Monday, March 12, 2012

My Comment on the Grace School Mayoral Academy Application

Dear Regents,

I am writing to urge the Board of Regents to withhold  the Grace School Mayoral Academy's (GSMA) preliminary charter pending at least two actions by the Regents and RIDE.

First, RIDE should draft and the Regents approve a set of clear legal guidelines for mixed public charter and private schools, such as GSMA, in particular concerning the education of non-public school students by public school teachers.

Second, RIDE should draft and the Regents approve a clear set of regulations, based explicitly on the text and intent of Rhode Island law, governing the unique governance and enrollment requirements of mayoral academies.

The most extraordinary feature of the proposed GSMA is its inclusion of non-GSMA, private Meeting Street (MS) school students in every classroom.  The proposal provides some detail on the relationship by which GSMA will pay MS for rent and management services, but it is mute on the converse: MS's payment for students who will attend all classes at GSMA, but are apparently not enrolled as students in GSMA.  In fact, in the estimated budget for a single 4th grade classroom, 72% of income and expenses are associated with students not enrolled in GSMA.  Presumably there will be some sort of contractual agreement, but the application omits details of this apparently unprecedented arrangement.

I am not qualified to speak to the legality of this proposed (or implied) arrangement.  I can, however, point out that if this school is approved, it sets a precedent for a whole range of previously unconsidered public charter/private school configurations.

For example:

Can a Boys and Girls Club start a charter school where in addition to the public lottery seats there will be a reserved set of private scholarship seats chosen by application?

Can Moses Brown start a charter school to provide an inclusive environment for its special education students?  Or as a remedial environment for its students?  Or to give its students some exposure to low-income and minority students?

Can The Wheeler School stretch its financial aid budget by offering ten subsidized “charter school” seats per year?

Can I start a charter school where I auction off 10 private admissions a year with the proceeds benefiting the school?

Can a residential private school serving a transient population (students with addiction or health issues, for example) mitigate the costs of educating its students by starting an on-site charter to be attended by its residents as well as local students?

Can any private school with extra seats add a small charter to pay the bills?

What will the rules be for charter schools within parochial schools?

I would also note that the apparent reason for GSMA mixing public and private students within its classrooms is to allow MS to collect the full special education costs from sending districts or families.  A charter school cannot do this directly.  

This is the fourth mayoral academy proposal that the Regents have considered in recent years, and it is painfully obvious that RIDE's regulations, application and review procedures are inadequate to describe and enforce the letter and intent of Rhode Island's unique law.

For example, RIDE seems to be juggling two distinct interpretations of the language regarding mayoral academy enrollment: on one hand that each sending town is offered an equal number of enrollments (as at Blackstone Valley Prep), on the other that each student should be offered an equal number of enrollments, meaning all students should have an equal chance to be selected from a single lottery pool (except when they are siblings, children of staff, economically disadvantaged, etc.).  The GSMA application manages to directly contradict both extant interpretations by asserting twice that “a minimum of 85% of students will reside in Providence.”

Further, the application states that the academy's board of trustees “is comprised of representatives from each included city or town.”  This is contradicted in two different ways by the GSMA's proposed board.

First, the proposed board has “five representatives from Meeting Street’s Board of Trustees .”  This is clearly in conflict the intent of Rhode Island law, and would give MS effective control over the board of a government-funded non-profit for which they serve as the primary contractor, customer, landlord AND financial agent.

Second, the application repeatedly asserts that the school will not be limited to students from Providence and North Providence, but makes no reference to the legal requirement for those students' communities to be represented on the school's board.

These problems illustrate the inadequacy of RIDE's application and review process.  Prospective mayoral academies are simply offered too little guidance on this unique law,  and as a result, the public and the Regents have repeatedly been forced to evaluate incomplete, inconsistent or self-contradictory applications.  RIDE and the Regents need to offer some clarity on these issues, or they will eventually be settled much more expensively and disruptively in court.

Tom Hoffman
Providence, RI

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