New York City Sound Basic Education Plan
A Model for Public Accountability & Public Engagement
January 10, 2005
Submitted by a committee with participants from the Alliance for Quality Education (AQE), Class Size Matters, Advocates for Public Representation in Public Education (APRPE), CFE Accountability Task Force members, and other leading education advocates.
INTRODUCTION:
This proposal was drafted by a group of NYC education advocates who saw a need for a
framework to provide public input, public review, and appropriate oversight in the development and implementation of New York City’s Sound Basic Education (SBE) Plan using existing governance and accountability structures.
Enhanced accountability is critical so that citizens and taxpayers, both in New York City and the rest of the State, can be assured that the increased funds devoted to our public schools will be efficiently and appropriately spent on programs that will offer our students an adequate education.
SUMMARY:
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The City’s plan should be required to be reformulated so that it conforms to commonly accepted principles of planning design, including transparent and measurable goals and objectives, with annual benchmarks for improvement.
The City’s plan should be required to be reformulated so that it conforms to commonly accepted principles of planning design, including transparent and measurable goals and objectives, with annual benchmarks for improvement.•The plan should achieve adequacy after five years in the core areas the Court held were key to ensuring a sound basic education, including but not limited to appropriate class size, teacher quality, and instrumentalities of learning. Adequacy will be defined, at a minimum, as conditions equal to those that exist in the rest of the State outside New York City.
The plan should achieve adequacy after five years in the core areas the Court held were key to ensuring a sound basic education, including but not limited to appropriate class size, teacher quality, and instrumentalities of learning. Adequacy will be defined, at a minimum, as conditions equal to those that exist in the rest of the State outside New York City.•The plan should undergo a thorough process of public input and review within existing governance structures, from the school level on up, including the duly elected Community Education Councils.
The plan should undergo a thorough process of public input and review within existing governance structures, from the school level on up, including the duly elected Community Education Councils.•Following implementation, there should be annual evaluations following the same process as in the initial review, as well as mandatory yearly audits by the State Comptroller’s office, to ensure that the money is being efficiently spent to achieve the goals and objectives as outlined in the plan.
Following implementation, there should be annual evaluations following the same process as in the initial review, as well as mandatory yearly audits by the State Comptroller’s office, to ensure that the money is being efficiently spent to achieve the goals and objectives as outlined in the plan.•There should be a documented complaint and appeals process, to assess if problems of a systemic nature remain, and if so, allow for judicial intervention.
There should be a documented complaint and appeals process, to assess if problems of a systemic nature remain, and if so, allow for judicial intervention.WHAT WE MEAN BY A PUBLIC ACCOUNTABILITY MODEL:
The proposed accountability model involves at least four basic components that reflect commonly accepted standards of good practice in planning and assessment:
A.Planning Design to arrive at shared vision for public education,
Planning Design to arrive at shared vision for public education, B.Public Review that includes public engagement and review within existing governance and accountability structures,
Public Review that includes public engagement and review within existing governance and accountability structures,C.Evaluation and Audit that include public engagement as a way to foster public oversight of CFE implementation, and
Evaluation and Audit that include public engagement as a way to foster public oversight of CFE implementation, and D.Complaint and Appeals Process to redress CFE non-compliance issues.
Complaint and Appeals Process to redress CFE non-compliance issues.A. The Planning Design: The committee proposes a planning design for NYC’s SBE plan consistent with commonly accepted standards of good practice.
The City’s five-year and annual plan must include but not be limited to remedies that address the areas found by the courts to impede NYC’s current delivery of a sound basic education. 1
All the components of a sound basic education as defined by CFE must be addressed in the plan, with special emphasis on achieving adequacy in the three areas specifically identified by the Court of Appeals in its decision, i.e. appropriate class size, teacher quality, and instrumentalities of learning. Adequacy will be defined, at a minimum, as conditions at least equal to those that exist in the rest of the New York State outside New York City. 2
To provide an objective basis for public review, in addition to the comprehensive five-year plan, there will be detailed plans for the first year and each year there after.
The design of the City’s SBE Plan must include:
1.Documentation of Need
Documentation of Need 2.Goals
Goals3.Objectives
Objectives 4.Activities, Strategies, and Timelines .
Activities, Strategies, and Timelines . 5.Budgets
Budgets 6.Evaluation
Evaluation Need: In all draft and final forms, the City’s SBE Plan must document need for each goal with quantitative Federal, State, and City data that compare the academic needs and performance of NYC public school students to the rest of the State. The documentation of need must also be used to justify the plan’s measurable objectives.
Goals: In all draft and final forms, the City’s SBE Plan must include but need not be limited to discrete goals for the required areas that the Court has determined necessary to provide a sound basic education.
Objectives: Measurable objectives underpin accountability. Without measurable objectives, it would not be possible for the public to hold the City accountable for its SBE Plan and expenditure of CFE funds.
Therefore, in all draft and final forms, the City’s SBE Plan must include specific measurable outcomes, performance, and process objectives for each goal with defined baselines and benchmarks. Each goal must have multiple measurable objectives. Outcomes must be established that equal or exceed the average for all public schools in the rest of the State. Objectives must be defined in quantitative terms, even where they might involve qualitative assessments.
Activities, Strategies, and Timelines (with rationales): In all draft and final forms, the SBE Plan’s objectives must contain a rationale for specific activities, strategies, and timelines at the school, district, and citywide levels. The rationale must reflect sound data-based research to demonstrate each activity’s likely efficacy.
If the City plans to spend CFE funds on programs not identified in the court record as a necessary component of a sound basic education, it should justify the purpose of the expenditure through reference to research or robust evidence from other school districts where such programs have led to higher student achievement or a narrowing of the achievement gap.
Budgets : In all draft and final forms, the SBE plan must contain detailed budgets for each activity or strategy at the citywide, district, and school levels. The draft and final annual plans must include line item budget allocations to each school, each school district, each region, and to the DOE for each of the implementing established in the SBE Plan. 3
Internal Evaluation Plan: In all draft and final forms, the DOE must write a SBE Plan that contains a detailed formative and summative Internal Evaluation Plan. The Plan must provide for an evaluation of the measurable outcomes defined in the SBE objectives.
In submitting annual plans to the public for review, the DOE must include copies of the internal formative and summative evaluations for the preceding year(s). The DOE shall also make its internal evaluation plan and the annual and cumulative formative and summative evaluations based on the Plan available to the public through the DOE web-site and in written form at the school and district levels at least one month before it make public its draft annual and five-year SBEs for public review.
B. The Public Review Process: The committee proposes a public review process for NYC’s SBE plan within existing governance structures, similar to that which presently exists for District Comprehensive Educational Plans as well as the City’s capital plan for schools. The Public Review Process for Five-Year and annual SBE plans must engage the public to the greatest extent possible. The public review process should result in a shared vision for public education addressing the conditions and inadequacies of NYC public education identified by the Court. The Public Review Process must provide for:
•Annual and Five-year public reviews,
Annual and Five-year public reviews,•Timely public reviews, and
Timely public reviews, and•Documented public reviews.
Documented public reviews.Annual Plan Review: The SBE Plan must be a comprehensive five-year plan with a detailed plan for the first-year and each year thereafter. The plan must be updated and reviewed each year in accordance with the public review process described below.
The Public Review Process must flow from the school forward in the order listed below:
•School Review—Each School Leadership Teams in collaboration with its respective PA/PTAs will submit a formal report of the review to the District level, based on a needs assessment at the school level.
School Review—Each School Leadership Teams in collaboration with its respective PA/PTAs will submit a formal report of the review to the District level, based on a needs assessment at the school level.•District Review—Each Community District Education Councils (CDECs) in collaboration with its respective Presidents Councils and the citywide CDECs for high schools and special education will hold district-wide public hearings, will review the school reports, and will submit its formal report to the Borough level.
District Review—Each Community District Education Councils (CDECs) in collaboration with its respective Presidents Councils and the citywide CDECs for high schools and special education will hold district-wide public hearings, will review the school reports, and will submit its formal report to the Borough level.•Borough Review—Each Borough President will hold public hearings and review the results, including the district and school level reports, with his/her Borough Board (which includes each borough’s City Council members and Community Board Chairs). The Borough Board deliberations will include the Borough’s Panel for Education Policy (PEP) representative. Borough Presidents will also submit formal reports to the Public Advocate.
Borough Review—Each Borough President will hold public hearings and review the results, including the district and school level reports, with his/her Borough Board (which includes each borough’s City Council members and Community Board Chairs). The Borough Board deliberations will include the Borough’s Panel for Education Policy (PEP) representative. Borough Presidents will also submit formal reports to the Public Advocate.•Public Advocate—The Public Advocate will hold citywide public hearings after reviewing the results of the school, district, and borough reviews. The Public Advocate will summarize and analyze results of the public review and make public a comprehensive report that is also submitted to the DOE. The comprehensive report will provide the DOE with public input into a shared vision for the SBE plan for DOE’s consideration in making revisions.
Public Advocate—The Public Advocate will hold citywide public hearings after reviewing the results of the school, district, and borough reviews. The Public Advocate will summarize and analyze results of the public review and make public a comprehensive report that is also submitted to the DOE. The comprehensive report will provide the DOE with public input into a shared vision for the SBE plan for DOE’s consideration in making revisions. The Public Advocate will retain all documentation related to public input from the school level forward. The Public Advocate will also submit a formal report to the State Department of Education with an analysis of the DOE’s final plan.
•Department Of Education—The DOE will use the comprehensive Public Advocate’s Report as well as comments by the Panel on Educational Policy as input for possible revisions to the SBE plan. DOE will submit its revised plan to the NY State Education Department for approval or disapproval. The Public Advocate will also evaluate the revised plan and will provide an assessment to the SED of the extent to which the revisions respond adequately to public concerns with a recommendation for approval or disapproval of the revised SBE by the SED.
Department Of Education—The DOE will use the comprehensive Public Advocate’s Report as well as comments by the Panel on Educational Policy as input for possible revisions to the SBE plan. DOE will submit its revised plan to the NY State Education Department for approval or disapproval. The Public Advocate will also evaluate the revised plan and will provide an assessment to the SED of the extent to which the revisions respond adequately to public concerns with a recommendation for approval or disapproval of the revised SBE by the SED. •State Education Department will make reference to the recommendations of the Public Advocate as well as the comments of the various levels of public review in its final decision as to whether the City’s Plan should be approved or amended. SED will also make reference to its own evaluations of the plan, including an independent 360 degree survey of a representative sample of schools.
State Education Department will make reference to the recommendations of the Public Advocate as well as the comments of the various levels of public review in its final decision as to whether the City’s Plan should be approved or amended. SED will also make reference to its own evaluations of the plan, including an independent 360 degree survey of a representative sample of schools.Timely Public Reviews. Public reviews shall be timely. To assure timely reviews, the DOE will provide its full draft plan to each of the school, district, and borough and citywide review entity at least one month before the review process is to begin.
Documented Public Reviews. Public reviews shall be formal. They shall include public hearings at each level. To assure that reviews at each level are comparable, the review body at each level shall report on the results of its review in writing on a report form designed by the Public Advocate with input from the DOE and education advocacy groups.
C.Public Evaluation and Audit Component
Public Evaluation and Audit Component Public Evaluation: To provide an informed basis for its annual review of the DOE’s draft SBE Plan for the coming year, each public review entity listed above shall review the DOE’s internal evaluation report described in Section A, above, and incorporate an assessment of:
•the preceding year’s/years’ implementation of the SBE at its level of review and
the preceding year’s/years’ implementation of the SBE at its level of review and•the preceding year’s/year’s appeals processes.
the preceding year’s/year’s appeals processes. Audit Component: The State Comptroller’s office will perform annual fiscal and performance audits of the city’s implementation of the SBE plan. If these audits find that the Plan itself or its implementation is insufficient to bring the city into compliance in the remaining years of the five-year planning cycle, especially as concerns the areas highlighted by the Court as necessary for a sound basic education, it will recommend to SED that the city’s Plan be amended.
D. Appeals Process
The Appeals process includes tracking procedures for individual complaints as well as a process to redress systemic, non-compliance on CFE issues, up to and including judicial review and action.
Complaints Documentation: Complaints documentation related to CFE compliance areas may be used as evidence:
•of continuing systemic problems in the provision of a sound basic education and
of continuing systemic problems in the provision of a sound basic education and •of continuing systemic problems in the resolution of complaints filed by members of the public.
of continuing systemic problems in the resolution of complaints filed by members of the public.Complaints Process: To protect the rights of each child to receive a sound basic education, individual parents, teachers, and other stakeholders must have the right to file a complaint at the local level and to have their complaints addressed in a timely manner.
A form, numbered to facilitate tracking, will be designed. Once the form has been completed at the school level, it is given to the principal to remedy the problem. The complainant will retain a copy and other copies will be forwarded to the district’s Community Education Council, the Borough President’s office, and the Public Advocate’s office. Data compiled by the Public Advocate can be used to document system-wide non-compliance when numerous complaints emerge on similar issues across the city.
Judicial Review: When areas of systemic non-compliance can be documented, either through data collected by the Public Advocate or elsewhere in the evaluation process, a judicial review should automatically be triggered in the areas of non-compliance. If the areas of non-compliance are still not remedied after judicial review and report of findings, then the court may act to force compliance.
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Footnotes
1 The schedule of the City’s SBE annual and comprehensive plans and of the Public Accountability review cycle will conform to the actual phase-in of CFE monies if more or less than a five-year period.
2 By referring to “adequacy” or setting “benchmarks” on par with the “rest of the state,” it is not meant to imply that school conditions outside of New York City are adequate, but that in order for NYC’s SBE Plan to be acceptable it must, at minimum, meet this standard to further evaluate and measure progress.
3 Additional state aid in response to the CFE decision must be used only to supplement and not to supplant existing State and City funding at the City, regional, district, and school levels under each of the objectives established for the SBE plan. The SBE Plan must clearly document the supplementary CFE funds allocated to each school, district, and the DOE.
