January 10, 2018

The School District of Philadelphia

New Charter School Application Evaluation Report New Charter Application for: APM Community Charter School

Submitted by: Asociación Puertorriqueños en Marcha, Inc.

Application Evaluation Team: Team Lead: Steve Coyle, Charter Schools Office Evaluators: Chester County Intermediate Unit Deborah Schadler, Gwynedd Mercy University Elizabeth Fornaro, Temple University Peng Chao, Charter Schools Office Tim Hanser, Charter Schools Office

Introduction School District of Philadelphia Overview The School Reform Commission (SRC) of The School District of Philadelphia (District) currently authorizes 84 operating charter schools serving approximately 65,000 students during school year 2017-2018.

Overview of Process The Charter Schools Office (CSO) of the District received nine (9) applications for new charter schools for the 2017-2018 new charter application cycle by the submission deadline of November 15, 2017. Each of these applications has been reviewed by a team of evaluators, led by the CSO, comprised of internal District employees and external reviewers with local and national expertise on the operation of successful charter schools. This evaluation report summarizes the assessments of the evaluation team and is limited to an evaluation of whether the application met the criteria set forth in the application instructions and certain aspects of the Charter School Law. This evaluation report is not intended to be a complete legal review of the charter application under the Charter School Law. The SRC by resolution at a public meeting will decide whether to approve or deny an application for a new charter school.

CSO Vision To create a service-oriented environment that enables the District to support and monitor charter schools while ensuring their accountability.

CSO Mission To assist the SRC and the District in meeting their legislative obligations under the Charter School Law and to promote accountability by exercising oversight for educationally sound and fiscally responsible charter schools as a means of improving academic achievement and strengthening school choice options in the District.

Evaluation Criteria Broadly, charter school applications will be evaluated on the following criteria: ● The extent to which the application considers the information requested in Section 1719-A of the Charter School Law and conforms to the legislative intent; ● The capabilities of the applicant, in terms of support and planning, to provide comprehensive learning experiences to students; ● The demonstrated, sustainable support for the charter school plan by parents, community members, and students; and ● The extent to which the charter school may serve as a model for other public schools.

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Proposal Overview Proposed School Name APM Community Charter School (APMCCS or Charter School)

Application Summary The applicant proposes that APM Community Charter School would serve 702 students in Kindergarten through Grade 8 at scale. The proposed charter school seeks to serve students beginning in the 2018-2019 school year. In Year 1, APMCCS plans to serve 312 students in Kindergarten through Grade 4; the Charter School plans to add one grade per year and would serve students in Kindergarten through Grade 8 with a maximum authorized enrollment of 624 students by Year 5. The applicant proposes a charter school with a community school model and plans to utilize their curriculum and educational program components to prepare students to be prepared for high school and beyond and leaders in the 21st Century. APMCCS is proposed to be located at 405-07 E. Roosevelt Boulevard, where the Archdiocese of Philadelphia formerly operated the St. Ambrose School and where more recently, the now closed Truebright Science Academy Charter School operated through school year 2014-2015. The District also currently operates an annex of Olney Elementary School (K and Grade 1) on the site but not in the specific buildings that the applicant has identified. The proposed location of the Charter School is in the Feltonville section of North Philadelphia. The proposed charter management organization (CMO) Asociación Puertorriqueños en Marcha, Inc. (APM), currently operates four Early Childhood Education centers in the target area (zip codes 19120, 19122, 19133, and 19140): APM Marshall, APM Rivera, APM Trinidad, and APM Rising Stars. These centers collectively serve approximately 500 children and according to the applicant, provide APM with a presence in the targeted communities and create awareness by the community of APM as a quality education services provider. APM does not currently operate any K-Grade 12 public schools, however.

Analysis Summary The proposed Charter School’s mission is focused on creating a safe, happy and nurturing teaching and learning environment. The application states that it would use a rigorous, standards-based curriculum that incorporates technology and arts in order to create critically thinking, socially capable and culturally sensitive young adults; however, the application does not detail how APMCCS would effectively meet the needs of diverse learners, provide a culturally relevant educational program that is inclusive of all students or successfully measure its success in executing all aspects of its proposed mission. Additionally, the application for the proposed Charter School presents an academic plan and curriculum that is not fully aligned with the Pennsylvania Core Standards (PA Core) in English Language Arts (ELA). Evaluators noted concerns with proposed staffing and service levels for students with disabilities, English Learners (ELs) and students at-risk. The Organizational Compliance section includes the required attachments and addressed most components of the application; however, the evaluation team noted several areas of concern, including the relationship between the CMO and the Charter School, staffing and personnel 3

procedures including the development and support of the principal, an absence of partnerships or pipelines for talent when experience and bi-lingual skills are given preference, and student admissions and enrollment policies that are inconsistent or not aligned to state requirements. Similarly, evaluators identified multiple areas of concern regarding the proposed budget including the lack of sufficient allocations to effectively support students creating concern for the future financial health of the proposed Charter School. Specifically, there are significant concerns with expenditure assumptions, the lack of detail presented to effectively evaluate salaries and line item expenditures, and a misalignment between the proposed staffing plan as it relates to the budget. While the applicant was able to provide evidence of community support and prior community engagement, the evaluators determined that the applicant did not provide evidence of intent to enroll forms from age-appropriate students for the 2018-2019 school year.

Mission “APMCCS students, staff, families, and community members foster the success of every student by creating a safe, happy, and nurturing teaching and learning community that stresses high expectations and that encourages a love of learning. Through a rigorous, standards-based curriculum that integrates technology and the arts we will provide a strong foundation that will enable our scholars to become critically thinking, socially capable, and culturally sensitive young adults who will succeed in high school and beyond and become leaders for the 21st century.”

Proposed Location 405-07 E. Roosevelt Boulevard in zip code 19120. The proposed location of the school is in the Feltonville section of North Philadelphia.

Focus of the School/Academic Program The proposed Charter School’s educational philosophy is that all students can learn and become active participants in society using 21st century skills regardless of racial or socioeconomic background. The applicant proposes to offer a high-quality education that prepares, ensures and empowers all students to achieve their full intellectual and social potential in order to become lifelong learners and productive, empowered members of society. The proposed curriculum aims to promote an awareness of how the child interacts with the world to become a self-reliant, engaged citizen. The proposed educational model seeks to integrate technology, communication, creativity, collaboration, artistic expression and critical thinking skills. The proposed academic plan calls for APMCCS students to learn deeply and to apply what they have learned to real world problems with problem-solving and hands-on learning being utilized to meet the needs of diverse learners including ELs. The application states the proposed school plans to implement a positive social and learning environment in part through a student to adult ratio of 13:1 using a co-teaching model that leverages one teacher and one teaching assistant per classroom. The application states that these systems will encourage students to think critically, appreciate diverse viewpoints and develop the capacity to solve problems as they engage in higher order thinking skills.

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Enrollment Projections Academic Year 2018-19 2019-20 2020-21 2021-22 2022-23

Proposed Enrollment 312 390 468 546 624*

Grades Served K-4 K-5 K-6 K-7 K-8

* The applicant would intend to increase student enrollment to a maximum authorized enrollment of 702 students by the 2025-2026 Academic Year

Proposed Opening Year ☑

2018 - 19

☐

2019 - 20

New or Experienced Operator (in Philadelphia) ☑

New Operator

☐

Experienced Operator

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Section Summaries Opening and maintaining a high-performing charter school depends on having a complete, coherent plan and identifying highly capable individuals to execute that plan. The analysis below provides insight into the key strengths and weaknesses of the five main sections of the new charter applicant’s proposal.

Mission and Vision APMCCS’s mission and vision statements, although clearly presented and easy to understand, are missing key elements. Neither the mission statement nor vision statement identifies a specific group of students that would be served by the proposed school, nor are specific, targeted methods identified to serve any particular student group(s). The mission statement does include innovative instructional approaches such as the integration of technology and the arts into a standards-based curriculum that aims to support the whole-child and leverage the resources of the Charter School’s community. The mission statement also reflects high expectations for all learners via a growth mindset. Aligned to its intention of operating as a community school as stated in the application narrative, the proposed vision for APMCCS includes objectives aligned to this proposed school model such as creating a space where children are protected and nurtured, and establishing partnerships with community organizations to help ensure that students are offered individualized academic support; however these objectives are not clearly measurable. Some goals presented in the vision, such as creating a school “where all families are self-reliant” or “where residents are engaged in their community” are not clearly tied to the educational program and curriculum and may present significant challenges in measuring success or failure, particularly within the term of the charter.

Academic Plan The proposed educational philosophy is research-based, reflects an understanding of educating students in an urban community and is predicated on the belief that all students are capable of learning and becoming active participants in their communities and society. The philosophy describes the use of various instructional methods including co-teaching and project-based learning, in a community school model, with native language used to support English proficiency as well as a diverse offering of out-of-school learning opportunities. It is unclear to evaluators however, if the out-of-school time opportunities are fully integrated in the academic program and will be available to all students without barriers including cost. Additionally, the applicant intends to have a bi-lingual instructional staff (English and Spanish) but fails to describe in detail how the Charter School would be inclusive for all students, including ELs, of different cultures or home languages. There was no representation of the other possible home languages or student ethnicities and cultural backgrounds that may live in the targeted neighborhoods or could potentially enroll in the proposed citywide charter school even though the District enrolls students with more than 150 home languages citywide. This led evaluators to have concern about the realization of “valuing cultural backgrounds of all students” and “maintaining positive relationships including multicultural” as the application asserts (page 7). The applicant states that it will meet its Child Find obligation to identify all students in need of special services and will inform families of the Charter School’s screening process through parent trainings and public notice. The application narrative includes a description of the proposed Charter School’s plan to identify and support students at-risk, in need of accelerated 6

learning options, or who required additional supports, through a universal screening process and Comprehensive Support Team (CST) (pages 10-11). The applicant also describes a Response to Instruction and Intervention (RtII) plan as an early intervention strategy to identify, intervene and monitor students both academically and behaviorally. It is not clear, however, how the CST and RtII programs will co-exist to ensure that all students are appropriately served, especially those who may require additional supports. Regarding special education services for students with disabilities, the application acknowledges the proposed Charter School’s obligation to serve all students. The special education plan describes a focus on reading fluency, phonics, comprehension, vocabulary and standards-based math supports. A Special Education Coordinator will ensure Individualized Education Program (IEP) development and compliance. Although the applicant indicated that the various instructional methodologies and pathways to learning including project-based learning, problem solving and technology supported lessons would allow the Charter School to reach a range of diverse learning needs, evaluators found, a lack of depth and cohesion with regards to how accommodations for students with IEPs would be executed to ensure full access to the Charter School’s academic programming. The applicant provided a comprehensive EL policy addressing Pennsylvania regulations that includes identification and exiting, but did not clearly present how the proposed curriculum will be appropriately adapted to serve all learners. Evaluators noted the absence of comprehensive curricular documents for EL and newcomer students and how the proposed Charter School would integrate necessary language acquisition instruction with a standards-aligned curriculum. The application narrative states, “existing content area curriculum for native speakers will be adapted for EL students” (page 10); however, evaluators did not find this to be a detailed plan expressing the integration of EL/Dual Language materials into the identified curricular documents across all content areas. The absence of a fully developed plan to serve ELs and a detailed Language Instruction Educational Program (LIEP) with all components as required by Pennsylvania regulation is of particular concern given the proposed Charter School’s mission and target community. The application narrative includes an overview of curriculum by grade and emphasizes gradelevel reading as well as reading and writing throughout core content areas as a priority of the overall educational plan. With the exception of art, physical education, social studies, and technology, the application included scope and sequence documents, unit plans, lesson plans, and assessments for all grades and subject proposed in Year 1. The curriculum provided, however, does contain deficiencies across grades and content areas. Most significantly, the proposed ELA curriculum does not fully align to the PA Core. ELA curriculum maps submitted for kindergarten through grade 6 do not clearly present standards including, but not limited to: phonics and word recognition (1st grade), fluency (3rd grade), and range of writing (6th grade). Across the core content areas (ELA, math, science, and social studies), there is a lack of alignment between the chosen publisher programs/materials and curriculum maps. As an example, the applicant proposes the implementation of Eureka Math as the math curriculum for kindergarten through grade 8, but as presented in the relevant attachments, the curriculum is not fully aligned with Pennsylvania Academic Standards across grade levels. Although not fully aligned, the proposed curricula that the applicant intends on purchasing for ELA and math, as well as the proposed instructional methodologies, are research-based.

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The extent to which standards were aligned in other content areas varied. Evaluators found that the proposed curricula for art, physical education, health, music, social studies, world language (Spanish) and technology include many, but not all, grade level Pennsylvania Academic Standards. The proposed science curriculum (ScienceDimensions by Houghton Mifflin Harcourt) appears to be fully aligned to grade level standards, however. Regarding implementation, the application does not provide clear and consistent evidence of budgetary support for low student to teacher ratios, which is cited by the applicant as a way they would seek to differentiate instruction. Moreover, although the application states that technology and arts will be integrated throughout the curriculum, the application does not reference details about the technology that will be used to support personalized learning including specific intervention software (page 6). The application makes references to online learning opportunities in grades 7 and 8, but it is not clear what curriculum would be used for such online learning or how such online learning would be provided (page 5). Further, while the application purports to align its promotion standards to the District’s, the proposed promotion standards do not match (i.e. APMCCS promotion standards in grades 1 to 8 include reading levels and math/science levels of Basic or above; however, the District’s promotion policy for the same grades relies on passing courses). Additionally, it was not evident to evaluators if the Charter School was proposing to adopt the District’s marking guidelines for reading assessments, which differ from the publisher’s standards, and how the Charter School would address the potentially large number of students scoring Below Basic in one or more tested subject areas in grades 3-8 (for example, by requiring summer school). The proposed curriculum does provide a description of the overall objectives for each subject area and states that grade-level reading is identified as a top priority for APMCCS. The curriculum is directly aligned to APMCCS’s mission and the rationale for the curriculum is clear and detailed; however, it does not speak to the likelihood of success as measured by the PSSA against Pennsylvania Academic Standards nor does it speak to any research related to the use of the proposed curriculum including Eureka Math, Wonders and HMH ScienceDimensions for atrisk or struggling students specifically. Evaluators also noted concerns about the ability of APMCCS to support at-risk students. The application does include narrative information about supports the Charter School could provide to at-risk students both in and out of school using the Community School Model, which would be facilitated by the CST. The applicant presents as evidence to their experience with providing at-risk support services the range of services that are currently provided to the community by APM. However, the coordination of all of these supports and services appears to be with one Case Manager in Year 1 for 312 students. Further, the minimum qualifications for the Case Manager position only requires minimal years of experience and no state certification or licensure; in Year 1 the Charter School does not propose to employ a counselor. Additionally, it is not clear if APM would be the assumed provider for these at-risk services, at whose cost, and if APM could provide the full range of services that students and families may require given the Community School Model proposed by the applicant. The applicant does not identify specific services that would be provided to homeless youth, youth in transient housing, youth in foster care or students involved with the juvenile justice system. Also, the application lacked specific references to trauma-informed care or details regarding specialized training for school professional staff. The lack of a counselor in Year 1 coupled with the reliance on primarily

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external providers for the community school and CST referred services led evaluators to have concerns for accountability and efficacy. The Academic Data and Goals section provides performance goals that exceed the PA standards for academic accountability and demonstrate a commitment to not only closing but eliminating the achievement gap for Philadelphia students compared with state averages. There is concern however for the Charter School’s ability to achieve the academic goals presented, and no discussion or rationale was presented for how APMCCS as early as Year 1 would achieve proficiency levels that are two or three times that of District or charter sector averages in Philadelphia. Although measures for closing the achievement gap were provided for all students, there was an absence of specific student subgroup measures and performance benchmarks which is inconsistent with expectations under the Every Student Succeeds Act (ESSA) and the Charter School’s educational philosophy. The applicant does however describe a comprehensive process for data-driven programs and instruction, which details data collection and analysis processes, use of data to inform instructional practices, training for teachers, progress monitoring processes and use of data in the decision making process. The applicant also includes a comprehensive assessment plan that incorporates the data source, frequency and alignment to CST timelines. The applicant identifies the use of nationally-normed assessments (DIBELS) for kindergarten through grade 2 as well as the PSSAs for students in grades 3 through 8 in addition to curriculum-based assessments for all grade levels (page 29). However, the applicant does not indicate why, how or when corrective action will take place, including at what level of performance corrective action or intervention would be expected, nor explain how the Charter School would align assessments to the mission and performance goals. Further, the application does not identify a separate assessment for universal screening and progress monitoring. In fact, the application states that this will be selected once key personnel are hired but there is no evaluation or selection criteria provided and without identification of the assessments the evaluators were not able to determine alignment to APMCCS’s mission and educational program (page 18). The applicant’s response to prompts regarding School Culture and Climate provided a description of APMCCS’s ideal culture through belief statements that include some details of how they would operationalize. Out-of-School Time (OST) partnerships are identified with both a local community organization and a higher-education institution. However as detailed elsewhere, it is not clear which students would be eligible for these services, if there would be any costs for students or the Charter School or what the source of funds is identified as “revenues” in the applicant’s budget. The application proposes a CST as a strategy to identify students in need of extra services and presents some discussion of the role of the Case Manager and other professional staff. However, there are major deficiencies in this section. As stated in the application, the Charter School intends to implement both Responsive Classroom and Restorative Practices systems. The Responsive Classroom model description provided in the application is verbatim from the website of the sponsoring organization; however, APMCCS did not provide any description of how that system would be effective for the population the Charter School intends to serve nor specifically how it would be integrated into the APMCCS educational model. Further, the only mention of training for staff on these systems is during the two weeks before school starts as one of the pre-school year trainings. There is no mention of staff or leadership attending off-site training or workshops for implementation or ongoing development on these systems nor contracting with expert trainers to train staff on site. There is

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no indication of how the school leaders would assess the need for ongoing development of and/or success of the system. As these systems form the primary culture and climate models to be used by APMCCS and as the applicant proposes a community school model which relies significantly on school climate, assessing, reflecting and improving the Responsive Classroom model is a major piece that is missing from this plan. Evaluators also noted that assessment of teachers and staff in using this system is not included in any formal or informal observation processes. In addition to the above concerns, the inclusion of Restorative Discipline Practices is represented only as a general description of the philosophy with only minimal mention of the methods associated with the system. Effective implementation of Restorative Discipline Practices, as with Responsive Classroom, requires significant front-loaded staff training, as well as ongoing staff training, assessment and reflection. The use or identification of the uniform questions for those that have harmed the community and those who were harmed is not identified, nor are the key processes of bringing parties together to restore relationships when possible.

Organizational Compliance The application was responsive to the required elements within the Organizational Compliance section of the evaluation, however, the evaluation team noted several key areas of concern throughout the submission. In the staffing plan, the positions listed as “PT” are not counted in position total. It is unclear to evaluators how the “PT” designation differs from “0.5.” This differentiation inaccurately identifies the total staff count for Year 1 as 42 which is also not aligned with the staff count, outside of after-school aides, as presented in the budget (Attachment 26). The application narrative identifies the hiring of a “Computer Technology” instructor in Year 1, but this is indicated in the staff table as “PT”. However, other positions listed as 0.5 or PT in the staff table are explicitly described that way in application narrative. Also, the application narrative states a full-time PE teacher is hired in Year 2, however the staffing table identifies this as in Year 3. Based on the targeted student population and the proposed recruiting and marketing strategy, EL enrollment levels are anticipated to be above District and charter sector averages. If the applicant’s projections for ELs are used, which evaluators find to be understated based on the educational model and proposal for student recruitment and marketing, the English as Second Language (ESL) staffing levels are far too low. Assuming the projected range of EL enrollment (6-22%) as specified by the applicant (page 46), this represents 19-69 EL students in Year 1, 2386 in Year 2, 28-103 in Year 3, 33-120 in Year 4, and 37-137 in Year 5. However in Years 1 and 2, the Charter School has budgeted only one ESL coordinator with a part-time ESL instructor position added in Year 3, switching to full-time in Year 4. Based on these proposed staffing levels, Year 1 caseload per position could be up to 69 students, Year 2 up to 86 students, Year 3 up to 69, Year 4 up to 60, and Year 5 up to 69. Based on these numbers, budgeted staffing levels for ESL services are insufficient. The application appropriately accounts for special education staffing in the Charter School’s first year, with 2.5 special education teachers and another staff member assuming some special education instruction duties also serving as the Special Education Coordinator. It appears that the proposed staffing structure could appropriately support students with IEPs if special

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education student enrollment projections are realized. Evaluators did note that the responsibilities for the Special Education Coordinator in Year 1, along with instructional duties, are significant which is a concern in light of the minimal qualifications and experience required for the position – only two years of special education teaching experience. Further, if the Charter School were to enroll more than the projected rate of special education students or need to create self-contained settings for students, the caseloads would increase significantly within the proposed staffing model. However, the applicant acknowledged the proposed school’s obligation to serve all students who have a disability that enroll in the Charter School and also acknowledged that in instances in which APMCCS is unable to provide direct services, applicant has legal and financial obligations to provide an appropriate alternative setting. The Principal for the Charter School has been identified, has been working as a contractor with APM since August 2017 on the new charter application and preliminary school start-up, and appears to be appropriately certified, with a PA Administrative I Certification. The Employee Handbook is detailed, comprehensive and sufficiently details the process for monitoring and dismissing staff. An organizational chart is provided but there are some missing elements. Evaluators noted concerns for the minimal expected experience and qualifications of professional staff, that the salaries proposed for teachers and specially certified instructors including special education instructors were far below District levels, and that there was an absence of an existing talent pipeline or established partnerships with teacher preparation programs (page 35). Additionally, the evaluators noted a concern that the proposed principal candidate has not previously served as a principal or assistant principal and will be supervised and supported by the Director of Operations, an employee of APM, LLC, not the Charter School, who does not hold a Pennsylvania certification as a school administrator. Evaluators did not understand the rationale for having a Director who lacks certification in educational administration serve as the mentor, supervisor and evaluator of a new principal. The application narrative and Attachment 7 fail to accurately identify all checks and clearances that all prospective employees would have to complete prior to securing employment. Two other leadership team members, the Case Manager and Special Education Coordinator, have not been identified, nor has the applicant provided a timeline for the recruitment and hiring of these individuals. Further as previously noted, the minimal qualifications for key professional positions are a concern for evaluators since this would be a new charter school with a proposed community school model that intends to serve a high-poverty, high needs student population. As stated above, the Director of Operations, the supervisor for the APMCCS Principal, will be employed by APM, LLC, not the Charter School, and his services are included in the management fee. Evaluators note a number of concerns with the Charter School’s Admissions and Enrollment policies and procedures. APMCCS proposes a number of preferences, although does not explicitly state a first preference for Philadelphia residents as required by Charter School Law, including siblings, founders, and children of staff members. The term “sibling” would apply to all children living at a single address, including cousins (page 49). This range of lottery preferences could constrain full availability of choice options for all Philadelphia students. The application does not provide clear details regarding back-filling; evaluators could not determine if back-filling would occur for all grades and at all times during the school year. Required enrollment documents are not compliant with Pennsylvania guidelines in that the Charter School

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requires documents for enrollment that are not permitted to be required for enrollment (e.g. medical and dental records, records release). Additionally, contrary to Pennsylvania guidelines, the Charter School would not require a parent or guardian to submit immunization records until 30 days after enrollment. Under Pennsylvania guidelines, parents or guardians must have evidence of required immunizations within five days of starting school and immunization records are required for enrollment. Further, the Charter School proposes use of a “family card” system for the lottery in which each family instead of each applicant would receive an entry into the lottery (page 49). The use of this system suggests that each applicant would not receive one entry into the lottery, which evaluators found to be inconsistent with the Charter School Law and Pennsylvania charter school enrollment guidelines. Evaluators noted concerns about the plan for student discipline and the Student Code of Conduct provided by the applicant. Although the Code is consistent with the U.S. Department of Education’s best practice principles, it does not clearly protect historically underserved student populations. The process for Manifestation Determination is stated to occur after a change in student placement based on reference that if a manifestation determination identifies the student’s disability as related to the behavior subject to disciplinary consequence, the student “can usually return to the placement from which he/she was removed” (page 51). The Charter School’s plan also fails to provide guidelines for staff in communicating with families regarding issues that may result in less severe consequences (e.g. detentions, 1 day suspensions). The role of APM is concerning based on the proposed Management Agreement between APMCCS and APM (Attachment 24). The applicant states that the current CEO of APM will appoint all initial charter school board members (page 59) indicating a related party concern and suggesting a lack of independence of the Charter School’s Board from the CMO. Additionally, simultaneously, APM will serve as the CMO, provide both support and oversight for the Charter School, act as the landlord, be the guarantor on the Charter School’s proposed $1 million loan, and also could serve as a service provider for many of the community school model supports. The Management Agreement suggests an imbalance of independence of the Charter School in consideration of the terms and conditions; the agreement does not require an annual evaluation of the performance of the CMO nor make any such formal performance evaluation a criteria for termination of the agreement, budgets are to be developed by the CMO and approval by the Charter School’s Board “cannot be reasonably withheld”, APM as the CMO may “modify the means, methods, and manner by which such services are provided at any time” and financial expenditure details for the Charter School are not provided except upon request by the Charter School. (Attachment 24) Further, in accordance with the proposed Management Agreement, "APMCCS may provide or contract for services, including, but not limited to, pre-kindergarten, summer school, academic camps, before and after school programs, vocational training, and community programs to students and non-students of APMCCS." It is unclear what revenues would be used to provide these services. Charter school per pupil revenues are to be used for the direct benefit of enrolled charter school students only. Charter school revenues cannot be used to provide community programming or educational services to students or individuals not enrolled at the charter school. Additionally, charter schools are not authorized to provide pre-kindergarten services and cannot use any charter school revenues or resources to provide a pre-kindergarten program.

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In addition to potential conflict of interest concerns regarding APM’s appointment of board members, evaluators noted concern regarding the absence of limits on subsequent terms for board members within the proposed bylaws and that two of the six board members identified live outside of Pennsylvania according to their resumes. Evaluators did find, however, that the identified board members possess relevant expertise with regards to charter school operations and academic programming. The application also sufficiently addresses the board’s obligations with regards to the Sunshine Act and Ethics Act.

Finance and Facilities Evaluators note several concerns in the Facility and Finance section. There are a number of unsubstantiated revenue assumptions which is of further concern as the Year 1 budget identifies a 7.3% operating deficit. The applicant assumes federal (IDEA and Title IIA) and state (health services reimbursement) funding but reviewers question eligibility and/or receipt in Year 1; the total of these federal and state funding revenue amounts in question for Year 1 is $47,820.24. Revenues proposed for lease reimbursements and Sinking Fund Programs are nearly double what would be anticipated ($36,500 vs. $71,000). Applicant did not justify the calculation regarding the Sinking Fund Programs. Further, evaluators were unclear about APMCCS’s eligibility for these funds as the Charter School would not own the building. Evaluators were not able to validate the source for aftercare services revenues ($200,000) and what the pass through of these payments would be as APMCCS proposes to partner with the organizations providing OST services. The narrative states that revenues will pay for after-school teacher salaries but no other detail is provided. Regarding expenditures, evaluators noted significant concerns regarding personnel. In addition to the previously referenced concerns regarding the level of staffing for ELs and students with disabilities, the FTE count in the budget (67.8 less 24.3 for After School Program = 43.5) does not match the position count in narrative (42, 44 if the four part-time positions are at 0.5 FTE). Additionally, there are 0.5 more teacher assistants in the budget than identified in the application narrative. The budget provides for summary by category (administration, regular teachers) but does not identify salary and benefits by position. The budget identifies an administration average salary of $45,200 for 7.5 FTE but it is not stated what positions are included. For school leadership team members, this average salary is far below charter sector and District averages and is non-competitive. Teacher assistant average salary as budgeted is $14,013.82/year. This also appears to include the Case Manager (listed as Counselor in budget worksheet) which evaluators expect to be paid at a significantly higher salary based on the qualifications and duties stated in the application (page 19). The average teacher assistant, which to support the coteaching model should be more than a 0.5 FTE, would then on an hourly basis receive a wage of $6.87/hour for 2040 hours or $10.27/hour using 195 days for staff/teachers, 7 hours/day. Evaluators found that this level of salary would challenge attraction and retention of qualified, experienced personnel especially if they are also expected to be bi-lingual to support the instructional program. The “Nurse” position is identified as contracted in the application narrative; however, as represented in the budget ($40,000) this rate of contracted services is low for 312 students in Year 1 as a FT nurse would be expected. Additionally, there is also a “School Doctor” described in the narrative as carrying out examinations, but this is not budgeted, and if the fees are to be under the Nurse budget line, the sufficiency of this amount is further questioned. There is no budgeted expenditure for food service however the application identifies

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food service to be contracted and additionally a 0.5 food service worker is listed in the application narrative for Year 1, increasing to 1 FTE in Year 2, and 2 in Year 5 (page 53). All benefits costs assume that all employees, including After School Program Staff, would be offered benefits. It is unclear to the evaluators if this is planned. The overall benefits rate budgeted is 25%. Bureau of Labor Statistics averages are 35% for public schools and 30% for private schools. A rate of 25% is more in line with national averages for the services industry, not education. Medical benefits per employee is budgeted at less than $6500/employee, which is lower than national averages (~$12,000 for family HMO plans and $5500 for single coverage). Page 62 of the narrative cites assumed yearly increases for health insurance benefits, which range from 2.68% for Year 2 to 4.63% for Year 5. These assumptions are well below the assumptions for the District as well as national survey results collected by Mercer in their 2017 National Survey of Employer-Sponsored Health Plans, Willis Towers Watson’s Best Practices in Health Care Employer Survey, and projections developed by PricewaterhouseCoopers’ Health Research Institute. The applicant proposes that employees would not participate in the state teacher retirement system (PSERS) but instead an alternate 403(b) plan. This alternate 403(b) plan would provide for up to a 7.5% match on employee contributions, however it was unclear to evaluators if the employee contribution was a prerequisite to any employer contribution. This led evaluators to question if the 403(b) plan proposed would meet the requirements for PSERS approval. Several positions listed in budget narrative appear to be redundant positions, as these functions are also provided for in the Management Agreement (e.g. fiscal manager, accounting clerk, IT technician, maintenance supervisor). The Charter management fee is 10% of local funding (perpupil) with a reference in the management agreement to an additional 12% of “other revenues” (Section 4.01) which may include other program revenues (e.g. afterschool revenues) and grant funding. In comparison to other charter school management fees in Philadelphia, this rate is high based on the services to be provided. It is also unclear if this is the net expense (10% local revenues plus 12% other revenues) or if there are other costs outside the facility which could be payable to APM. This lack of clarity regarding the management fee was a concern for evaluators as this would impact the Charter School’s ability to accurately project annual CMO fee related expenses with a portion of the fee being variable. The proposed facility would be purchased by APM, serving as both the landlord to APMCCS as well as the charter management organization. Annual rental expense for Year 1 is budgeted at $706,300; the tentative lease agreement states a cost of $14/square foot. The application narrative indicates APMCCS would lease 50,450 sq. ft. in Year 1, expanding to 66,040 sq. ft. by Year 5. However, the proposed facility is approximately 71,800 sq. ft., and there is no language in the tentative agreements submitted with the application outlining how space much would be rented, or the landlord’s willingness to rent only a portion of the facility. Assuming lease of a portion of the facility is feasible and as the tentative lease outlines a 2% increase in the base rent each year, for Year 5 in which 66,040 sq. ft. would be used at a base rent of $15.15/sq. ft., the rent in Year 5 would increase to $1,000,506. This exceeds the budget presented for Year 5 by $46,076.75. Evaluators note that the base rent per sq. ft. of $14 is high for rent in this area and does not appear to be aligned with fair market value. There is also no consideration of ownership transfer once the mortgage for the property, carried by APM, is paid off.

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Maintenance and repair costs are budgeted as $5,000 in Year 1, which is very low. Based on averages per square foot, evaluators were expecting an expenditure of approximately $20,000. Based on the terms of the proposed lease between APM and APMCCS, the Charter School would operate in three buildings that are located at 405-07 East Roosevelt Boulevard in Philadelphia. Evaluators again note a concern regarding a potential conflict of interest between APM and APMCCS as the CEO of APM signed the lease terms on behalf of the Charter School. As presented by the applicant in the Facility Planning Questionnaire, the proposed facility includes classrooms, multipurpose rooms (auditorium, cafeteria, gym), and office space however there does not appear to be dedicated space planned for science labs, computer labs, family or community resource rooms or a library. According to the lease terms, the only pending renovations are to the HVAC system in advance of the 2018-2019 school year. Adjacent to the proposed facility is an annex of Olney Elementary School, a District school serving students in kindergarten and first grade. The applicant did not provide a plan for ensuring operational feasibility with another school. The backup facility presented, 926 W. Sedgley Ave, is currently occupied by Khepera Charter School, which continues to operate at the facility, although its charter was revoked by the SRC in December 2017. In the Other Purchased Services section of the budget, there is no expenditure for student transportation or field trips; minimally charter schools are responsible for the accommodation costs for transportation of students receiving special education services. There is an expense of $9,000 per Diem travel for 50% of staff that is not justified in the budget narrative. The applicant’s professional development (PD) program for school staff includes opportunities for growth, collaboration and communities (peer coaching, focus groups, workshops, PD committee). As mentioned elsewhere, there are concerns for the time and intentionality of PD for Responsive Classroom and Restorative Practices Training and Assessment. Teacher evaluations will be completed using the Danielson Framework. Unsatisfactory performance will result in coaching/mentoring/meeting with principal to address deficiencies however specific timelines for improvement or removal are not identified.

Family and Community Engagement and Support The applicant provided evidence that they have experience working with the targeted communities and that they intend on bolstering the proposed Charter School’s academic programming with a community school model. While their familiarity with the targeted community is evident through their existing community organization and early childhood centers, the application submitted did not comprehensively address how the Charter School would fill the needs of the targeted community nor detail sufficient evidence of support for the Charter School from families of prospective students in Year 1, the 2018-2019 school year. The applicant identified four District schools used as the basis for enrollment projections and to support their assertion that they would seek to enroll students primarily from specific targeted zip codes. However, the applicant did not include the seven charter schools in those zip codes – Mastery Charter School Clymer Elementary, Pan American Charter School, Universal Creighton Charter School, Mastery Charter School Cleveland Elementary, Mastery Charter School Gratz Campus, Esperanza Academy Charter School and Antonio Pantoja Charter School. All but three of these charter schools serve the same grade span as the proposed Charter School, as do the

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District schools in the applicant’s narrative (one is a K-6, and two are 6-12). Of the four K-8 charter schools in the targeted zip codes, all have higher attendance than the identified District schools; one has a SPP score higher than all four identified District schools; and the remaining three charter schools have SPP scores higher than three of four of the identified District schools. The applicant’s evidence to support the need for “high quality seats” is weakened when charter schools are included. Further, as one of the drivers of need was anecdotal evidence from the APM-operated early childhood centers, the inability of these families to be guaranteed a seat at the proposed school led evaluators to question the need, from a capacity standpoint, in these specific zip codes. Evaluators felt that the data the applicant chose to provide as evidence of why the proposed school is needed in the targeted community was inconsistent, inaccurate and omitted compelling contrary information. The Community Involvement and Support section of the application does have strong elements, however. The applicant seeks to target the same community in which it already operates multiple early childhood centers, and the applicant appears to have a general understanding of some of the communities' needs. However evaluators do note the concern that APM’s current relationship with the community does not include any experience in operating a K-8 public school which is what the applicant proposes. APM has provided some evidence of relationships with, and support from, organizations and leaders within the targeted communities. The applicant included 11 letters of support received from community organizations including Esperanza, Horizon House and Project Home, as well as from the State Representative of the 180th Legislative District, located just south of the proposed facility. Whereas the applicant provided evidence of interest in the proposed charter school, the applicant provided no evidence of student intent to enroll at APMCCS for the 2018-2019 school year from age or grade eligible students. The applicant submitted 266 documents, of various formats, that identified a parent or guardian's interest in the proposed school for a specific student. These documents were of different formats and some indicated a 2017-2018 school year. Ten (10) of these documents included a date of birth or student age of the interested students and of these it appeared that most if not all 10 would be age and grade eligible in the 2018-2019 school year. For the other documents indicating interest, some of which did not identify interest for the 20182019 school year, 256 indicated a grade level for the 2018-2019 school year that would be served by APMCCS in Year 1, grade levels K-4. However, due to the absence of a date of birth or age, evaluators could not confirm grade level eligibility especially for kindergarten (five years of age by September 1) and grade 1 (six years of age by September 1) for any of these interest forms. The applicant did demonstrate evidence of ongoing parent and family engagement. The Charter School proposes to have at least one parent as a voting member of the Board and a Home and School Association was listed as part of the organizational chart. Throughout the application narrative the applicant makes reference to supporting families of diverse cultural backgrounds and languages including providing translators for non-English or Spanish speakers and written translations of materials as needed.

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