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Irving Independent School District

057-912,2013-2014
Texas Education Agency
Division of Program Monitoring and Interventions
Preliminary On-site Report of Findings
Section I: Overview: Overall History & Background
The Irving Independent School District (ISO) was identified for an on-site review due to the identification of
substantial, imminent, or ongoing risks across programs monitored by the Performance-Based Monitoring
Analysis System (PBMAS), as reflected in current and/or longitudinal data. For 2013-2014, Irving ISO was staged
for interventions at stage 4 in special education; stage 3 in bilingual education/English as a second language
(BE/ESL); stage 2 in No Child Left Behind (NCLB); and stage 2 in data validation monitoring (DVM) - discipline.
The major concerns identified by the 2013 PBMAS report included:
performance of students in the BE/ESL program;
performance of students with disabilities;
performance of migrant students;
Title I, Part A diploma rate; and
special education placements in instructional settings 40/41.
In the 2013 state accountability rating system, Irving ISD and 28 campuses Met Standards but failed to meet
state standards for one or more system safeguards. Additionally, Nimitz High School (HS), Keyes Elementary
(EL), Schulze EL, Pierce Early Childhood Center, Wheeler Transitional and Development Center, and Wheeler
Transitional and Development Secondary Center were rated 1
st
Year Improvement Required (IP).
Report Topics in Section II: Findings
Systemic Integrated Issues Affecting Student Performance
> Administrative Leadership and Organization
> Curncu urn and nstruction
> Special Education Student Performance
> Least Restrictive Environment
Special Education Representation
> Special Education Non-Comphance
Bilingual Education/English as a Second Language - Student Performance
> Bilingual Education/English as a Second Language - Non-Comphance
Irving Independent School District
057-912,2013-2014
Single Program Areas
Migrant Program
Support for Improvement Required Campuses
Data Validation Monitoring - Discipline
10-11
10
11
11-12
Section II: Findings
Systemic Integrated Issues Affecting Student Performance
> Administrative Leadership and Organization
At the time of the on-site visit, the superintendent was in his third month as superintendent in the district. The
agency team learned that the superintendent's leadership team was not in place, and he was still evaluating
current staff and looking to fill vacancies. The loca! education agency's (LEA's) school board's expectations for
the superintendent were for his team to be in place within the year.
During interviews with the superintendent, the team learned that there were 27 departments housed at central
office. The superintendent shared that his challenge was to know who the central office administrators were and
to determine if they had the same focus for student success and achievement. The superintendent held monthly
meetings with the central office staff to develop the district focus. His work with the staff included developing a
plan to link central office support to campuses while still holding the campus and campus leadership
accountable.
Through the superintendent's interview, the agency team learned that the first layer of support for the IR
campuses began with the elementary and secondary division directors. The expectations were for the division
directors to be on the campuses daily walking with principals, providing instructional and non-instructional
support, and overseeing the content coordinators work and support on the campuses. The Assistant
Superintendent for Teaching and Learning conducted data walks to identify good instruction and pacing of the
curriculum in the classrooms. Also, the superintendent visited campuses weekly to see classrooms and the
principals, with more frequent visits to the IR campuses. Campus principals had a direct line of communication to
the superintendent and central office for support.
Additionally, the superintendent identified for the team some of his findings found during his first 90 days as
superintendent:
District systems were not able to keep up with the district's growth;
* There was a lack of an appropriate district focus on individual student growth and psycho-social needs;
Campuses added programs and staff to resolve problems without sustainability;
* Central office needed to ask the right questions of campus leadership;
* There was a lack of daily campus visits, which are important to program evaluation;
* There was a silo approach to support from central office to the campus level;
* The curriculum was changing yearly for the last three years; and
* The research and development team had data housed in Eduphoria but it was not used to drive
instruction.
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Irving Independent School District
057-912.2013-2014
Systemic Integrated Issues Affecting Student Performance
The agency team interviewed central office staff and learned that in recent years there had been a division
among the staff at central office. The focus was more on the adults and not on the students. There was a lack of
communication and collaboration between campuses and central office, resulting in a lack of instructional
consistency. It was reported to the team that there were a number of turnovers in central office staff with several
vacancies still unfilled at the time of the on-site visit. The team determined that the previous central office
division, lack of central office campus support, inconsistent communication, and lack of collaborative decision
making were causal factors contributing to low student performance. During the on-site visit, it was evident to the
team that the superintendent was working to build relationships, his leadership team, and create systems for
central office support for campuses.
Recommendations and Required Actions:
1. Establish a climate of trust and collaborative leadership that shares common goals and works
together to achieve the goals. Establish systems and processes for program directors and their staff
to collaborate with one another and campus principals to address needs of students identified across
program areas.
2. Continue to build the capacity of the central office staff to support campuses. Develop processes and
systems to communicate efficiently and effectively from central office to the campus level. Implement
a monitoring system to routinely evaluate the effectiveness of developed processes.
> Curriculum and Instruction
Through central office staff, campus leadership, and teacher interviews, the agency team learned that the LEA
had implemented several curriculum systems in the past. At the time of the on-site visit, the district had
contracted with the former district director of teaching and learning as an outside consultant to assist classroom
teachers and curriculum specialists in the development and writing of the curriculum. The team learned that
there was an inconsistency in the selection of teachers used in the writing of the curriculum. While some
teachers on campuses identified as IR were losing instructional time when being pulled from classrooms each
six weeks, other teachers with similar expertise on campuses identified as Met Standard were not being utilized.
The team determined the practice of pulling teachers from the IR campuses, where there was the greatest need
for quality time and instruction, was a causal factor contributing to low student performance.
The team learned that the curriculum the district was writing was standards-based. This was the first year of
implementation of the district's developed curriculum. It was a resource of scope and sequence, activities, and
accommodations for ELLs and students with disabilities. At the time of the visit, the curriculum was deployed
prior to each unit with lesson plans designed to build on the foundation and assessments to be developed in the
following year. Teachers were able to access the curriculum through Engrade, a district data source, campus
professional learning communities (PLC), department meetings, and trainings conducted by district coordinators.
District support for the curriculum varied among the campuses. The team learned some campuses received
support from the content, ESL, and special education coordinators through training and walk-throughs. On other
campuses, principals shared that they had a difficult time getting the coordinators to visit their campuses. Central
office elementary and secondary division directors visited campuses to work with principals, and the assistant
superintendent for teaching and learning conducted data walks observing best practices. In addition, central
office staff conducted peer learning data walks with teachers to observe good instruction and calibration walk-
throughs to ensure appropriate instructional pacing.
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Irving Independent School District
057-912,2013-2014
Section II: Findings
Systemic Integrated Issues Affecting Student Performance
Through the curriculum writing process, the special education department had developed a vertical and
horizontal alignment for special education modified curriculum for resource classes. To assist teachers with
understanding the district written curriculum, including the scope and sequence, the special education
department had added two special education instructional coaches in the area of math and English/language
arts. Special education instructional coaches provided training to assist special education teachers and
administrators in understanding the Texas Essential Knowledge and Skills (TEKS) curriculum and scope and
sequence. Additionally, the team learned that teacher and administrator turnover in the district had impacted the
implementation of the curriculum with fidelity. District staff shared with the team that teachers and administrators
employed by the district received their training and experience with the district and then ieft for other
opportunities in the surrounding communities.
The team learned through central office staff interviews that the district used a Unit Comparison Chart to align
curriculums from the special education resource classes with the general education programs. The chart was
used to help ensure that students with disabilities in the resource setting were receiving instruction on the same
grade level TEKS as students in the general education setting. Since the comparison chart was early in its initial
implementation, data was not available to measure the effectiveness of this resource.
Campus-level support for the curriculum varied from the academic leads that are the department chairs at the
high schools to academic specialists at the middle and elementary schools. Through a directive from central
office, department chairs taught half the day and provided instructional support to their campus the other half of
the day. No additional funding to support this position was provided, and the high school campuses had to
absorb the teaching assignment into other content area classes. The academic specialist position, which did not
have any classes, served as a new teacher mentor, modeled lessons, co-taught with teachers, assisted in the
implementation of the curriculum, and assisted in the administration of assessments.
During the district leadership team (DLT) meeting, the agency team learned that vertical and horizontal
alignment across the curriculum, alignment of the curriculum with STAAR objectives, and a completed
curriculum map were areas of concern impacting teacher instruction. The DLT felt confident teachers were
empowered to make data-driven decisions regarding instruction in the classroom and faithful implementation of
the improvement plan was ensured by campus administration. The DLT also believed, while teachers were more
aware of students' needs, true collaboration across program areas and campuses was imperative and
acknowledged the district was working toward this goal.
The agency team determined that the implementation of several curriculum approaches the last several years
with inconsistent support from central office was a causal factor contributing to low student performance. The
team recognized that new systems and support were being implemented through collaboration across program
areas as central office staff continued to work to meet the needs of the campuses.
Recommendations and Required Actions:
3. Evaluate the selection process of teachers being utilized to assist in writing the curriculum to take into
consideration the need of the campus and loss of core content instructional time for students with the
greatest need.
4. Identify needs and provide targeted professional development to offer the knowledge and skills
teachers need for using the district-developed curriculum. Implement systems for monitoring the
implementation of the training and the curriculum.
5. Evaluate support of the curriculum to ensure consistent central office support to the campus level.
Implement systems to monitor the implementation of the support.
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Irving Independent School District
057-912,2013-2014
Section !!: Findings
Systemic Integrated Issues Affecting Student Performance
6. Implement a system for vertical planning, communication, and collaboration across campuses and
program areas.
Special Education Student Performance
2013 PBMAS data on state assessments for students with disabilities indicated performance concerns on the
STAAR 3-8 and end-of-course (EOC) exams. The agency team learned through interviews with the special
education director that a causal factor contributing to poor student performance on state assessments was a lack
of rigor in developing a targeted accelerated learning/intensive program of instruction for students who were not
successful on a STAAR administration.
The LEA used the case manager model for providing support for students with disabilities. The team learned
through staff interviews that the special education teacher was assigned students to monitor. The teacher was
responsible for all relevant paper work for the student, contacting parents, and ensuring the schedule of services
was accurate.
The district has experienced an increase in the number of students with disabilities taking the STAAR Alternative
state assessment, interviews with the special education director revealed to the team that students with an
intellectual disability had remained steady; however, the district had seen an increase in the number of students
with autism. The special education director stated that with the use of the state assessment criteria document,
the district was monitoring their assessment determinations to ensure the correct assessment was provided for
each student.
Recommendations and Required Actions:
7. Evaluate the intensive programs of instruction for students with disabilities to determine if the
programs are meeting the needs of students who have not been successful on state assessments.
8. Evaluate the results of monitoring assessment determinations and provide training for staff in the use
of the state assessment criteria document, including changes for the 2014-2015 school year.
Least Restrictive Environment
The agency team learned through central office staff interviews that the LEA offered inclusion, resource, and
self-contained settings to provide academic support for students with disabilities. Staff interviews, document
reviews, and campus visits revealed to the agency team that the LEA addressed the least restrictive
environment for students with disabilities through the use of the co-teach model in the inclusion setting. New
teachers to Irving ISO received mandatory three-hour co-teach training while teachers who were returning to the
district received one-hour co-teach refresher training each year. The special education department had
developed a walk-through document to be used with the professional development appraisal system (PDAS) to
monitor the co-teaching model. The data collected from the walk-throughs indicated that 10% support strategies
for English language learners (ELL) and special education students were being observed. The special education
director reported that the data indicated the special education teacher was being used more in a support role
than a true co-teach model. The team, through interviews with principals, general and special education
teachers, and classroom observations, supports the LEA's findings.
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Irving Independent School District
057-912,2013-2014
Section II: Findings
Systemic integrated Issues Affecting Student Performance
Additionally, the LEA offered a more restrictive setting at the Wheeler Transitional and Development Center
(WTDC). The WTDC is a separate campus for students with disabilities with challenging behaviors. The center
provides support from temporary interventions to teaching the student more appropriate school behavior and
better ways of coping, as well as continuing the academic program outlined in the students' individual education
program (IEP). The LEA was in the process of transitioning the Wheeler Center from a campus or a placement
facility to a program for students with disabilities as the result of an outside review of the Transition Center in
March 2013. Key findings from the review were:
There had been an increase in the number of part-time students at WTDC;
Most of the students had emotional problems or were on the autism spectrum; however, students with
other disabilities were in attendance;
The longer a student was enrolled at WTDC, the less likely the student was to be dismissed;
Long-term placements resulted in student and parent resistance to returning to the home campus;
A multidisciplinary team considered entry and exit to WTDC with clear and appropriate pre-placement
steps specified for campuses to complete for placement consideration;
Lead principals attended entry and exit admission, review, and dismissal (ARD) committee meetings; and
Occasionally the administrator requested the exiting student be returned to another campus rather than
their assigned campus,
The review recommended the following actions:
Eliminate the practice of placing students for a short time after the development of the behavior
intervention plan (BIP);
Eliminate full-time and long-term placements for students;
Change the focus of the interventions from maintaining and remediating academic deficits to a targeted,
intense effort to change the behavior and attitudes of the students;
Consider eliminating the practice of placing 10
th
through 12
th
grade students; and
Use project-based learning as the academic context for behavior training.
Through interviews, document reviews, and classroom observations the team learned that not all of the
recommendations had been implemented. The team discovered a second administrator had been added to the
campus to strengthen the academic component. The team concluded academics were not being fully
emphasized and teachers could not speak to professional development training they received for best practices
or where the students were academically. The team did find the teachers were very well versed on the strategies
they were implementing in their classrooms to assist students with behaviors and attitudes.
The agency team was able to observe the implementation of several of the review recommendations including a
tiered system associated with the response to interventions (Rtl) for behaviors, the continuum of services for
students with challenging behaviors, and the establishment of the distinct role of WTDC in context of the
redesign continuum.
While on-site, district personnel shared with the agency team that there were plans to transition WTDC from a
campus to a program of support.
Recommendations and Required Actions:
9. Analyze the current continuum of services at all campuses for effectiveness and develop an action
plan to address the areas of need.
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Irving Independent School District
057-912,2013-2014
Section II: Findings
Systemic Integrated Issues Affecting Student Performance
10. Develop a plan for WTDC's transition from a campus to a program of support that includes how
students with disabilities' academic needs and requirements will be met.
11. Evaluate the effectiveness of the transition of the Wheeler Center from a campus to a program of
support for students with disabilities and develop a plan to address the deficiencies.
> Special Education Representation
A review of the 2013 PBMAS data indicated a disproportionate number of African-American students were
represented in special education. The agency team learned through interviews with the special education
director that the LEA was monitoring this indicator and the data had been shared with the diagnosticians. The
team determined through staff interviews and campus visits that the implementation of the Rtl process varied
from campus to campus. The Rtl for behavior was the focus for the district in the 2013-2014 school year with
each campus professional learning committee (PLC) meeting 5-6 times a year with a special education teacher
present to facilitate behavior interventions.
The agency team learned that the LEA had implemented the use of the initial referral log to ensure they met the
requirements of the new state timelines which was monitored through the special education director's office.
Further, the team learned through interviews with centra! office staff, administrators, and teachers for students
identified as ELLs and special education that there was documented collaboration in ARD committee meetings.
Through the use of an ARD agenda, principals were provided prompting questions for discussions regarding
educational and behavioral planning for students with disabilities who were also ELLs.
Recommendations and Required Actions:
12. Evaluate the LEA's behavioral Rtl process, including identification, interventions and supports, and
special education referrals for effectiveness; revise the process as needed, to include staff training,
implementation, and monitoring.
13. Review referrals of African-American students to special education. Identify the reasons students
were referred and the interventions and supports that were provided to them prior to referral. Provide
training in areas of need and monitor implementation.
> Special Education Non-Compliance
Specifically, for students receiving services in a special education class, the LEA was not documenting the
frequency and duration of that service. Additionally, for students receiving inclusion support, the special
education service was listed as an accommodation and was not clearly specified as a special education service.
The lack of specificity in the frequency, duration, and location of inclusion and related services is a
violation of 34 Code of Federal Regulations (CFR) 300.320 (a) (7).
Recommendations and Required Actions:
14. Revise policies, procedures, and operating guidelines to ensure the services, including frequency and
duration, provided to students with disabilities are documented according to federal guidelines.
15. Train staff on the policies, procedures, and operating guidelines to ensure appropriate documentation
of service frequency and duration as determined by the IEP.
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Irving Independent School District
057-912,2013-2014
Section II: Findings
Systemic Integrated Issues Affecting Student Performance
16. Convene ARD committees or conduct ARD amendments for students to document frequency,
duration, and location of special services.
17. Develop a monitoring system that includes regular folder reviews to verify that students with
disabilities are receiving their services as determined by the student's IEP,
Additionally, through staff interviews and the review of student folders and class schedules, the agency team
learned that for some students, their IEP indicated instruction in core academic subjects by a special education
teacher. The team discovered some teachers were not highly qualified in the core academic subject they were
teaching. The failure to provide special education teachers who are highly qualified in their area of
assignment is a violation of 34 CFR 300.18(d).
Recommendations and Required Actions:
18. Evaluate certifications or highly qualified status of special education teachers who teach academic
core subject areas to determine if each is highly qualified in the area of their area of assignment.
19. Develop a system to ensure that students with disabilities are provided services specified in their
lEPs by certified and, when appropriate, highly qualified staff.
20. Convene ARD committee meetings for students instructed by special education teachers who were
not highly qualified in the area of their assignment to determine if students were denied a free
appropriate public education (FARE) and to consider compensatory services, if appropriate. Track the
provision of compensatory services.
Bilingual Education/English as a Second Language Student Performance
The agency team learned through central office staff interviews that the BE/ESL program was implementing
several program models to provide instruction for ELLs. There were 15 elementary campuses using the late exit
model, 4 elementary campuses using the dual two-way model, and one elementary campus using the one-way
dual language model. The middle schools and high schools were content-based programs using the sheltered
instruction model to serve their ELLs. The staff shared with the team that campuses had changed their model of
instruction frequently in the past with little support from central office. In addition, the district was implementing
different curriculums each of the last two years. To compensate for this, the LEA established a BE task force to
review research-based programs to determine which model would best meet the district's needs. The district
was considering transitioning to a 50/50 program model with central office support.
2013 PBMAS data on state assessment for BE/ESL students indicated performance concerns on the STAAR 3-8
and EOC exams. The world language director was in her first full year in the district. She inherited a program in
which students' scores were regressing and there was a lack of written guidelines and procedures for
departmental processes. PBMAS longitudinal data reflected the LEA was a stage 3 in BE/ESL in 2013, wherein
the previous three years, the LEA was not staged. The team learned through central office staff interviews that in
an effort to address the academic low performance of ELL students, the world language department
developed guidelines and procedures;
provided campuses with targeted supplemental support;
began to have conversations with students about expectations;
conducted round table meetings with parents in the fall and spring;
conducted campus walk-throughs with the director and her staff;
presented student case studies to campus PLCs; and
provided after-school support through Journey, a career path program.
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Irving Independent School District
057-912,2013-2014
Section II: Findings
Systemic Integrated Issues Affecting Student Performance
in addition, instructional support for teachers was led by ESL teachers and academic specialists. The agency
team determined that the inconsistent implementation of a BE/ESL program model and a lack of district focus on
the BE/ESL program were causal factors contributing to low student performance.
The LEA had requested an exception and a waiver during the last two years for their BE/ESL program. Through
staff interviews, the team learned that the LEA had provided English Language Proficiency System (ELPS) and
differentiated and sheltered instruction training for teachers in an effort to remove the waivers and build staff
capacity.
Through staff interviews, the agency team learned that the LEA transitioned their ELLs between campuses by
sending a representative from the receiving campus to the LPAC of the sending campus. Grades and
interventions were exchanged and in some instances, the BE teachers looped with their students to the next
campus to minimize regression during transition.
Recommendations and Required Actions:
21, Determine the BE/ESL program model the district will implement for instructional support for ELL
students.
22, Determine, provide, and document the necessary training to implement the new BE/ESL program
model.
23, Develop and implement a system to monitor and provide feedback to campuses regarding the
program model implementation.
> Bilingual Education/English as a Second Language Non-Compliance
Through student folder reviews, the agency team found that the language proficiency assessment committee
(LPAC) records were incomplete. Documents such as the parent consent for entry into the BE/ESL program or
denial of services were missing for some students. Failure to provide in the student's permanent record
documentation of all actions impacting the English Language Learner is a violation of 19 TAG 89.1220
(I).
The director of world language showed the agency team newly developed guidelines and procedures for the
identification of ELLs and program placement. The team acknowledges that the LEA was conducting a complete
audit of the BE/ESL records, correcting any documentation noncompliance, and reviewing ELL identification
processes.
In addition, the LEA last conducted an annual BE/ESL program evaluation in 2010. Upon arrival of the new world
language director in the spring of 2013, a program evaluation had been completed and presented to the school
district board of trustees.
Recommendations and Required Actions:
24. Revise policies, procedures, and operating guidelines to ensure that the LPAC is retaining
appropriate documentation of its actions in accordance with state guidelines. Create a monitoring
system to verify implementation and provide feedback to campuses.
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Irving Independent School District
057-912,2013-2014
Section II: Findings
Systemic Integrated issues Affecting Student Performance
25. Ensure the implementation of the newly developed guidelines and procedures for identifying and
placing ELLs into the appropriate program of instruction.
26. Provide and document training for the staff on the procedures and guidelines developed, including
training for all LPAC committee members on their role and responsibilities. Develop a system to
monitor the implementation of LEA procedures and guidelines and to provide feedback to campuses
regarding the implementation.
Section II: Findings
Single Program Areas
> Migrant Program
The migrant education program (MEP) is designed to assist migrant students in overcoming the challenges of
language, mobility, and other barriers associated with a migratory lifestyle. The agency team learned through
staff interviews that migrant students must complete a yearly enrollment packet containing a family survey and
specific questions to assist the migrant program staff in determining eligibility. A local migrant recruiter conducts
face-to-face interviews with parents to also determine eligibility for the MEP.
Through staff interviews, the team discovered that during the 2012-2013 school year, approximately 100
migrant students attended Irving ISO schools, and the number of migrant students had declined to 50. The loss
of student enrollment resulted in a nearly 50 percent reduction of federal district funding to support the MEP,
and the loss of funding resulted in the loss of several staff positions throughout the district.
Based upon 2013 PBMAS data, the performance of migrant students on the STAAR grades 3-8 and EOC state
assessments fell below PBMAS standards. District staff reported to the team that the in-school migrant student
tutorial program was cut due to the loss of funding. The staff also shared that migrant students performed better
on state assessments during the 2011-2012 school year due to the in-school tutorial program focusing on the
individual needs of migrant students. At the time of the on-site visit, migrant students were offered the same
opportunities as all students to attend after-school tutorials. It was reported to the team that most migrant
students did not attend the after-school tutorials because of job responsibilities or having to take care of younger
siblings. In addition, student performance logs were maintained and used to monitor the monthly academic
progress of migrant students in previous years. Conferences were held with students failing to make academic
progress and parents were contacted. In 2013-2014 with the loss of funding and staff, student performance logs
for migrant students were only maintained during the second semester.
The agency team learned through staff interviews that the LEA had not developed district policies and
procedures for the operation of the migrant program. However, the new state and federal compliance
coordinator had begun developing policies and procedures for the consistent and supportive implementation of
the MEP.
Recommendations and Required Actions:
27. Review the current practice of after-school tutorials and the impact it has on migrant students.
Develop a plan to provide support meeting the individual needs of migrant students.
28. Develop district policies and procedures for the migrant program, provide training for the staff, and
implement a process for monitoring the program's effectiveness.
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Irving Independent School District
057-912,2013-2014
Section II: Findings
Single Program Areas
Support for improvement Required Campuses
In the 2013 state accountability rating system, Nimitz HS, Keyes Elementary EL, Schulze EL, Pierce Early
Childhood Center, Wheeler Transitional and Development Center, and Wheeler Transitional and Development
Secondary Center were rated 1
st
Year IR. While on-site, the agency team visited all seven IR campuses,
conducted teacher interviews, facilitated an IR principal meeting, and met with the campus intervention team
(CIT) and learned that the district had not made the IR campuses a priority. No additional funds, instructional
supplies, materials, nor staff were provided. IR campuses were expected to use existing campus funds
budgeted for the 2013-2014 school year for additional support. For the IR campuses, staff vacancies were a
concern. One campus reported they were able to complete their staff in late August, prior to the start of school.
Furthermore, with enrollment projections changing slightly for 2014-2015, the current human resource plan
called for cutting four to five core content teachers from a campus already struggling academically and rated IR.
The team concluded that the district lacked a full understanding of the needs and resources needed for
prioritizing and providing support for a campus rated IR.
Recommendations and Required Actions:
29. Develop and implement a plan to prioritize, support, staff, and fund resources needed to assist IR
campuses to improve student performance.
Section II: Findings
Data Validation Monitoring - Discipline
Although the LEA documented an extensive administrative training for student discipline coding prior to and
during the 2012-2013 school year, agency team interviews with administration and a review of 2012-2013
student discipline documentation revealed that written procedures were inadequate to ensure accurate student
discipline coding.
The agency team reviewed student files related to the following 2012-2013 student discipline data validation
indicators;
#1: Length Of Out-Of-School Suspension;
#2: Length Of In-School Suspension; and
#7 African-American Discretionary DAEP Placements.
Data reviewed for the school year 2012-2013 was submitted as a part of the PEIMS Summer Submission 2013.
Of the files reviewed, two were coded correctly based on documentation maintained by the district, and two
were not coded appropriately based on a lack of documentation.
Additionally, the team reviewed folders for 2013-2014 with the LEA staff that were in electronic format, for which
the LEA could not produce documents following the PEIMS Data Standards. Errors noted included:
Inappropriate disciplinary code assignments based on Appendix E of the PEIMS Data Standards;
Insufficient discipline record retention;
Inconsistencies in discipline documentation standards at the campus level; and
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Irving Independent School District
057-912,2013-2014
Section II: Findings
Data validation Monitoring - Discipline
Missing dates and signatures on electronic documents, discipline referrals, and administrative
findings/assignment documentation.
Recommendations and Required Actions:
30. Review and revise current discipline procedures and submit a written procedures manual which
includes documentation standards and consequences for noncompliance with PEIMS Data
Standards and TEC Chapter 37.
31. Review current data programs to ensure auditable documents that include electronic signatures with
time and date stamps.
32. Develop a process implemented at the campus level to ensure and validate that discipline coding is
supported by appropriate documentation. Develop a system to monitor the implementation of this
process at the campus level and share feedback with campus administration.
33. Conduct an analysis to determine which campuses are contributing to the disproportionate African-
American discretionary DAEP placements and develop an action plan of support to those campuses.
34. Develop a DVM corrective action plan (CAP) to address coding and or procedures noted in this
report and submit validation of completion of each activity.
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Irving Independent School District
057-912,2013-2014
Section 111: Next Steps
The LEA will:
> Revise the targeted improvement plan to include the development and implementation of all systems
activities listed as recommendations and required actions in this report as well as 2014 state accountability
ratings and PBMAS received in August;
> Develop a corrective action plan (CAP) that outlines steps and procedures the LEA will take to correct all
findings of noncompliance, which are indicated in the report with bolded print;
> Inform the board of trustees in a public meeting of the noncompliance with statutory requirements identified
in 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 the
district. This reporting will consist of written, as well as oral descriptions of the data and implementation of
activities; and
> Submit the targeted improvement plan with CAP to the TEA by November 21, 2014.
The targeted improvement plan and progress reports must be submitted through the Intervention Stage and
Activity Manager (ISAM) application within the Texas Education Agency Secure Environment (TEASE)
according to the due dates listed above. The TEASE link is; https://sequin.tea.state.tx.us/apps/iogon.asp.
Instructions regarding the use of ISAM can be found under the How Do I section of the monitoring link on the
Program Monitoring and interventions website at the following link: http://www.tea.state.tx.us/pmi.
Required Corrective Actions for Noncompliance Findings:
The LEA is required to correct any noncompliance finding as soon as possible, but in no case may the
correction take longer than one calendar year from the date of notification of noncompliance. Failure to
correct noncompliance within required timelines will result in elevated interventions or sanctions as
referenced in Texas Education Code (TEC), Chapter 39, Subchapter E; 19 Texas Administrative Code
(TAG) 89.1076, Interventions and Sanctions, 97.1072, Residential Facility Monitoring: Determinations,
Investigations, and Sanctions.
Corrective actions must be completed within one year of receipt of findings.
The agency also will require documentation verifying that:
> Policies and procedures, including operating guidelines and practices, have been changed, as necessary,
and implemented as written;
> The LEA has notified the public of any changes to policies and procedures, including operating guidelines
and practices, related to disproportionality, discipline, and/or child find issues, as appropriate to the LEA;
> Decision-making frameworks/guidelines have been implemented;
> The LEA has systems to ensure that students with disabilities are receiving all special education and related
services consistent with the child's needs; and
> The LEA conducts ARD committee meetings as necessary to ensure the provision of a free appropriate
public education to the students in question and considers compensatory services, if appropriate to the
students' individual circumstances.
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