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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.

 

Public Comment: Proposed Changes to Financial Framework Rules

The Board has drafted proposed changes to the Financial Performance Framework rules. Specifically, the changes proposed under this rule package include:

  1. Reducing requirements for reporting under the intervention process [see R7-5-101, R7-5-402, R7-5-509 and R7-5-511].
  2. Replacing all previous non-quarterly financial report submissions with attestations to better streamline Board review and reduce burden on Charter Holders. The attestations are addressed in R7-5-402(F), R7-5-402(I)(2), R7-5-402(J)(1) and R7-5-402(K)(1).
  3. Providing for earlier notification of their intervention status by Board staff to Charter Holders assigned an “Intervention” rating for the first-time.
  4. Modifying the criteria used for determining which schools Board staff must visit to conduct a physical count of students such that schools operated by Charter Holders under first-time intervention would not be required to receive a physical count of students, but rather schools operated by charter holders identified as being “On Probation” would receive a physical count of students [see R7-5-402(N)].
  5. Changing the scenarios associated with Probation Risk Level Three to address an oversight in an earlier rulemaking [see Table 2].

Arizona Revised Statutes (“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. A.R.S. § 15-182(E)(1) requires the Board to exercise general supervision over the charter schools it sponsors.

You may access the proposed rule changes here.

The window for the first opportunity for public comment will be open August 9, 2022 – August 29, 2022.

Please submit your feedback in writing to the Board during the public comment window 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)

All public comment received by August 29, 2022 will be presented to the Board and members of the public will have an additional opportunity to provide comment to the Board at the meeting during which the Board considers the proposed changes to the Board’s rules.

 

Public Comment: Financial Framework's Visit Requirements

 

The Financial Performance Framework (“Financial Framework”) approved by the Board in December 2018 requires Board staff to conduct financial site visits of all first-year schools and certain second-year schools. The table below identifies proposed revisions to the Financial Framework’s visit requirements. These revisions include eliminating visits to second-year schools and shifting to primarily desk reviews for first-year schools. Under the proposal, Board staff will continue to visit first-year brick-and-mortar schools to count students.

 

Existing Language

Proposed Language

First-Year and Second-Year Financial Site Visits
Since only one year of ADM data would be available, the ADM measure will not be applicable for first-year charter contracts. Board staff will visit all new schools approved through the new application, replication application or amendment processes in the fall of their first year of operation. Prior to that visit, Board staff would compare enrollment projections identified in the application package or amendment request to the school’s estimated count or, if available, actual ADM. During the visit, Board staff would meet with school officials and review documentation to ascertain the school’s current financial situation and, if applicable, discuss adjustments made or planned due to lower than projected enrollment.

Schools will be selected for second-year financial visits based on the results of the first-year visit and first-year audit, as well as the school’s second-year estimated count or, if available, actual ADM. Any second-year visits would likely occur in the winter of the school’s second year after the prior year’s audit has been received and reviewed.

First-Year Financial Reviews
Since only one year of ADM data would be available, the ADM measure will not be applicable for first-year charter contracts. Board staff will conduct a desk review of all new schools approved through the new application, replication application or amendment processes in the fall of their first year of operation. The desk review will include Board staff reviewing information submitted by the charter holder regarding its operations, financial situation, payroll processes and board financial responsibilities, as well as contract information on file with the Board and ADM, payment and budget information available through the Arizona Department of Education’s website. For each new brick-and-mortar school, Board staff will conduct a visit to count students.

 

Arizona Revised Statutes (“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. A.R.S. § 15-182(E)(1) requires the Board to exercise general supervision over the charter schools it sponsors.

The window for the first opportunity for public comment will be open August 9, 2022 – August 29, 2022.

Please submit your feedback in writing to the Board during the public comment window 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)

All public comment received by August 29, 2022 will be presented to the Board and members of the public will have an additional opportunity to provide comment to the Board at the meeting during which the Board considers the proposed changes to the Financial Framework’s visit requirements.