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FINAL DRAFT
Overview
A significant number of charter schools who have been
designated under “Independent Study” guidelines
and classified as “non-classroom” programs
operate more accurately as hybrid “Personalized
Learning” programs that offer educational opportunities
both within and beyond the classroom. Many of these
Personalized Learning programs have significant annual
budget expenditures designated for facilities that are
used primarily for instruction-related purposes. These
purposes encompass ongoing use ranging from part-time
to full-time in a variety of instruction-related activities
including reduced-size classes, testing and assessment,
computer technology and science labs, resource library
space, tutoring, and teacher/parent/student meetings,
among others.
Yet SB740, as written, does not allow for these instruction-related
costs to be included in the formula that is used to
calculate the required second-tier criteria that 80%
of the school’s budget be used for instruction-related
purposes. Currently, these instruction-related facilities
costs are being treated separately as a mitigating factor.
As a mitigating factor, however, charter school administrators
are not able to calculate their instruction-related
costs accurately for SB740, nor plan their expenditures
with predictability and reliability to ensure that they
can meet the 80% budget expenditure criteria required
under SB740. Concurrently, the ACCS is unable to verify
with reliability under the current funding determination
process that these costs are being reported accurately.
Consequently, the ACCS has expressed concern over the
possibility of abuse taking place in the reporting of
facilities for instructional purposes. Clearly, these
costs should eventually be included as part of the instruction-related
expenditure formula, but can only be incorporated as
such with a legislative or administrative change to
SB740.
The Advisory Commission on Charter Schools (ACCS), at
its November 21st 2002 meeting, requested that representatives
of these hybrid Personalized Learning charter schools
develop and submit a set of proposed criteria that will
enable the ACCS to accurately determine and verify whether
expenditures claimed in present year or planned in future
years for facilities-related costs for instruction-related
activities are in fact being used for that purpose.
APLUS+, the Association of Personalized Learning Services,
serving as the network association for many Personalized
Learning programs, has volunteered to help spearhead
this proposal. This proposal is the result of a collaborative
effort with input from representatives of several Personalized
Learning charter schools.
APLUS+ proposes that the process for verifying accurate
use of facilities for instruction-related purposes through
the ACCS under this year’s SB740 funding determination
be structured in two distinct categories as follows:
This facilities verification process
is not intended to be required independently of the
SB740 funding determination process, but as part of
it. This facilities verification process can be incorporated
as part of the standard SB740 funding determination
form and process, similarly to be required as stated
in the SB740 regulations upon charter renewal, a significant
change in the charter school’s education delivery
process, or upon expiration of a single or multiple
year funding determination approval.
An approved ACCS facilities form shall be created to
provide the following facilities-related background
information. This form shall be used for each individual
facility being claimed by the charter school. For example,
If the charter school is claiming three facilities for
instruction-related purposes, the charter school shall
submit one form for each facility, or a total of three.
1. Information
a. Type of facility. Examples: Mobiles,
store fronts, office complex, school buildings, etc.
b. Acquisition arrangement. Lease, rent, purchase, etc.
and terms of agreement.
c. Reason for Acquisition; ie. Overall school growth,
community expansion, facilities expansion, facilities
relocation, facilities improvement, special needs student
group, etc.
d. Physical location/address of facility.
e. Size of facility in square footage.
f. Percent of facility used for instruction-related
purposes.
g. List of instruction-related activities provided in
facility. Examples:
1. # of classes scheduled per semester
2. Testing and Assessment activities
3. Resource Library
4. Labs: computer, science, etc.
5. Tutoring
6. Teacher/Parent/Student meetings
7. Certificated Staff or parent development activities
h. How many hours per day and how many days per week
are the facilities accessible, with staff supervision,
to students for instruction-related purposes?
i. What specific student groups will be served by this
facility? ie. K-8, 9-12, at risk, special education,
etc.
j. What is the potential total number of students that
may be served by this facility?
k. What is the estimated percentage of students (from
j) that will use this facility for instruction-related
purposes?
2. Documentation
a. Copies of lease or purchase agreements
for each facility used for instruction-related purposes.
b. If not included in a, documentation verifying facilities
costs.
c. If not included in a or b, documentation verifying
facilities space dimensions in sq. feet, such as a building
or space schematic.
d. Photos of exterior and interior of facility. These
can also be used as part of the third party verification
explained below.
Personalized Learning type charter schools who are claiming
facilities for instruction-related purposes through
the SB740 process shall have an independent third party
verify and certify that the facilities claimed are in
fact being used accordingly. Third party entities used
for this purpose shall only be entities approved by
the ACCS in advance of the verification and certification
process. Third party entities that are approved by the
ACCS shall agree to be an objective representative on
behalf of the ACCS to accurately and honestly verify
use of each facility being claimed by the charter school.
Current entities already serving the charter school
community are natural candidates to provide an objective
third party verification and certification service as
part of their existing services to charter schools.
These entities include:
1. CANEC/WASC. CANEC, the California
Network of Educational Charters recently announced a
partnership with WASC to provide accreditation services
to charter schools. Facilities verification and certification
could be included in this process.
2. CSDC, the Charter Schools Development
Center. The CSDC offers a full range of workshops, how
to publications, and experienced technical support to
charter school developers and operators. Facilities
verification and certification could be included in
the CSDC’s array of services to charter schools.
3. APLUS+, the Association of Personalized
Learning Services. APLUS+ already offers onsite visits
to its charter school clients to profile the program’s
learning activities at its various site locations and
could easily verify and certify the school’s use
of facilities as part of its services.
4. INDEPENDENT AUDITORS. The independent
audit firms that charter schools use annually for financial
accountability could include facilities verification
and certification in their array of audit services.
a. Verification of Facilities Use
Third party verification would involve site visits by
the ACCS approved third party to all facilities claimed
by the charter school for instructional purposes. At
each facility, the third party entity would verify use
by:
1. Verifying physical location and address of
facility with that claimed on ACCS facilities
form and with the facilities documentation above.
2. Conducting Site walk-through to assess use
and purpose of facility. An assessment comparing
square footage actually used for instructional purposes
with what is being claimed by the charter school.
3. Providing visual documentation of site.
Taking photographs of internal areas of facility to
visually document usage.
b. Certification
The ACCS may develop an approved certification form
that can be used by the third party entity to verify
and sign in writing the facility’s usage. This
third party certification, signed by an ACCS approved
third party entity, may then be submitted by the charter
school, along with the above required information and
documentation, to demonstrate beyond a reasonable doubt,
the accuracy of the facilities expenditures for instruction-related
purposes.
A facilities use submission process formula for SB740
such as is proposed here that combines information,
documentation, third party verification and certification
will effectively satisfy the concerns of both the ACCS
and charter school administrators.
For the ACCS, that concern centers around objective
verification of facilities use for instructional purposes
to eliminate the potential for any loopholes or abuses
that may exist or arise in the facilities submission
process. Through this proposed process, the facilities
purpose and usage can be more clearly identified through
the provision of more detailed information relating
to specific instructional uses for each of the facilities
being claimed, and verified and certified through the
provision of accompanying documentation and the participation
of an approved third party.
For the charter school administrator, the primary concerns
are reliable and predictable planning for current and
future budget expenditures, and the proper inclusion
of facilities expenditures for instruction-related purposes
in the required 80% criteria formula used in the SB740
funding determination process. The inclusion of instruction-related
facilities into instruction-related costs also properly
acknowledges and recognizes in SB740 the distinction
between a hybrid, Personalized Learning program from
a more traditional home study, distance learning, or
independent study program. This process will then allow
for better predictability and reliability of the budget
expenditures used in calculating the 80% criteria requirement
necessary for qualifying for full funding in the future.
The intent of SB740 was not to serve as a disincentive
for hybrid Personalized Learning charter schools to
invest in or utilize facilities for instruction-related
purposes. If anything, just the opposite is true. Charter
school programs, perceived as traditional Independent
Study and homeschooling programs, historically have
been highly scrutinized and criticized for not including
classroom-based learning opportunities. Hybrid Personalized
Learning programs have incorporated classroom learning
opportunities effectively into their model, and should
be encouraged and supported, through the SB740 funding
determination process and required criteria, to continue
to invest in facilities for instruction-related purposes.
This dilemma needs to be corrected in the current interpretation
of facilities costs in the SB740 funding determination
process. |
