Testimony Before the DC Public Charter School Board

Apr 19, 2021

The DC Charter School Alliance (“DC Alliance”) supports the at-risk enrollment preference because it affords students designated as “at-risk” the opportunity to attend high-quality schools they may not otherwise have access to. In addition, it allows schools to be intentionally more socioeconomically diverse. However, we have several process and content concerns about the District of Columbia Public Charter School Board’s (DC PCSB) At-Risk Preference Approval and Monitoring Policy based on our review of the proposal and numerous conversations with school leaders.

Process Concerns

This policy needed more stakeholder engagement with and input from those who would be most affected by it. Numerous school leaders have been thoughtfully engaged in the efforts to get this preference in place and wanted to be included in the development of the policy. As a result, it is disappointing that they have little opportunity to understand the policy and staff’s intentions before the DC PCSB votes on it and before they are expected to complete an application. While staff thoughtfully engaged the DC Alliance team very early in the policy development process, more engagement with schools and the DC Alliance before the policy was opened for public comment likely would have resulted in a policy that schools would more readily support.

School leaders are concerned that the timeline is rushed. The policy states that DC PCSB will release the application and evaluation rubric on June 1, and the application deadline will be July 15. With this short timeline and at this time of the year, schools will struggle to conduct authentic, meaningful family engagement and secure school community buy-in. As laid out in the proposal, schools will have approximately six weeks from the time they first see the application and evaluation rubric to build a compelling case for applying the preference, authentically engage families, secure school community buy-in and board approval, and prepare the application. This would be a substantial lift for any six-week span, one that is even greater in the current environment.

Additionally, in an ideal process, DC PCSB would have released a draft application and evaluation rubric simultaneously with the proposed policy. Without a clear understanding of what the application will require and how the application will be evaluated, schools will face unnecessary challenges trying to decide whether to apply for this preference.

Content Concerns

The DC Council enacted this preference to provide more agency and access to the families of students designated as “at-risk”. Unfortunately, however, the prescriptiveness and tone of this policy are likely to discourage schools from offering the preference. This is exactly the opposite of what the DC Council intended when it enacted the preference, and it may cause the city to miss an opportunity to reduce barriers of entry for families.

This policy overreaches into governance in a way that other DC PCSB policies do not. Should DC PCSB want to ensure that schools’ boards have discussed and approved the preference and engaged parents and families, an assurance from the board chair, a resolution, or approved meeting minutes would suffice here just as they do for other policies. This proposal’s requirement for a letter from three specific board members sets a dangerous precedent that is counter to the way nonprofit boards operate.

Families and students deserve greater access to high-demand schools of their choice. This proposed policy in many ways assumes that choices of parents of students designated as “at-risk” must be regulated, reevaluated, and subjected to additional scrutiny beyond what other parents face. As you consider the public comments submitted for this proposed policy, we respectfully encourage you to respect and prioritize parents’ preferences.

Thank you for your time and attention to this matter.