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February 14, 2014 Via electronic mail Mayor Vincent C. Gray Council of the District of Columbia 1350 Pennsylvania Avenue, NW Washington, D.C. 20004 Re: Implementation of the Public Education Adequacy Study Recommendations Dear Mayor Gray: There are several policy implications from the Deputy Mayor for Education’s recently released “Cost of Student Achievement: Report of the DC Education Adequacy Study,” including a potential to increase funding for both DC Public Schools and public charter schools through the Uniform Per Student Funding Formula (“UPSFF” or “Formula”). The signatories to this letter enthusiastically support increasing funding for education on the scale suggested by the study, particularly through an increase in the base level and a new formula weight for at-risk students. We suggest the District adopt a phase-in approach to implementation of new dollars to account for 1) strategic planning of the use of at-risk funds across schools, 2) pending changes to the student assignment process, and 3) available revenue and competing budget priorities. Even as we support the core finding of the study that funding should be increased to achieve adequacy, we oppose some of the other changes that we believe do not promote that goal. Specifically, we are concerned that the study calls for changes to funding for maintenance that could under-fund DCPS and over-fund public charter schools, and about recommendations to place funding for health and other agency services inside the Formula. We applaud the study’s recommendations on the need for more transparent financial data from both sectors. Without that, it will be difficult or impossible to assess how each sector is spending funds and what each sector actually needs to provide an adequate education. MAINTENANCE While the study was developed to tackle the issue of adequacy, several issues related to equity between school sectors also emerged in the study’s final recommendations. The undersigned individuals feel strongly that enough sector differences exist between DC Public Schools and public charter schools, making mathematical parity on a per-student basis – or a dollar for dollar match up for local funds – the wrong approach, particularly when it comes to maintenance costs. Implementation of the rubric proposed in the study could leave DC Public Schools with approximately $47 million less than what it needs for maintenance while giving public charter schools, as a whole, $9 million more than needed. The cover letter to the Adequacy Study Report, the Deputy Mayor for Education acknowledged that “[a]lthough the funding formula assumes uniformity in funding across sectors, the two systems have unique characteristics and cost drivers that create challenges in devising uniform funding that is adequate for each sector.” The DME stressed “we have more work to do in developing equitable and cost efficient ways to address sector differences.” We strongly agree this is the case. As a system of right, DCPS must maintain enough space to serve any student needing a space, either because of private or charter school closures or families moving into any area within the city. Each public charter school is only required to serve the number of students it has agreed to enroll. DCPS buildings are also considered public assets. These older buildings have larger hallways, stairways, lobbies and mechanical rooms than do newer buildings. They also have theaters, full-service kitchens and vocational education spaces. Many of their spaces are designed to be used by the city and surrounding community. On the other hand, charter schools are often in spaces that are at student capacity. This means that maintenance costs, when measured per student, are lower for the typical charter school than for DCPS. Some say this change would provide DC’s charter school sector with funding to improve their facilities and have more space. But the solution to charter school facility needs is not to give them more operational funds than they need, which may not necessarily go towards improving facilities. There is no requirement in the adequacy study report that the additional operating funds be allocated to maintenance or facility needs. Given the large differences in actual maintenance needs and responsibilities between school sectors, an alternative and more sensible approach is to fund maintenance based on actual need. The adequacy study suggests that the Department of General Services will make up the difference for DCPS expenses, as they currently do. We agree that DGS should continue to fund DCPS M&O costs in the short-term, as they have in recent years, with a new mechanism created in the coming year to cover actual M&O costs outside of Formula funds. This method should be informed by actual cost data that should be collected from both sectors, and be combined with incentives for DCPS to co-locate with other users. THE TREATMENT OF OTHER AGENCY COSTS The study also recommends including within the formula some costs currently incurred outside of the school funding formula, including school nurses and mental health clinicians provided by Department of Health and Department of Health and Behavior Health, respectively, and services provided by the Office of the Attorney General, Office of Contracts and Procurement, and Office of the Chief Technology Officer to date only to DCPS. (See Adequacy Study report, p. 89.) We believe those costs should continue to be covered outside of the per-pupil formula and the services be made fully available as needed to both DCPS and charter school sectors. We believe, for example, that if such health services are provided as required by the relevant agencies, we can be more confident that the needs will be met, but if the costs are built into the formula, some local education agencies (“LEAs”) may choose to use the funds for other purposes and leave this critical need unmet. 2 If an adequate increase is made to student funding, we would, however, encourage including the costs associated with the Public Charter School Board, like the costs associated with the DC public schools central office, within the formula funding. TRANSPARENCY – THE PILLAR ON WHICH FUTURE PLANNING MUST REST The study notes that “education budgeting, resource allocation and financial reporting are not clear and easily traceable processes in DCPS or public charter schools. The state of financial recordkeeping makes it difficult to determine the total amount spent by cost category or to assess cost drivers and cost variations within and among DCPS and public charter schools.” The report also recommends the city establish an online public education reporting system that can allow for full information and transparency. (See Adequacy Study report, p. 121). We agree that these transparency and data collection measures should be a key part of implementation. To enable a fully informed planning process for education budgeting going forward, we would urge that LEAs provide the required data in 2014 for the upcoming school year and the two previous school years. We thank you for your consideration and would welcome an opportunity to discuss these issues further with you and your staff. If you have any questions, please feel free to contact Soumya Bhat, DC Fiscal Policy Institute, at 202-325-8814; Matthew Frumin at 202-247-0819, or Cathy Reilly, SHAPPE, at 202-722-4462. Sincerely, (Signatories) cc: Abigail Smith, Deputy Mayor for Education Scheherazade Salimi, Chief of Staff, Office of the Deputy Mayor for Education Eric Goulet, Budget Director, Mayor’s Office of Budget and Finance Justin Constantino, Budget Counsel, Mayor’s Office of Budget and Finance Councilmember Yvette Alexander Councilmember Marion Barry Councilmember Anita Bonds Councilmember Muriel Bowser Councilmember David Catania Councilmember Mary Cheh Councilmember Jack Evans Councilmember Jim Graham Councilmember David Grosso Councilmember Kenyan McDuffie Councilmember Vincent Orange Councilmember Tommy Wells 3 .

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