Public Comment
General Information
Welcome to the Public Comment Forum!
Through this forum, the charter community and other stakeholders have an opportunity to voice their position on a potential rule or policy and provide valuable information on how it may impact you and your community. Your feedback will assist the Arizona State Board for Charter Schools (Board) and improve its services to the charter community.
We appreciate you taking the time to participate in this forum and look forward to hearing from you.
Academic Eligibility for Expansion Requests Recommendation
At the Board’s August 12, 2019 meeting and at a subsequent meeting with stakeholders on August 26, 2019, the Board heard concerns from schools that are identified as a comprehensive support and improvement (CSI) school. Specifically, charter holders that operate an alternative school identified for CSI solely based on a low graduation rate, expressed concerns on the criteria that is used to identify CSI schools.
Based on feedback, Board staff is proposing to modify the eligibility criteria for expansions to allow a charter holder that operates an alternative school identified for CSI based on a low graduation rate and not low achievement, to submit an expansion request, if the On-Track to Graduate measure is 66% or higher as calculated in the 2019 A-F Letter Grade Accountability System and receives an “A”, “B”, or “C” alternative letter grade.
Schools Identified for CSI Low Graduation Rate
As a result of the FY 2018 CSI designation, the Board has under 30 schools identified for CSI based solely on a low graduation rate, which under the academic framework places them with an Overall Rating of “Falls Far Below Standard.” The majority of the schools are designated as alternative, followed by a few distance learning schools.
Proposal
The current policy for expansion eligibility restricts charter holders with CSI schools from submitting an expansion request. In order to ensure that charter holders operating alternative schools are held to a minimum standard of achievement before expanding Board staff proposes the following:
- Determine academic performance eligibility for all expansion requests, based on a school’s letter grade of “A”, “B”, or “C” and on confirmation that the school is:
- Not designated for Comprehensive Support and Improvement due to low achievement; and
- Receives a rating of 66% or higher on the On-Track to Graduate measure.
Posting period: October 18, 2019 – November 7, 2019
Please submit your feedback in writing to the Board during the posting period using one of the following options:
1. Written comments may be emailed to [email protected].
2. Written comments may be mailed to the Arizona State Board for Charter Schools, P.O. Box 18328, Phoenix, AZ 85005
3. Written comments may be delivered to the Board office located at 1616 W. Adams St., Suite 170, Phoenix, AZ 85007
For all responses please provide the following information:
- First and last name
- Email Address
- Mailing Address (optional)
- Organization (optional)
Proposed Rubric for Board Staff’s Report on the Initial Financial Response
At its meeting on September 9, 2019, the Board directed staff to provide stakeholders with an additional five-day window for public comment on the rubric Board staff will use to review the initial financial response submitted by a charter holder assigned an "Intervention" summative financial performance rating. This additional five-day window will close on September 20, 2019.
Under the Board’s Financial Performance Framework, Board staff will review the initial financial response and prepare a report. Pursuant to A.A.C. R7-5-509(C), Board staff’s report will answer the following questions and briefly explain the basis for each answer:
1. Is there a sound explanation for why the charter holder underperformed on the Financial Performance Framework’s measures?
2. Did the charter holder perform at a level just below or well below the Financial Performance Framework’s measure(s) targets?
3. In what direction is the charter holder’s financial health heading?
4. Do the charter holder’s proposed or implemented actions address the problems that contributed to or caused the charter holder’s underperformance on the Financial Performance Framework’s measures and are they realistic to implement?
The Board has posted the proposed rubric for this additional opportunity for public comment (see link below).
Proposed Rubric for Board Staff’s Report on the Initial Financial Response
Additional Posting Period: September 13, 2019 – September 20, 2019
First Opportunity for Public Comment: August 12, 2019 – September 2, 2019
Please submit your feedback in writing to the Board during the posting period using one of the following options:
1. Written comments may be emailed to [email protected].
2. Written comments may be mailed to the Arizona State Board for Charter Schools, P.O. Box 18328, Phoenix, AZ 85005.
3. Written comments may be delivered to the Board office located at 1616 W. Adams St., Suite 170, Phoenix, AZ 85007
For all responses, please provide the following information:
- First and last name
- Email address
- Mailing address (optional)
- Organization (optional)
Academic Eligibility for Expansion Requests Recommendation
Every year, the Board considers expansion requests submitted by charter holders that meet the expansion eligibility criteria. Under the Board’s current framework, a charter holder is eligible to request an expansion if it meets the eligibility criteria for academic, operational and financial performance. Specifically, under the academic performance framework, a charter holder is eligible to submit a request if:
- 1. An academic dashboard for each school operated by the charter holder is available through ASBCS Online;
- 2. 75 percent or more of schools under its charter have a minimum Overall Rating of “Meets Standard” in the current academic dashboard; and
- 3. Either of the following is true:
- 75 percent or more of all Associated Schools have a minimum Overall Rating of “Meets Standard” on the Associated Schools’ academic dashboards; or
- If one or more Associated Schools are excluded for academic performance purposes, 100 percent of the remaining Associated Schools have a minimum Overall Rating of “Meets Standard” on the Associated Schools’ academic dashboards.
In addition to the above criteria, a charter holder requesting a replication or transfer charter is eligible to submit the request if the school being replicated or transferred to its own charter has a minimum Overall Rating of “Above Standard” on the academic dashboard in each of the last two years.
In fiscal year 2019, the Arizona Department of Education (ADE) identified schools for targeted support and improvement (TSI) based on Spring 2018 AzMERIT student data. The criteria to be identified as a TSI school as required by the Every Student Succeeds Act (ESSA) is:
- Any school with any subgroup of students that has a combined ELA and Math proficiency for identification is 13% or lower (13% is the calculated threshold that represents the bottom 5% of low performing schools).
- Subgroups include students from major racial and ethnic groups, students with disabilities, English learners and economically disadvantaged students.
- The N count (i.e., the minimum number of students that must be present in a subgroup in order for it to be used for school improvement identification) for Arizona is 20.
This means that schools meeting the overall standard for the A-F Letter Grade with an “A”, “B”, or “C” letter grade can still be identified for TSI if at least one subgroup of students have a combined ELA and Math proficiency of 13% or lower. Prior to this, the ADE identified TSI schools in fiscal year 2014 and the TSI list was frozen for two more years.
Proposal
In order to ensure that charter holders are held to a minimum standard of achievement before expanding, but are not held back solely because of a school’s TSI status, Board staff is proposing one modification to the Academic Eligibility for Expansion Requests in the Board’s Academic Performance Framework and Guidance and another to the replication and transfer application instructions for fiscal year 2020.
- Revision #1: Determine academic performance eligibility for all expansion requests, based on both a school’s letter grade and on confirmation that the school is not designated for comprehensive support and improvement.
- Revision #2: A charter holder requesting a replication charter or transfer charter, is eligible if the school being replicated or transferred to its own charter has an “A” or “B” letter grade and is not designated for comprehensive support and improvement in each of the last two years and must also comply with Revision #1.
These proposed changes are detailed below in bold lettering.
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EXISTING LANGUAGE |
PROPOSED CHANGE |
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All Expansion Requests, including Replication and Transfer |
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75 percent or more of schools under its charter have a minimum Overall Rating of “Meets Standard” in the current academic dashboard; and |
75 percent or more of schools under its charter have an “A”, “B”, or “C” letter grade and are not identified for comprehensive support and improvement in the most recent fiscal year that state achievement profiles are available. |
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Either of the following is true:
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Either of the following is true:
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Replication |
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The Replication Model School must currently be open and have:
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The Replication Model School must currently be open and have:
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Transfer |
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Posting period: July 17, 2019 – August 5, 2019
Please submit your feedback in writing to the Board during the posting period using one of the following options:
- 1. Written comments may be emailed to [email protected](link sends e-mail).
- 2. Written comments may be mailed to the Arizona State Board for Charter Schools, P.O. Box 18328, Phoenix, AZ 85005
- 3. Written comments may be delivered to the Board office located at 1616 W. Adams St., Suite 170, Phoenix, AZ 85007
For all responses please provide the following information:
- First and last name
- Email Address
- Mailing Address (optional)
- Organization (optional)
Draft Rules – Implementation of Financial Framework and Transparency Recommendations
The Arizona State Board for Charter Schools (“Board”) has drafted proposed rules to implement the financial performance framework and additional transparency recommended by the Board’s Financial Framework Subcommittee (“Subcommittee”) and approved by the Board at its December 10, 2018 meeting.
Financial Framework
A.R.S. § 15-183(R) requires the Board, as a sponsoring entity of a charter school, to ground its actions in evidence of the charter holder’s performance in accordance with the Board’s performance framework and requires the Board’s performance framework to include the financial expectations of the charter school. The draft proposed rules include revisions to nine current rule sections, with most of the revisions related to the financial framework being made to R7-5-101, R7-5-402 and R7-5-509. The revisions made to R7-5-402(I) and (L) specify that if, based on the next audit, a charter holder identified as “Not on Probation” under R7-5-402(F) is assigned a summative performance rating of “Intervention,” the Board shall determine that the charter holder is “On Probation.”
Transparency Recommendations
As part of the Subcommittee’s discussions with stakeholders, the Subcommittee determined that additional transparency is needed to complement the financial framework. The additional transparency includes requiring charter holders to:
By September 1 of each year, notify the Board, in writing, of whether they have an agreement or contract with an education service provider for the current school year and provide certain information about that provider [see R7-5-501(D)].
Conspicuously and permanently post a link on their websites to their performance dashboards on the Board’s website [see R7-5-501(E)].
Report certain information to the Board within 10 business days [see R7-5-501(C)].
The Board has drafted rules for the implementation of the financial framework and the additional transparency recommendations and, in accordance with the Board’s Procedures for Rule and Policy Adoption, has posted the draft rules for the first opportunity for public comment (see link below).
Draft Rules for Implementation of Financial Framework and Transparency Recommendations
The Board is also considering the process it will use to implement the financial framework in Fiscal Year 2020. At this time, the Board’s intention in Fiscal Year 2020 is to assign each charter holder a summative performance rating under the new framework based on Fiscal Year 2019 audits, including the rating of “Intervention.” Those charter holders assigned a rating of “Intervention” would be subject to the reporting and evaluation requirements prescribed in the draft rules.
For Fiscal Year 2020 only, in recognition of the fact that the financial framework was developed during Fiscal Year 2019 and that Fiscal Year 2020 is a transition year to the new framework, and notwithstanding R7-5-402(D), the Board may choose to allow those charter holders assigned a summative performance rating of “Intervention,” if the charter holder meets all other eligibility criteria, to submit expansion requests specified in R7-5-402(C)(1)-(7). Such expansion requests would require the review and approval of the Board and such charter holders whose Fiscal Year 2020 audit produces a summative performance rating of “Intervention” would no longer be eligible to submit expansion requests specified in R7-5-402(C)(1)-(7) and would be subject to the provisions of R7-5-402(D).
Additionally, the Board does not intend to make revocation or non-renewal decisions based on the financial framework until a charter holder’s Fiscal Year 2020 audit has been reviewed.
Posting period: June 4, 2019 – June 24, 2019
Please submit your feedback in writing to the Board during the posting period using one of the following options:
- Written comments may be emailed to [email protected].
- Written comments may be mailed to the Arizona State Board for Charter Schools, P.O. Box 18328, Phoenix, AZ 85005.
- Written comments may be delivered to the Board office located at 1616 W. Adams St., Suite 170, Phoenix, AZ 85007
For all responses, please provide the following information:
- First and last name
- Email address
- Mailing address (optional)
- Organization (optional)
Financial Eligibility for Expansion Requests Recommendation
To ensure a minimum standard of achievement and operations charter holders should strive to obtain before expanding, the Board adopted financial, academic and operational eligibility criteria for expansion requests. Board staff is recommending the changes below to the financial eligibility criterion that considers the financial performance of the charter holder’s Associated Charters.
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Existing Language |
Proposed Change |
|---|---|
| 75 percent or more of all Associated Charters have no measure rated “Falls Far Below Standard” for the most recent fiscal year presented on the Associated Charters’ dashboards. If one or more Associated Charters are excluded for financial performance purposes, then 100 percent of the remaining Associated Charters must have no measure rated “Falls Far Below Standard” for the most recent fiscal year presented on the Associated Charters’ dashboards. |
Based on Current Financial Framework For the most recent fiscal year presented on the Associated Charters’ dashboards, either 75 percent or more of all Associated Charters have no measure rated “Falls Far Below Standard” or no more than one Associated Charter has a measure rated “Falls Far Below Standard”. Based on December 2018 Financial Framework For the most recent fiscal year presented on the Associated Charters’ dashboards, either 75 percent or more of all Associated Charters have not received a summative performance rating of “Intervention” or no more than one Associated Charter has received a summative performance rating of “Intervention”. |
Posting period: June 4, 2019 – June 24, 2019
Please submit your feedback in writing to the Board during the posting period using one of the following options:
- Written comments may be emailed to [email protected].
- Written comments may be mailed to the Arizona State Board for Charter Schools, P.O. Box 18328, Phoenix, AZ 85005.
- Written comments may be delivered to the Board office located at 1616 W. Adams St., Suite 170, Phoenix, AZ 85007
For all responses, please provide the following information:
- First and last name
- Email address
- Mailing address (optional)
- Organization (optional)
Proposed New Financial Performance Dashboard
During the new financial framework’s development, stakeholders repeatedly expressed to the Board’s Financial Framework Subcommittee that the new financial dashboard must be easy to understand and user friendly. Based on these discussions, the Board is releasing a rough mock-up of the proposed financial dashboard for feedback on the proposed descriptions and format (see link below). The proposed financial dashboard is based on the financial performance framework approved by the Board at its December 10, 2018 meeting.
Posting period: May 1, 2019 – May 31, 2019
Please submit your feedback in writing to the Board during the posting period using one of the following options:
1. Written comments may be emailed to [email protected].
2. Written comments may be mailed to the Arizona State Board for Charter Schools, P.O. Box 18328, Phoenix, AZ 85005.
3. Written comments may be delivered to the Board office located at 1616 W. Adams St., Suite 170, Phoenix, AZ 85007
For all responses, please provide the following information:
- First and last name
- Email address
- Mailing address (optional)
- Organization (optional)
Specific-School Academic Goals Recommendations
A.R.S. §15-183(R) requires that in implementing its oversight and administrative responsibilities, the Board must adopt a performance framework that includes “the academic performance expectations of the charter school and the measurement of sufficient progress toward the academic expectations.” The purpose of the Academic Performance Framework (“academic framework”) is to communicate the Board’s academic expectations for ensuring all schools provide a learning environment that will improve pupil achievement and provide an additional academic choice for parents and pupils.
In the academic framework, State Accountability is the default indicator used to evaluate the academic performance of all charter schools sponsored by the Board. In addition, this indicator considers state designations for school improvement.
The academic framework also recognizes that there are charter schools serving preponderant populations of at-risk students that are not included in the State’s criteria to obtain Alternative School status and has provided an opportunity for those schools to request use of school-specific academic goals in place of State Accountability, as seen in Appendix A of the academic framework. If at least 70% of the students served by a school operated by a charter holder are identified as needing special education services or are homeless, the charter holder may apply to use school-specific academic goals to determine the charter school’s Overall Rating. Board staff is recommending to add a risk factor that takes into consideration a higher than average English Language Learner student population. The Board is requesting feedback from the charter community on this item.
Appendix A: School Specific Academic Goals of the Academic Performance Framework and Guidance
Posting period: December 19, 2018 – January 9, 2019
Please submit your feedback in writing to the Board during the posting period using one of the following options:
1. Written comments may be emailed to [email protected].
2. Written comments may be mailed to the Arizona State Board for Charter Schools, P.O. Box 18328, Phoenix, AZ 85005
3. Written comments may be delivered to the Board office located at 1616 W. Adams St., Suite 170, Phoenix, AZ 85007
For all responses please provide the following information:
- First and last name
- Mailing Address
- E-mail Address
- Organization (optional)
