Report of the Quality Assurance Review Team for Riverdale High School



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Report of the Quality Assurance Review Team for Riverdale High School Thomas V Nolan, Principal Review Dates: 03/12/2008-03/13/2008 AdvancED is the unified organization of the North Central Association Commission on Accreditation and School Improvement (NCA CASI), Southern Association of Colleges and Schools Council on Accreditation and School Improvement (SACS CASI), and National Study of School Evaluation (NSSE)

Quality Assurance Review Report Page 2 of 16 Quality Assurance Review Report Contents About AdvancED and NCA CASI/SACS CASI 3 Introduction to the Quality Assurance Review 4 Summary of Findings 5 Commendations 5 Recommendations 6 Next Steps 6 Standards for Accreditation 8 Standard 1 Vision and Purpose 8 Standard 2 Governance and Leadership 9 Standard 3 Teaching and Learning 9 Standard 4 Documenting and Using Results 10 Standard 5 Resource and Support Systems 12 Standard 6 Stakeholder Communications and Relationships 13 Standard 7 Commitment to Continuous Improvement 14 Conclusion 15 Appendix 16 Quality Assurance Review Team Members 16 AdvancED Standards for Quality Schools 16

About AdvancED and NCA CASI/SACS CASI Background Founded in 1895, the North Central Association Commission on Accreditation and School Improvement (NCA CASI) and the Southern Association of Colleges and Schools Council on Accreditation and School Improvement (SACS CASI) accredit public and private schools and districts in 30 states, the Navajo Nation, Latin America, and the Department of Defense Schools worldwide In 2006, NCA CASI, SACS CASI, and the research and development arm of the accrediting associations, the National Study of School Evaluation, unified to form AdvancED Dedicated to advancing excellence in education, AdvancED provides accreditation, research, and professional services to 23,000 schools in 65 countries, serving 15 million students NCA CASI and SACS CASI serve as accreditation divisions of AdvancED Through AdvancED, NCA CASI and SACS CASI have defined shared, research-based accreditation standards that cross state, regional, and national boundaries Accompanying these standards is a unified accreditation process designed to help schools continuously improve The Accreditation Process To earn and maintain accreditation from NCA CASI or SACS CASI, schools must: 1) Meet the AdvancED Standards for Quality Schools Schools demonstrate adherence to the seven AdvancED standards which describe the quality practices and conditions that research and best practice indicate are necessary for schools to achieve quality student performance and organizational effectiveness 2) Engage in continuous improvement Schools implement a continuous improvement process that articulates the vision and purpose the school is pursuing (vision); maintains a rich and current description of students, their performance, school effectiveness, and the school community (profile); employs goals and interventions to improve student performance (plan); and documents and uses the results to inform what happens next (results) 3) Demonstrate quality assurance through internal and external review Schools engage in a planned process of ongoing internal review and self-assessment In addition, schools host an external quality assurance review team once every five years The team evaluates the school's adherence to the AdvancED quality standards, assesses the efficacy of the school's improvement process and methods for quality assurance, and provides commendations and recommendations to help the school improve The team provides an oral exit report to the school and a written report detailing the team's recommendations The school acts on the team's recommendations and submits a progress report two years following the review NCA CASI and SACS CASI accreditation engages the entire school community in a continuous process of self-evaluation and improvement The overall aim is to help schools be the best they can be on behalf of the students they serve Quality Assurance Review Report Page 3 of 16

Introduction to the Quality Assurance Review Purpose The purpose of the Quality Assurance Review is to: 1 2 3 4 Evaluate the school's adherence to the AdvancED quality standards Assess the efficacy of the school's improvement process and methods for quality assurance Identify commendations and recommendations to improve the school Make an accreditation recommendation for review by the national AdvancED Accreditation Commission A key aim of the quality assurance review is to verify that the school is operating with institutional integrity - that it is fulfilling its vision and mission for its students School Preparation To prepare for the Quality Assurance Review, the school community engages in an in-depth self assessment of each of the seven AdvancED standards The school identifies and describes the evidence that demonstrates that it is meeting each standard Through this internal review, the school examines how its systems and processes contribute to student performance and school effectiveness Summary of Team Activities The Quality Assurance Review team is led by an AdvancED certified team chair and comprised of professionals from outside the school The team reviews the findings of the school's internal self-assessment, conducts interviews with representative groups of stakeholders, reviews student performance data and other documentation provided by the school, and observes practices and daily operations The team engages in professional deliberations to reach consensus on the school's adherence to the standards for accreditation The team provides an oral exit report and prepares a written Quality Assurance Review Team Report designed to help the school improve The Quality Assurance Review Team Report Following the visit, the review team completes the Quality Assurance Review report After review by a nationally-trained reader, the report is submitted to the school The report contains commendations and recommendations for improvement Using the Report - Acting on the Recommendations The school uses the report to guide its improvement efforts The school is held accountable for addressing the recommendations identified in the report The NCA CASI/SACS CASI State Office is available to assist schools in addressing the recommendations Two years following the Quality Assurance Review team visit, the school must submit a progress report detailing the actions and progress the school has made on the team's recommendations The report is reviewed at the state and national level to ensure the school is addressing the recommendations Accreditation Recommendation The Quality Assurance Review team uses the findings from the onsite visit to make an accreditation recommendation that is reviewed at the state level and by the national AdvancED Accreditation Commission Accreditation is granted by the AdvancED Accreditation Commission and communicated to the school following action from the commission Quality Assurance Review Report Page 4 of 16

Summary of Findings A Quality Assurance Review Team representing the Southern Association of Colleges and Schools Council on Accreditation and School Improvement (SACS CASI), a division of AdvancED, visited the Riverdale High School in Murfreesboro, Tennessee on 03/12/2008-03/13/2008 During the visit, members of the Quality Assurance Review Team interviewed the Principal, 3 members of the administrative team, 20 students, 7 parents, and 30 teachers In addition, team members of Community 6 were interviewed The team also reviewed documents, student performance data, and other artifacts provided by the school Specifically, the team examined the school's systems and processes in relation to the seven AdvancED standards: Vision and Purpose Governance and Leadership Teaching and Learning Documenting and Using Results Resource and Support Systems Stakeholder Communications and Relationships Commitment to Continuous Improvement The AdvancED standards focus on systems within a school and systematic methods of attaining high student performance and organizational effectiveness The power of the standards lies in the connections and linkages between and among the standards The Quality Assurance Review team used the AdvancED standards to guide its review of the school, looking not only for adherence to individual standards, but also for how the school functions as a whole and embodies the practices and characteristics of a quality school Through its examination of the school's adherence to the standards, the Quality Assurance Review team identified the following commendations and recommendations Commendations The Quality Assurance Review team commends the school for the following strengths and accomplishments While additional strengths are noted in the detailed review of each standard that appears later in this report, the commendations listed below are the strengths that the team believes are most deserving of being highlighted Riverdale and its administration are dedicated to student achievement and continuous improvement The administration has set high expectations for the students, both academically and socially The school utilizes Profesisonal Learning Communities (PLC), department meetings, and the School Leadership Team to constantly monitor and assess student learning; the array and uniqueness of the course offerings appeals to many and varied interests; and the numerous opportunities for student involvement in clubs and organizations makes them take pride in their school Quality Assurance Review Report Page 5 of 16

A school's dedication to student achievement and continuous improvement indicates the school's commitment to students reaching their highest potential Riverdale has an extremely large base of support within the community Support is evidenced through the PTO which has 260 members, numerous booster clubs supporting the school's various programs, and the Community Advisory Committee All of the interviewed groups mentioned the strong community support and attendance at athletic events The amount of stakeholder involvement creates a large base of community support for the school Recommendations In addition to the commendations, the Quality Assurance Review team identified the following recommendations for improvement The team focused its recommendations on those areas that, if addressed, will have the greatest impact on improving student performance and overall school effectiveness The school will be held accountable for making progress on each of the recommendations noted in this section Two years following this review, the school will be asked to submit a progress report on these recommendations Provide an additional assistant principal and technological support for the school The large number of students and the school's continued growth creates undue burdens on the administration The addition of a Freshman Academy next year will necessitate the need for additional technological support for that building and classrooms By adding additional assistant principal and technology support all students will receive equal services Restructure the Guidance Department to meet the needs of the students Interviews with parents and students revealed that the Guidance Department does not provide adequate information to students regarding college application requirements and scholarship information Students also stated that they were unable to turn to the Guidance Department for help with personal problems The large number of students who pursue higher education makes it critical that they receive adequate and timely information regarding colleges and scholarship information Review of AdvancED Standards for Quality Schools: The team reviewed the school's adherence to each of the AdvancED standards The findings from this review are provided in the next section of this report Next Steps The school should: Quality Assurance Review Report Page 6 of 16

1 2 3 4 5 6 Review and discuss the findings from this report with all stakeholders Ensure that plans are in place to embed and sustain the strengths noted in the commendations section to maximize their impact on the school Develop action plans to address the recommendations made by the team Include methods for monitoring progress toward the recommendations Use the report to guide and strengthen the school's efforts to improve student performance and school effectiveness Two years following the Quality Assurance Review, submit the Accreditation Progress Report detailing progress made toward addressing the team's recommendations The report will be reviewed at the state and national level to ensure that significant progress is being made toward the recommendations Lack of progress can result in a change in accreditation status Continue to meet the AdvancED accreditation standards, submit required reports, engage in continuous improvement, and document results Resources AdvancED offers a range of resources to support your school as it acts on the findings in this report The AdvancED Resource Network, available at wwwadvanc-edorg/resourcenetwork, provides an online network of peer-to-peer practices, best practices, and resources and tools designed to help schools with their improvement efforts Available any where, any time, the network can be queried for information on a variety of school improvement subjects The AdvancED Research and Development division provides research, handbooks, and tools to assist schools with continuous improvement In addition, your state office provides hands-on professional development and ongoing technical assistance Contact your state office for more information on the range of resources available to you Celebrating Accreditation Following the visit, the Quality Assurance Review team submits an accreditation recommendation to AdvancED for state review and for action at the national level by the AdvancED Accreditation Commission, which confers accreditation and communicates it to the school Upon receiving its accreditation, the school should celebrate its achievement with the school community The SACS CASI logo is available through the SACS CASI website for schools to post on their website and in school communications Flags, door decals, diploma seals, and more can be ordered from the website to help you share your accomplishment with your community Summary The accreditation process engages the school in an ongoing journey of continuous improvement The next steps in this journey are to build on the strengths and address the recommendations noted in this report Doing so will enable the school to advance in its quest for excellence and deepen the fulfillment of its mission for all students Quality Assurance Review Report Page 7 of 16

Standards for Accreditation The primary requirement for accreditation is that the Riverdale High School demonstrates that it meets the seven standards for accreditation The findings of the Quality Assurance Review Team regarding the standards for accreditation are summarized on the following pages Standard 1 Vision and Purpose Standard: The school establishes and communicates a shared purpose and direction for improving the performance of students and the effectiveness of the school Description - The team noted how the school met the intent of the standard based on the preponderance of evidence: Riverdale High School (RHS) has the full support of its stakeholder groups The Quality Assurance Review Team (QART) found an unusually high support for the school on the part of its parents, alumni, and community people The administration constantly sells the vision of the school throughout the community Communication is a high priority and the school has incorporated varying media (email, web page, notes, newsletters, telephone calls, etc) to assist in this task Communication of the goals and expectations of the school has helped bring the stakeholders greater understanding of how the school uses its vision and purpose to set expectations for the students The School Leadership Team was composed of all stakeholder groups: teachers, administrators, support staff, parents, students, and community members Professional Learning Communities within the faculty provide faculty teaching the same courses a common time to discuss learning concepts, establish goals for teaching and learning, create benchmark tests for assessing the effectiveness of teaching and learning in each discipline, and establish interventions for both at-risk and advanced students The leadership ensures that the school's vision, purpose, and goals guide the teaching and learning process through the use of a curriculum committee, the School Leadership Team, faculty meetings, and professional learning communities Strengths - The team noted the following successful practices deserving of recognition: Parents and community members know, understand, and support the school's vision and purpose Riverdale utilizes a plethora of avenues to communicate to its stakeholders The tiered structure of committees (Curriculum Committee, School Leadership Team, faculty meetings, and Professional Learning Communities) provides communication throughout the school Opportunities - The team offers the following opportunities for improvement for consideration by the school: Maintain current practices and expand communication with stakeholders as needed Finding: Riverdale High School has earned the overall assessment level of "Highly Functional" and has met this standard for accreditation Quality Assurance Review Report Page 8 of 16

Standard 2 Governance and Leadership Standard: The school provides governance and leadership that promote student performance and school effectiveness Description - The team noted how the school met the intent of the standard based on the preponderance of evidence: The administration at RHS fosters leadership among the school's teachers and students These leaders continuously promote the school's vision and purpose RHS handbooks and student agendas, containing information regarding policies and procedures, are revised and distributed annually The principal authorizes curricular, extra-curricular, and financial decisions Four assistant principals assist with discipline and other school operations The school is in compliance with federal and state laws, standards, and regulations The QAR Team can verify that the school is prepared for emergencies as they were present when a bomb threat, which necessitated the evacuation of the school, was received by the city police department Many opportunities exist for stakeholders and students to contribute to the decision-making process Faculty participate in numerous committees as well as sponsoring student organizations Students may choose from nearly forty clubs for participation as well as athletics and band A unique feature was scholarships awarded to students which are based on funds raised by students A Community Advisory Board, Parent Teacher Organization, and booster organizations involve the community in the school The faculty conducted stakeholder opinion inventories during a football game The administration maintains discipline while setting high expectations for student behavior and sells the school to the community People want to be a part of Riverdale High School Strengths - The team noted the following successful practices deserving of recognition: Approximately forty clubs and organizations are available for students Students raise funds for scholarships awarded to students who best represent RHS's vision statement or who have overcome life-changing obstacles while succeeding academically Numerous opportunities allow for stakeholder involvement The administration maintains discipline while setting high expectations for student behavior and sells the school to the community Opportunities - The team offers the following opportunities for improvement for consideration by the school: Maintain current practices and expand as needed Finding: Riverdale High School has earned the overall assessment level of "Highly Functional" and has met this standard for accreditation Standard 3 Teaching and Learning Quality Assurance Review Report Page 9 of 16

Standard: The school provides research-based curriculum and instructional methods that facilitate achievement for all students Description - The team noted how the school met the intent of the standard based on the preponderance of evidence: Riverside utilizes internal and external academic and nonacademic data to make curricular and instructional choices Decisions based on Gateway and End of Course Exam scores and Tennessee Value Added Assessment System (TVAAS) data led to the implementation of new innovative programs for the students and teachers RHS provides research-based curriculum and instruction methods that facilitate achievement for all students The curriculum at RHS reflects the diversity of the student body Adjustments and refinements are made during department meetings and in-service days Expectations are clearly communicated to all stakeholders through their handbook, the student planners, and the RHS web page Examples of innovative programs include: agriscience, horticulture, Communication of Life, Virtual Enterprise, environmental science, and Early Childhood Education Careers RHS is planning a Freshman Academy for the 2009 schoool year which will nessitate the addition of a computer lab with the appropriate educational hardware, software, and peripherals Professional development time is allocated to analyze student test data and identify strengths and weaknesses This analysis is utilized in making curricular and instructional choices to enhance student performance The administration conducts formal and non formal observaations to ensure quality teaching strategies are being inplemented The entire faculty and student body use many different types of multi media programs throughout the school day Strengths - The team noted the following successful practices deserving of recognition: The administration conducts formal and informal observations The use of computers and multi-media is apparent throughout the school Opportunities - The team offers the following opportunities for improvement for consideration by the school: Create a computer lab for the New Freshman Academy equipped with appropriate educational hardware, peripherals, and software Finding: Riverdale High School has earned the overall assessment level of "Highly Functional" and has met this standard for accreditation Standard 4 Documenting and Using Results Quality Assurance Review Report Page 10 of 16

Standard: The school enacts a comprehensive assessment system that monitors and documents performance and uses these results to improve student performance and school effectiveness Description - The team noted how the school met the intent of the standard based on the preponderance of evidence: RHS utilized a comprehensive assessment system that is based on clearly defined performance measures that provide valid and reliable results Student performance data is analyzed and reviewed to assess student learning and the effectiveness of the curriculum The Administrator of Curriculum and Instruction, along with the Curriculum Committee, meet every six weeks to analyze report card data Professional Learning Communities PLC) meet monthly to examine benchmark testing data and changes in student performance At this time interventions for both at-risk and advanced students are established Teachers can post grades on-line through a secure web site link for students and parents to view grades in progress Teachers receive continuous training in analyzing the data on student performance and effective use of data An annual comprehensive data analysis in-service session is conducted so that teachers can see the overall picture of student performance and adjust the curriculum and goals of the School Improvement Plan (SIP) accordingly Various means of assessment techniques are utilized The addition of a graduation coach has increased their ability to identifiy and provide intervention for students performing below expectations Strengths - The team noted the following successful practices deserving of recognition: RHS uses continuous analysis of student assessment data to improve the teaching and learning of the school The results of student performance is communicated to the stakeholders through the following: school report card, student report cards, teacher web pages, school improvement newsletter, Special Education progress reports, and classroom newsletters RHS utilized a comprehensive assessment system that is based on clearly defined performance measures that provide valid and reliable results Student performance data is analyzed and reviewed to assess student learning and the effectiveness of the curriculum The data is utilized to aid in planning instructional strategies Teachers receive continuous training in analyzing the data on student performance and effective use of data Opportunities - The team offers the following opportunities for improvement for consideration by the school: Maintain current comprehensive assessment systems and analysis of results to implement programs as needed Finding: Riverdale High School has earned the overall assessment level of "Highly Functional" and Quality Assurance Review Report Page 11 of 16

has met this standard for accreditation Riverdale High School Standard 5 Resource and Support Systems Standard: The school has the resources and services necessary to support its vision and purpose and to ensure achievement for all students Description - The team noted how the school met the intent of the standard based on the preponderance of evidence: Riverdale High School has the resources and services necessary to support its vision and purpose Throughout the Standard Assessment Report(SAR) and interviews with students, teachers and other stakeholders the QART concluded that the school employs a Highly Qualified staff that is able to support its educational programs Through interviews with stakeholders, business leaders, and parents it was evident that RHS has remarkable support for their student body The school has a warm and caring feeling The faculty and staff are dedicated to providing instruction and remediation that serves the academic needs of their students Parents feel that the RHS faculty more than adequately serves the diverse academics needs of their children Because of the size of the student body comprehensive guidance assistance is limited Although the SAR states that the guidance department maintains a website that contains information abut testing, registration, and scholarships available that all stakeholders can access, interviews with parents and students indicated otherwise Student safety is a priority A written Emergency Action Plan covers procedures for all threats to student safety Two Student Resource Officers monitor the campus and are on call for students and teachers The school has human, material, and fiscal resources to implement a curriculum that enables students to achieve expectations for student learning The school employs and allocates staff members who are well qualified for their assignments The school provides ongoing professional development for all staff to improve their knowledge base All new teachers are assigned tenured mentors The school ensures compliance with applicable local, state, and federal regulations Strengths - The team noted the following successful practices deserving of recognition: RHS has remarkable support for their students, faculty, staff, and administration from parent and community stakeholders RHS has an administration and Leadership Team in place that works diligently to analyze all resources to ensure that they are utilized to their utmost Opportunities - The team offers the following opportunities for improvement for consideration by the school: Quality Assurance Review Report Page 12 of 16

Analyze the resources available from the Guidance Department looking for ways to better provide comprehensive assistance to all students with an emphasis on seniors Provide an additional assistant principal to serve the large student body Finding: Riverdale High School has earned the overall assessment level of "Operational" and has met this standard for accreditation Standard 6 Stakeholder Communications and Relationships Standard: The school fosters effective communications and relationships with and among its stakeholders Description - The team noted how the school met the intent of the standard based on the preponderance of evidence: RHS has the understanding, commitment, and support of all stakeholders This is evident because the school has many avenues in place to communicate school events, student successes, as well as, problems to their parents as well as an open-door policy Through the use of parent meetings, PTO, progress reports, conferences, newspapers, and the School Messenger system it is evident that communication with parents and stakeholders is a top priority RHS has an excellent website that provides parents with much information The school has partnerships with several local businesses that allows the school to learn how they can best met the needs of the business community in creating productive, employable citizens Many students also have the opportunity to participate in job shadowing programs By analyzing various data, RHS has strived to foster a learning community for all This process has allowed the faculty to focus specifically on areas of concern in students academic performance Students and teachers have benefited from various programs such as, inclusion integrating regular and special education in select classes, a Directed Studies period, a mentoring program for new teachers, Advance Placement (AP) classes, and Professional Learning Communities Strengths - The team noted the following successful practices deserving of recognition: RHS has provided many opportunities for foster learning communities for students and teachers and stakeholders The faculty does an excellent job analyzing their community opinion data RHS has created a strong sense of tradition which is exemplified by the extremely large amount of community and stakeholder support Opportunities - The team offers the following opportunities for improvement for consideration by the school: Develop a plan to advertise all the avenues of communication to stakeholders made available by RHS Finding: Riverdale High School has earned the overall assessment level of "Operational" and has met Quality Assurance Review Report Page 13 of 16

this standard for accreditation Riverdale High School Standard 7 Commitment to Continuous Improvement Standard: The school establishes, implements, and monitors a continuous process of improvement that focuses on student performance Description - The team noted how the school met the intent of the standard based on the preponderance of evidence: RHS has a collaborative and continuous process for improvement that aligns the functions of the school with the expectations for student learning The following information was gathered from the school's SAR, School Improvement Plan, interviews, and observations Regular meetings of the School Leadership Team, the Curriculum Committee, and the Professional Learning Communities keeps the school aware of needs within the school as it progresses towards its goals The school reviews and updates its mission and test scores annually, as well as its School Improvement Plan Parents and stakeholders are included on its committees as they update their information and participate in surveys To encourage team spirit and socialization, the students participate in a variety of extracurricular activities, pep rallies, and clubs Information is provided to the school's stakeholders through the state report card, individual results to teachers, the local newspapers and television stations, the school newspaper, RTN, the school's website, and the school marquee A yearly conference on differentiated instruction is provided for school personnel Technology training is conducted with all new teachers to acquaint them with the school's capabilities As the school continues to grow and strives to meet the needs of all its varied students, additional technological services and opportunities will need to be provided Strengths - The team noted the following successful practices deserving of recognition: The school produces a yearly School Improvement Plan which targets goals for the school Teachers consistently seek methods to improve student achievement Professional Learning Communities afford teachers in similar subject areas a period of duscussion as to ways to improve their delivery of concepts Opportunities - The team offers the following opportunities for improvement for consideration by the school: Provide additional technological support for the Freshman Academy and each department Finding: Riverdale High School has earned the overall assessment level of "Highly Functional" and has met this standard for accreditation Quality Assurance Review Report Page 14 of 16

Conclusion The commendations and recommendations in this report are designed to focus the school on those areas that will have the greatest impact on student performance and school effectiveness While powerful in potential, the commendations and recommendations only have meaning when acted upon by the school The strength of this report lies in the school's commitment to using the findings to continuously improve The key is action The school is encouraged to use the report as a call to action, a tool to sustain momentum in the ongoing process of continuous improvement The team identified several recommendations for improvement that the school will need to address Two years following this review, the school will be required to submit a progress report summarizing its progress toward addressing the team's recommendations The Quality Assurance Review Team expresses appreciation to Thomas V Nolan, members of the professional staff, students, parents and other community representatives for their hospitality throughout the visit The team wishes the school and its students much success in the quest for excellence through SACS CASI accreditation with AdvancED Quality Assurance Review Report Page 15 of 16

Appendix Quality Assurance Review Team Members Beverly Youree, Chair Jennifer Turpen, Team Member Lisa Creson, Team Member AdvancED Standards for Quality Schools The AdvancED Standards for Quality Schools are comprehensive statements of quality practices and conditions that research and best practice indicate are necessary for schools to achieve quality student performance and organizational effectiveness As schools reach higher levels of implementation of the standards, they will have a greater capacity to support ever-increasing student performance and organizational effectiveness Each of the seven standards listed below has corresponding indicators and impact statements which can be accessed at wwwadvanc-edorg Vision and Purpose The school establishes and communicates a shared purpose and direction for improving the performance of students and the effectiveness of the school Governance and Leadership The school provides governance and leadership that promote student performance and school effectiveness Teaching and Learning The school provides research-based curriculum and instructional methods that facilitate achievement for all students Documenting and Using Results The school enacts a comprehensive assessment system that monitors and documents performance and uses these results to improve student performance and school effectiveness Resource and Support Systems The school has the resources and services necessary to support its vision and purpose and to ensure achievement for all students Stakeholder Communications and Relationships The school fosters effective communications and relationships with and among its stakeholders Commitment to Continuous Improvement The school establishes, implements, and monitors a continuous process of improvement that focuses on student performance Quality Assurance Review Report Page 16 of 16