What's Wrong with Proposed Policy 2200

Every so often something comes along that exposes and epitomizes a wide range of problems. This week it is the proposed Policy 2200, Equitable Access to Programs and Services. This proposed revision to Board Policy C56.00 reveals and illustrates problems with the Board's procedures, the Board's practices, the staff, program placement, the allocation of authority, the factors that really drive decisions within Seattle Public Schools, and the whole concept of governance vs. management.

Where to begin?

The History
In 2006 Carla Santorno, the district's Chief Academic Officer under superintendent Raj Manhas, proposed splitting middle school APP between Washington and Hamilton. The APP community hated the idea but there was no resistance to it on the Board. The change was announced in December along with a number of other program placement changes for the coming year. The driving reason given for the split was overcrowding at Washington. District staff claimed that there was no room for neighborhood students at Washington as a result of the growth of APP there. Board Policy D12.00 precluded the creation of additional APP sites in the absence of district-wide enrollment growth. At the time, the District was claiming that enrollment was dropping (to support their plan to close schools). Policy debates lasted over the winter break and in January the Board gave the policy an interpretation that was very favorable to the staff and determined that the policy allowed the creation of additional APP sites, but only following Board review. The Board assigned the review job to the Student Learning Committee (now called the Curriculum and Instruction Policy Committee). Everyone expected a quick, rubber stamp review and approval for the plan to split the program.

The Student Learning Committee expected to hold their review as part of their meeting on February 27, 2007. The review went very, very badly for the staff. It quickly became clear that they had not done any work to really think about the problem or possible solutions. Their rationale proved non-existent. The decision was "withdrawn". But the real impact of the episode was how it drew the Board's attention to the program placement process. The Board had never thought about program placement because policy grants the superintendent absolute authority to decide it unilaterally. The Board, and everyone else, discovered through this review that the entire program placement process was thoroughly corrupt.

So the Board wrote and adopted a Program Placement policy, C56.00. This policy does not put one toe across the line between governance and management. It does not diminish the superintendent's authority to make program placement decisions. It doesn't even intrude on the superintendent's authority to determin the process for these decisions. It only requires two things: transparency and a performance report. The Board believed that if the process were transparent, if it were no longer secret, then it would have to be honest - or at least more honest. And the Board reckoned that if the superintendent had to produce a report that measured how well the decisions matched the Board's priorities for program placement, then the decisions would more closely match those priorities. The Program Placement policy, C56.00, is an exceptionally good policy.

For three years, 2008-2010, the superintendent, Dr. Maria Goodloe-Johnson, provided her administrative procedures for program placement decisions. It was a vague document that generally described a loose practice. In truth, the practice described in the document was not followed, but the Board had no interest in finding any fault with the superintendent. Also for those three years the superintendent produced a summary of program placement decisions which didn't begin to meet the requirements of the policy. Again, the Board had no interest in finding any fault with the superintendent or enforcing any policies. There were some rather comical statements made in these reports including this rationale used for rejecting a number of program placement proposals "The proposal was rejected because it was not recommended."

When Dr. Enfield took over for Dr. Goodloe-Johnson compliance with the program placement policy went away entirely. Dr. Enfield never established or disclosed her procedure. Dr. Enfield never produced a report. The Board, again, refused to enforce the policy. In 2011 and 2012 every element of the policy was violated without any response or consequence.

That's the history. It reflects the history of everything that is wrong with Seattle Public Schools at the District level. It reflects the exact opposite of the values of openness, honesty, transparency, accountability, responsiveness, and engagement. Program placement has represented the intransigent rejection of all well-intentioned efforts to reform a district that is secretive, corrupt, political, un-accountable, un-responsive, and disengaged. The history of program placement illustrates all of the worst aspects and elements of the district. And yet it gets even worse.

The Present
Now, as part of the Policy Review Project, the Board is considering revisions to the policy.

No one on the Board directed the staff in how to change the policy. The staff wrote the draft revisions to the policy without any input or collaboration from the Board or any board director. The staff, when describing the changes in the policy at the C & I Committee and in the Board Action Report, never make any reference to any direction from the Board on how the policy should be changed. If you were to review the history of trespasses across the governance/management line, you would see that the staff trespasses on the Board's territory much more than the Board trespasses on the superintendent's territory. This is just such a case. The perceived need for a policy revision, the direction of the policy revision, and the details of the policy revision all come from staff.

The revisions were presented to the C & I committee - for the first time - at their May meeting. The members of the committee didn't discuss the content of the policy at all. Yet the policy was advanced to the Board for introduction at one meeting and voting at the next. This is all without any board member's input on the policy at all. The Board, as usual, is simply drifting along like a leaf in the staff's current.

What does the revised policy say? It says almost nothing. The revised policy repeals the transparency requirement; it removes the obligation for the superintendent to reveal the program placement procedure. It invites a return to the secretive, political, and corrupt practices of the past. How do we know? We know because we have already seen a return to those practices during the past two years when the superintendent refused to disclose her process and the Board refused to enforce the policy.

The reporting requirement was retained, although the reporting requirement has never been fulfilled before, so there's no reason we should we expect it to be fulfilled in the future.

The guiding principles for program placement have been retained, but they were not enforceable before and they aren't enforceable in the revision.

The Board Action Report states five reasons to revise the policy. They are all false.
"The proposed amendments to this policy aim to achieve five goals. First, the policy is renamed to better reflect what we are really talking about—equitable access to programs and services. Second, language has been changed to reflect that the Superintendent is authorized to create procedures or administrative guidelines, rather than requiring that procedures be set. This language reflects the language now standard in our policies on developing procedures. Third, the amendments retain the requirement of an annual report on decisions, but remove the requirement to allow anyone to make recommendations. Last, it is hoped that these amendments can help bring the focus back to the original meaning behind the policy, and that curricular focuses can remain community driven, rather than imposed by the district."
The policy is called "Equitable Access to Programs and Services" but there is nothing in the policy to bring any equity to the access to programs in the District. Nothing. The change to remove the requirement that the superintendent establish procedure removes the requirement for transparency. The rationale for doing that is nothing more than "that's how we do it". If members of the community are not allowed to propose programs or to propose program placements then we would not have any of our most successful alternative programs. Also, the staff both claims that there haven't been many of these and that evaluating them requires too many resources. In truth, the staff has never evaluated any proposal made by a member of the public but has simply rejected them all out of hand without doing any analysis or making any review of them. Finally, there is nothing about program placement that has anything to do with "curricular focus". They are two completely separate things.

The Future
The revised policy will be introduced at the Board meeting on Wednesday. Let's listen to how the committee's action is described. Let's listen to hear if there is a claim that the C & I committee recommends the adoption of the revised policy, as if they had discussed it and came to that conclusion.

The Board is not likely to discuss the policy much at the legislative meeting. Extended discussion there is discouraged by the President of the Board who wants to run briskly moving meetings. The time and place for discussion is in the committee meetings, only it didn't happen there. The Board is likely to discuss this policy only very little at introduction and not at all at action.

When can there be any community engagement on this policy? Only during the period between introduction and action. And, if the Board decides to make any changes to the proposed policy, when can there be any community engagement on that? There can't be.


mirmac1 said…
Why wouldn't this policy require that the superintendent take into account the input of the multiple superintendent-appointed advisory committees. Oh right, they are window-dressing, never mind.
"Last, it is hoped that these amendments can help bring the focus back to the original meaning behind the policy, and that curricular focuses can remain community driven, rather than imposed by the district.""

What? Since when have "curricular focuses" been community driven?
And just to say, now this history is written down. Charlie did a great job in reviewing it and at least this history is now in a place where the district can't change it.
Anonymous said…
Thank you, Charlie! This is an excellent summary and analysis. It's a shocking example of the district/superintendent/board's complete disregard for the rules they are supposed to follow and the families they are supposed to serve. I sincerely hope that incoming Superintendent Banda will have the opportunity to read this post. It would undoubtedly be discouraging for him, but could inspire him to really clean house and mend the ways of the Star Chamber that SPS has become.

Anonymous said…
Update on APP North, in a letter to families from Susan Enfield:

APP North will remain at Lincoln for the next two school years. For the interim, it will become a stand alone school with it's own budget, and be called "APP at Lincoln." Future program placement is being deferred to Jose Banda.
Anonymous said…
The policy uses language such as the Superintendent "should endeavor" rather than shall, and "is authorized" rather than shall. It makes the policy pretty meaningless and unenforceable. As written, it's more of a nebulous guideline.

sign me, disappointed
Eileen said…
Not only are program placement policies unfair: so are program placements within buildings. The first to get kicked to the curb are special education students. Sending them to portables is a common practice that is at the sole discretion of principals. Unequal is unfair, especially when foisted upon students who are already marginalized. This unchecked practice must stop. Hopefully our new superintendent will pay attention to the entire spectrum of needs, from APP to SPED.
Charlie Mas said…
Director McLaren has entered a motion to remove the approval of Policy 2200 from the agenda.

This is very good news. The board is actually going to consider and discuss the policy before voting on it.

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