Proposed Policy 2220

As the Board considers revisions to Policy C56.00, the program placement policy, they should think about what they want this policy to do. I will link to a copy of the draft proposal as soon as one is available.

Historical Background. The original policy, adopted in 2007, had a very specific purpose. The board, upon discovering the superintendent’s process for making program placement decisions, found it secretive, dishonest, political and, in many cases, contrary to the students’ best interests. Programs were placed wherever space was available. Unpopular programs went into unpopular schools and accelerated the downward spiral. Principals in political favor were allowed to veto the addition of a program at their schools while principals who were out of favor with the district staff were not. Some schools were allowed to start programs on request while other schools were required to meet impossible standards before they could start a program. The entire process was corrupt. The Board, not wishing to constrain the superintendent’s authority to make program placement decisions, decided to require transparency and a report. If the process were fixed and known, they reckoned, it could no longer be unfair or political. And if the outcomes of the decisions had to be reported, they could no longer be contrary to the students’ interests.

Unfortunately, neither Dr. Goodloe-Johnson nor Dr. Enfield ever followed the policy and the Board has never enforced it. As a result, the program placement process continued to be secretive, dishonest, political, and often contrary to the students’ interests.

Policy Goals. What should this policy do? What guidance and direction does the Board want to give?

The Board has expressed a set of values around program placement. The Board has expressed an interest in providing equitable access to programs and has expressed an interest in providing programs and services close to the students’ homes. The Board has certainly expressed an interest in making effective use of buildings – neither leaving them too empty nor overcrowding them. And, of course, the Board does not wish to commit the District to unsustainable expenses.

The Board has also expressed values around openness, honesty, transparency, accountability, responsiveness, and engagement. These are values that have not been much in evidence in program placement practices.

Equitable Access. The draft revisions to the policy begin with renaming the policy “Equitable Access to Programs and Services”. While this captures one of the Board’s values that should be expressed in the policy, that value is not expressed in the body of the policy. If this really is an intent of the policy, that intention should appear somewhere in the body of the policy as an enforceable statement. Some reference to equitable access needs to be added and some measure and benchmark for equitable access needs to be defined. The New Student Assignment Plan was supposed to have equitable access to programs as an outcome, but no real effort was put towards that goal and no equitable access resulted. Our district fails to provide equitable access to Montessori, language immersion, Spectrum, CTE, and IB programs. Any real commitment to equitable access should be both thoughtful and real. This is neither.

Programs and Services. The revisions add the words “or services” after the word program wherever that word appeared in the current policy. As the District moves from a program model to a services model to meet the wide variety of student needs it is good to include services under this policy. In the case of intervention services and resource room services for students with IEPs, the inclusion of services under this policy represents a significant expansion of the policy’s scope. Everyone should be mindful of that.

It would also be worthwhile for the Board to make clear what is a program, what is a service, and what is neither. Among programs we include APP, Spectrum, special education programs that cluster together students from various attendance areas, bilingual programs, alternative school programs, language immersion programs, specialized CTE academies (such as biotech and maritime at Ballard), and Montessori programs. All of these are distinguished by following an enrollment process different from the standard enrollment process. Among services we could include ALOs, resource room special education services, AP and IB classes, and inclusive services for students with IEPs. All of these are distinguished by a different set of academic standards and goals for individual students within a school. Attendance area schools with a distinctive curricular focus or emphasis are not included among programs or services, but the Board should consider whether they have an interest in providing equitable access to electives, CTE classes, music programs or international programs.

Criteria List. Seven of the eight criteria that the superintendent “should endeavor” to consider when making program placement decisions were carried forward from the current policy. The new one, making the placements in accordance with the student assignment plan, doesn’t add much. Was there concern that the superintendent would make placements contrary to the student assignment plan? What would that look like? The board should consider how this list contributes to the meaning and effectiveness of the policy. Is this part of the policy enforceable? What if the superintendent were to disregard these criteria? Is the intention to offer guidance without making rules? Is the enforcement for these criteria supposed to come in the annual report? Has it?

Transparency. The draft revision deletes the language that required transparency. This is a tragic flaw. That language should be restored. The transparency was supposed to be the cure for the corruption. We continue to see the corruption as long as the transparency is absent. Without the requirement for transparency there is no policy here. Without the requirement of transparency there is no governance. The Board cannot oversee a secret process.

Proposals from the public. The revision appears to remove the opportunity for members of the public to propose programs. Does the Board want communities to have the opportunity to propose new programs or not? The District’s long-standing alternative schools all started as proposals from the public. The Board has expressed support for innovation, and no one believes that the District staff has a monopoly on innovation. If this process does not exist, then what is the process by which communities can propose the creation of a program? How was the proposal for the Downtown Elementary school made? Didn’t that come from a member of the public?

The Board Action Report claims that staff spent time and resources to evaluate proposals from the public. There is no evidence to support this contention. I have asked a number of people who would have been in a position to participate in those discussions, and no one can recall a single moment spent considering the proposals received from the public. All evidence indicates that the proposals from the public were never seriously considered at all. The Board Action Report states that “very few proposals” came from the public. It's clear that the burden on staff has been minimal.

Annual Report. The draft revision makes no material change in the requirement for an annual report. Where is this annual report? Does it meet the requirements of the policy? Shouldn’t the annual report required by the policy have some data instead of just narrative? Shouldn’t it be a performance report?

What is the problem we are trying to solve? The policy was written to assure that the program placement procedure would be honest, data-driven, and work in support of the students’ best interest. The policy is to encourage the superintendent to make decisions driven by academic priorities instead of political forces or operational preferences. Any review of the history of program placement will show that the District’s problems in this area are not due to any deficiency in the policy. The policy is fine. It is, in fact, one of the Board’s better policies. It does not put one toe across the line between governance and management. Not only does it refuse to constrain the superintendent’s authority to unilaterally determine program placements, it goes so far as to reaffirm that authority. The policy only requires transparency and an annual report. These reflect the best forms of governance and oversight. The problem does not lie in the policy, but in the fact that the policy has not been followed. The superintendent specifically refused to establish the procedure as required by the policy. When asked how decisions were made the superintendent refused to answer. The superintendent refused to provide the annual report as required by the policy. The board, for their part, refused to enforce the policy. Any problems with this policy do not lie in the policy itself, but in the superintendent and the board and their refusal to fulfill their duty with regard to this policy.

I am reminded of a quote from G.K. Chesterson. He said “Christianity has not been tried and found wanting; it has been found difficult and not tried.” So it is with the Program Placement Policy. The policy is fine, but the people who have been charged with following and enforcing it have not been willing to accept the task. It is time for the Board to assert their better selves, to write a meaningful policy, and to enforce it.

Comments

Watching said…
https://docs.google.com/document/d/16jh0lQYd1X9rcz7PRe5P-_D92SIN52lIfW_lTU42fnQ/edit?pli=1#

Here is the full text.
Charlie Mas said…
Watching,

That's the text of the charter school initiative.
dw said…
For those families in APP, any policy that begins with “Equitable Access to Programs and Services” should be a big red flag.

First, that was the district mantra leading up to the N/S split.

Second, there are factions within the district (and even the APP advisory committee) that feel the north and south programs must be "equal", regardless of whether that means shoehorning one or the other into a model that doesn't work well for them.

Not saying the families of either building are wrong to advocate for what works best for their own population, but they are two different buildings, with two different populations in two different parts of the city. They're not going to be "equal" no matter what anyone says or does, so let's make sure that both buildings can work as well as possible for their own cohort of kids, teachers and families.
Charlie Mas said…
Thank you, dw, for your comment. Following the C & I meeting, Director McLaren asked me what I thought about the draft proposal. Although I was seeing it for the first time, I was able to tell her that the removal of the transparency requirement was a tragic flaw. I also said that if the policy was going to call itself "Equitable Access to Programs" then shouldn't it say something about equitable access to programs in it? When describing the policy, Ms Ferguson had said something about "putting the programs where the students live". I told Director McLaren that there is a very high concentration of APP students in the northeast, so would this policy mean that 250 seats at Bryant would be used for APP? She replied "of course not". I asked her "So what does it mean?" and let the silence hang there for a while.

In more direct response to dw's concern, equitable does not mean equal.
dw said…
Yes, thanks for your last sentence. When I wrote the "equals" in quotes it was an (overly) abstruse way of getting people to think about what you came right out and said. I think your way was better.

Bottom line though, people need to stop thinking of things in terms of "equal" or "equitable". Rather, the concern of everyone involved with schools, from the Board to staff to parents and guardians, should be to serve as many kids in the best way(s) as possible. Nothing is one-size-fits-all when it comes to education. That goes for all programs, not just APP.

Language immersion may mean different languages in different areas of the city. Special Ed needs are different depending on the distribution of various needs around the city. Now that APP is split, the very smart people involved with that program should be digging in to make the program work as well as possible for as many families as it can, not working to make them look exactly the same. This should be blatantly obvious, but for some reason it's not to some people.

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