Eva Moskowitz letter to charter authorizers regarding Enrollment and Retention Targets

7/31/2019 Eva Moskowitz letter to charter authorizers regarding Enrollment and Retention Targets

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June 1, 2012

Susan Miller Barker Interim Executive Director

Charter Schools InstituteState University of New York

41 State Street, Suite 700Albany, NY 12207

Sally Bachofer

Assistant Commissioner New York State Education Department

89 Washington AvenueAlbany, New York 12234

Dear Ms. Barker and Ms. Bachofer:

We write to comment on the methodology proposed by the Charter Schools Institute

(“CSI”) of the State University of New York (“SUNY”) and the New York StateEducation Department (“SED”) for establishing enrollment and retention targets

(“Targets”) for New York charter schools.

Although we appreciate your efforts, we do not support the establishment of hard

enrollment and retention targets for students with disabilities (“SWDs”), Englishlanguage learners (“ELLs”), and students who qualify for the federal Free and ReducedPrice Lunch program (“FRPL”). The establishment of such targets does not serve the

interests of children.

Institutionalization of Perverse Incentives that Penalize Good Schools

The proposed targets institutionalize perverse incentives for charter schools. Withrespect to the proposed ELL targets, schools are penalized for graduating their ELLs from

ELL status and rewarded for failing to teach their ELLs English.

While SUNY and SED have attempted to address this issue by creating a three-year “look-back” period, we do not see how this fixes the problem. Success Academy schools

start with kindergarten and first grade, and will eventually grow to eighth grade (and possibly high school). Because the schools do not admit new students beyond third

grade, a three-year look-back does not remove the penalty for schools that graduatedstudents from ELL status more than three years ago. Moreover, charter schools are

statutorily mandated to hold random lotteries, subject to allowable admissions preferences, and can only backfill any vacancies from their waitlists—they cannot pick

and choose only ELLs, SWDs and students eligible for FRPL. As Success Academy



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schools continue to graduate their ELL students from ELL status, the number of ELLstudents admitted through the random lottery, even if a constant 20% (which is the set-

aside percentage for ELLs at Success Academy schools), will comprise a smaller and

smaller percentage of the overall growing student population each year until the schoolsare at scale.

To illustrate, the average ELL student in traditional public schools requires more than 5years to graduate from ELL status.

1By contrast, Success Academy schools, on average,

graduate ELL students from ELL status within 2 years. If a new Success Academy ELLfirst grader graduated from ELL status after 5 years (end of 5

thgrade), using the

traditional public school average, the three-year look-back would ensure the studentcould be counted toward the ELL target until he/she finished middle school. The

school’s failure to teach the child English within 5 years would keep the school in goodstanding with respect to the ELL target. But the reality is that any Success Academy

school will likely graduate the student from ELL status within his or her first or secondyear. The three-year look-back would be a grace period for three years, but there would

still be four to five years until the end of middle school during which the school would be penalized for having graduated the student from ELL status “too quickly.” Indeed, our

middle schools’ ELL percentages should be zero or close to zero because we expect tohave graduated all of our ELL students from ELL status by that point – bizarrely, our

successful education of ELL students will actually put us out of compliance with the proposed ELL targets.

Likewise, SWD targets are equally problematic. The issue of graduating SWD students

from their Individualized Education Programs and integrating them fully into the general

education program is not as critical a focal point as with ELLs because some SWDs willnot be able to do so, given the nature of their special needs. However, the proposedtargets nonetheless institutionalize perverse incentives to over-identify students with

disabilities and to not move students fully into the general education program if and whenthey are able and ready to do so.

Institutionalization of Segregated Schools

The proposed targets have the draconian effect of essentially requiring charter schools to

be economically and racially segregated.

Integration has been a colossal failure in New York City public schools. Despite itsdiverse population, New York City's schools are among the least diverse in the

nation.2

The school system in New York City is largely divided along racial andsocioeconomic lines—with the overwhelming majority of African American/Hispanic

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1!! See Success Charter Network report, The Parking Lot of Broken Dreams: How English

Language Learner programs in NYC hurt children, March 2011 (attached as Exhibit 1).2

Kleinfield, N.R., Why Don’t We Have Any White Kids?, N.Y. TIMES, May 11, 2012,

available at http://www.nytimes.com/2012/05/13/education/at-explore-charter-school-a-portrait-

of-segregated-education.html?smid=pl-share (last visited May 31, 2012) (attached as Exhibit 2).



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and low-income youth attending the weakest traditional public schools in the City, whiletheir Caucasian middle-class counterparts generally attend the best traditional public

schools in the City.

This issue is best illustrated by a tour through New York City Community School District(“CSD”) 3. CSD 3 is located in the west side of Manhattan and includes Central Harlem,

Manhattan Valley, the Upper West Side, and Lincoln Center. It encompasses incrediblediversity, both racially and socioeconomically. CSD 3 has 43 traditional public schools.

Twelve of those schools (28%) would not meet the proposed FRPL targets.3

The ten CSD 3 schools that would be furthest from meeting the proposed FRPL targetshave the following characteristics: (1) their student populations are, on average, 30.8%

African American or Hispanic,4

(2) their average 2011 New York State Math and ELAAssessment passage rates were 85.7% and 80.6%, respectively,5 and (3) they are all

located in the most affluent areas of CSD 3—below 96th Street, with one exception. Bycontrast, the ten schools that would most exceed the proposed FRPL targets have the

following characteristics: (1) their student populations are, on average, 84.5% AfricanAmerican or Hispanic,

6(2) their average 2011 New York State Math and ELA

Assessment passage rates were 44.4% and 35.9%, respectively,7

and (3) all but one arelocated in the least affluent areas of CSD 3—at or above 96

thStreet. The map below

displays this location divide with the district schools that would be furthest from meetingthe proposed FRPL targets in blue and the district schools that would most surpass the

proposed FRPL targets in red:

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Based on data from the Empirical Analysis of School Enrollment Rates using Proposed

Methodology, available at http://www.p12.nysed.gov/psc/enrollment-retention-targets.html (last

visited May 31, 2012).4

Based on data from the New York City Department of Education’s School Demographics

and Accountability Snapshot, available at http://schools.nyc.gov/NR/rdonlyres/2DC1923F-96D9-

443B-943B F5CBC29C47D0/0/CEP6162011FINAL.xlsx (last visited May 31, 2012).5

Based on the New York City Department of Education 2010-2011 Progress Reports,

available at http://schools.nyc.gov/Accountability/tools/report/

FindAProgressReport/default.htm (last visited May 31, 2012).6 See note 2, supra.

7 See note 3 , supra.



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The foregoing data reflects a tremendous inequitable correlation among socioeconomicstatus (virtually identifiable by location/zip code), race, school quality, and student

achievement—within just one CSD. CSD 3 bears out the ugly truth about New York City public schools: the best traditional public schools are largely wealthier and more

predominantly Caucasian than the weakest traditional public schools, which are largely poorer and predominantly minority.

This should not be.

Because charter schools are required to provide a CSD-wide preference, they are

uniquely positioned to break down these inequitable divisions and de facto segregation.Indeed, Success Academy – Upper West (“SA – Upper West”), which is located in

Manhattan’s Upper West Side, does just this. SA – Upper West has the following



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characteristics: (1) 50% of its student population is African American or Hispanic, and(2) 40% of its student population is eligible for FRPL. And internal assessments indicate

that the school is poised for high student achievement in the same vein as all of Success

Academy’s other schools, across all racial and socioeconomic categories. SA – Upper West has achieved what public policy makers have purportedly tried to accomplish for decades: an integrated school where all populations—regardless of socioeconomic status

or race—are performing at the highest academic levels.

Moreover, Success Academy’s Harlem, Bronx, and Bed-Stuy schools offer high-qualityschool options where there are very few. The inevitable effect that we have already

started to see is that more families across the socioeconomic spectrum seek to enroll their children in our schools, as opposed to moving to another zone or the suburbs or choosing

private or parochial schools via scholarship or otherwise. Diversity, both socioeconomicand racial, will likely increase in these schools as diverse families choose our high-

quality school options. Longer term, we expect even greater impact: in Harlem, wherewe currently serve around 2,500 public elementary school children, we hope to see

transformation in the community as our students graduate high school, college, graduateschool, and ultimately become successful, contributing members of society—very

possibly in the community of Harlem.

Schools should not be penalized for having increased socioeconomic and racial diversity, particularly when that diversity is a natural outcome of running great schools. We remain

unwavering in our commitment to reaching out to and serving every community population, including English language learners, students with disabilities, and students

eligible for free and reduced price lunch. But we feel very strongly that segregated

schools perpetuate historical inequities, and can see no benefit to imposing enrollmentand retention targets that cement segregation as a part of the charter school model.

The Answer Is Simple

We urge you not to impose any enrollment and retention targets. Instead, we request thatyou partner with us in going to Albany to change this poorly-thought-out legislation.

Alternatively, SUNY and SED should require no more than that charter schools “shall

demonstrate good faith efforts” to attract and retain English language learners, studentswith disabilities, and students eligible for free and reduced price lunch. See N.Y. Educ. §

2854(2)(a).

We feel strongly that the imposition of the proposed enrollment and retention targets oncharter schools is diametrically opposed to reforming the dysfunctional, segregated, and

inequitable public educational system currently in place. Charter schools were meant to be free from bureaucratic requirements in order to focus on providing the highest quality

education to as many children as possible. Please allow us to continue doing just that.



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If you have any questions or comments regarding the foregoing, please do not hesitate tocontact me at (646) 747-6202 or at [email protected].

Sincerely,

Eva MoskowitzChief Executive Officer

Success Academy Charter Schools

Eva Moskowitz letter to charter authorizers regarding Enrollment and Retention Targets

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