Services" section of
http://www2.ed.gov/about/offices/list/ocr/letters/colleagu
e-el-201501.pdf. Submit an action plan for ensuring that
the Home Language section of the enrollment form is
completed for each student. Submit an action plan for
reviewing enrollment forms and transfer records to
identify students who potentially have been identified as
ELL in previous districts, so that the Limited English
Proficiency Application in the OSPI EDS system can be
consulted. In this way, the district will ensure
continuous enrollment of eligible students who transfer
from other districts. Submit an action plan for
maintaining current enrollment reporting for TBIP eligible
students who are under a parent waiver. These students
must be reported under program model "P", and program
enrollment must be reported annually until the student is
assessed as having reached English proficiency.

Perkins/C 12.4
TE

Special
Populations

District did not provide the 2014-15 enrollment report for

CTE courses.

Civil
Rights

Compliance
Coordinators

For each Title IX coordinator and Civil Rights

Compliance/Laws coordinator, please submit a description
of their duties and activities related to their specific
compliance roles. With these descriptions, please clearly

14.1

Following a review of all Title 1 buildings, there are

several teachers who do not appear to meet the federal HQT
requirements. Please provide a date that each of these
teachers will take appropriate test. In addition, please
provide a plan going forward that will ensure the district
will not place non-highly qualified teachers in a Title I
building.

identify who the current designated employee is. Sample

job descriptions are available at
http://www.k12.wa.us/Equity/Districts/ConsolidatedProgramR
eview.aspx.
Civil
Rights

14.2

Nondiscriminat Please submit an action plan describing how the district

ion Statement will ensure that all district and building publications
that are widely disseminated to students, parents, and
employees (including newsletters, websites, handbooks, job
announcements, and CTE materials) will include the
district's nondiscrimination statement with the current
coordinator contact information.

Civil
Rights

14.3

Discrimination (1) Please submit draft handbook language that informs

Complaint
students and parents about the discrimination complaint
Procedures
procedures. Sample handbook language is available at
http://www.k12.wa.us/Equity/Posters.aspx (translations
pending). (2) Please submit an action plan describing how
and when the district will distribute this information to
students and parents annually, such as in a student
handbook, calendar, or other publication (to be
implemented no later than beginning of the 2015-16 school
year).

Fiscal

15.5

Ranking and
Alloction

Olympic Hills Elementary over expended their 13-14 rank

order allocations. This resulted in Olympic Hills having
per pupil expenditures that were higher than the budgeted
per pupil amounts for schools with greater poverty
percentages. Submit an action plan to ensure that rank
order allocations will comply with Title I ranking and
allocating requirements.

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

Program

Monitor

Consolidated Program
Review

Phone
Number

(360) 7256100

Title I, A

Larry Fazzari, Nate Marciochi

(360) 7256100

LAP

N/A

(360) 7256100

Title I, C

Sylvia Reyna

(360) 7256147

Title I, D

N/A

(360) 7256046

Title I, G

N/A

(360) 7256097

Title II, A

Hisami Yoshida

(360) 7256340

TBIP and Title III

Alyssa Westall

(360) 725-

6147
8

Gun-Free

N/A

(360) 7256044

Rural Education

N/A

(360) 7256234

10 Homeless

Melinda Dyer

(360) 7256050

11 Highly Capable

Kristina Johnstone

(360) 7254991

12 Perkins/CTE

Phouang Hamilton

(360) 7256245

13 Private Schools

N/A

(360) 7256229

14 Civil Rights

Sarah Albertson

(360) 7256162

15 Fiscal

Jennifer Carrougher, Debra Crawford, Toni Bernethy,

Jamey Gelhar

(360) 7256104

16 OSSS

N/A

(360) 7256424

GP:ar/tm:kl
cc: , CPR Team Lead, Office of Superintendent of Public Instruction
Kevin Corrigan, Fiscal Contact, Seattle Public Schools
Min Yee, CPR Contact, Seattle Public Schools

Sylvia Reyna