January 22, 2018

The School District of Philadelphia

New Charter School Application Evaluation Report New Charter Application for: Franklin Towne Charter Middle School

Submitted by: Joseph M. Venditti, Esq., on behalf of Franklin Towne Charter Middle School

Application Evaluation Team: Team Lead:

Lauren Iannuccilli, Charter Schools Office

Evaluators:

Abena Osei, School District of Philadelphia Chester County Intermediate Unit DawnLynne Kacer, Charter Schools Office Roger Kligerman, Charter Schools Office Tim Hanser, Charter Schools Office

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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 Franklin Towne Charter Middle School (FTCMS or Charter School) Application Summary The applicant proposes that FTCMS would serve 450 students in Grades 6 through 8 in Year 1 and throughout the charter term. The proposed charter school would serve students beginning in the 2019-2020 school year. The Charter School would open at scale, enrolling 150 students per grade. The proposed charter school would offer an educational model founded on education, awareness and responsibility with a curriculum developed on the Understanding by Design model. The applicant proposes an academic plan that values a rigorous curriculum, emphasizes nutrition and fitness, and develops student character. The Charter School identifies two addresses for its proposed facility; both are in zip code 19137 in the Bridesburg neighborhood of Northeast Philadelphia: 5301 Tacony Street and 2275 Bridge Street. The Charter School would be co-located with FTCHS which uses space in this facility for a gymnasium and other student programming. \The Charter School would be operated by Franklin Towne Charter High School (FTCHS) through a management and shared service arrangement. FTCHS also currently operates another charter school, Franklin Towne Charter Elementary School, in Philadelphia; this school serves students in Kindergarten through Grade 8. These two charter schools collectively serve approximately 2,100 students. Analysis Summary Evaluators did not find that the stated mission of the proposed charter school addressed key aspects of the legislative intent of the Charter School Law (CSL) including improving student learning, increasing learning opportunities for all students and using innovative methods. Evaluators were also concerned due to a lack of coherence in the application regarding the proposed charter school’s mission - there is a second, different stated mission delineated in another area of the application. Evaluators identified a core curriculum and array of extracurricular activities that included real-world connections and a range of instructional methods including project-based learning and evidence-based teaching. However, the curricular materials submitted did not fully align to PA Academic Standards and were incomplete, preventing evaluators from determining the instructional goals and objectives, accessibility of instructional resources, and cultural relevancy of the curricular materials. Across all subjects to be taught in Year 1, standards were only partially evident with the exception of Math. Additionally, evaluators had serious concerns regarding the educational experience that would be provided for students requiring any kind of support outside of regular, classroom instruction and questioned the resources (funding, staff and programming) for proposed offerings. Further, evaluators found that the Charter School’s proposed exit standards could have a significant, disproportionate impact on certain subgroups of students. Evaluators also raised questions regarding the lack of a clear vision for the culture and climate of the proposed charter school and for the merit-consequence system which appears to rely on

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extrinsic motivation and teacher discretion which, as a result, could produce bias and disproportionality through the absence of clear, systemic implementation and established norms. In terms of organizational compliance, evaluators identified aspects of the Charter School’s enrollment and admissions practices that do not seem to be based on available data and may not be compliant. Evaluators found the budget to be generally credible and sustainable with a few exceptions. A joint area of concern for the evaluation team across organizational compliance and financial management pertains to related entities – the proposed Board, FTCHS and FTCMS leadership structures and relationships create a related party structure that results in potential conflicts of interest. As described in the application and demonstrated in the proposed organizational chart, there appear to be several degrees of separation between the Charter School’s board and the principal. Additionally, the service agreement does not provide for annual evaluation of these services or provide a right to termination for subpar performance. Further, FTCHS is proposed to simultaneously serve as both the charter operator through a management agreement and the landlord. In terms of community engagement and support, evaluators found that the applicant failed to provide sufficient evidence of intent to enroll for the Year 1 proposed enrollment of 450 students. Also, the applicant failed to present projected Charter School demographics of the targeted student population and evidence of engagement with a citywide school community. The evaluation team found that, throughout the application, the applicant provided referenced or cited Applicable Laws without explaining how these laws would influence or guide the actual policies and practices of the Charter School; examples of this include student enrollment, personnel and student due process. As such, in several areas of the application, specifically academic plan and organizational compliance, evaluators were unable to determine the capability of the applicant to provide comprehensive learning experiences to all students, as required by the CSL, or the likelihood of the Charter School’s policies and practices to be compliant with applicable federal, state and local laws. Mission of the School “To provide a structured, secure, and academically progressive educational environment grounded in an evidence-based PA Common Core aligned curriculum to 6th, 7th and 8th grade students.” Proposed Location The Charter School identifies two addresses for its proposed facility; both are in zip code 19137 in the Bridesburg neighborhood of Northeast Philadelphia: 5301 Tacony Street and 2275 Bridge Street. The Charter School would be co-located with FTCHS which uses space in this facility for a gymnasium and other student programming. Focus of the School/Academic Program In addition to developing core content proficiency, the Charter School’s academic approach seeks to develop students’ life-long learning skills and strong moral character exemplified through traits such as high self-esteem and respect for diversity.

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The proposed academic plan is predicated on the Understanding by Design (UbD) approach to curriculum design, a research-based approach that seeks to ensure that instructional staff share a common language with regards to curriculum. The applicant contends that this approach serves as the basis for ensuring that teachers across content areas, including special education teachers, are able to effectively communicate and collaborate with each other. Enrollment Projections Academic Year

Proposed Enrollment

Grades Served

2019-20

450

6-8

2020-21

450

6-8

2021-22

450

6-8

2022-23

450

6-8

2023-24

450

6-8

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 The proposed mission for FTCMS is missing key elements. Evaluators found that the mission statement lacked references to the legislative intent of the CSL, including improving student learning, increasing learning opportunities for of all students and using innovative teaching methods (page 1). Further, evaluators were concerned that the mission is inconsistently stated in the application – the mission as presented on page 2 of the application is different from that presented on page 7. It was also not clear that the proposed mission is unique and specific to FTCMS as opposed to merely being a restatement of the mission of the applicant team’s other charter schools, FTCHS and Franklin Towne Elementary School (FTCES). For example, the applicant failed to describe what aspects of the Charter School would make it “academically progressive” or how the application is uniquely tailored for the challenges of operating a successful stand-alone middle school. When analyzing the vision proposed by the applicant, evaluators found that it lacked a clear and compelling rationale for the proposed existence of this school. The vision lacked explanation for why a middle school serving grades 6-8 was needed in the proposed location, identification of measurable outcomes and a description of what might be experienced or observed at this school on an ongoing basis. Further, the mission and vision both failed to promote an innovative program design.

Academic Plan The applicant’s proposed academic plan has a stated focus on the mastery of core subjects and personalized learning to prepare students for the demands of the 21st century. Instructional techniques are purported to be based upon what the applicant believes are evidence-based pedagogical concepts such as multiple intelligences, cooperative interaction, scaffolded instruction and a spiral curriculum utilizing the backmapping techniques illustrated in the UbD model (page 4). Real-world connections would be built into the curriculum and multiple instructional methods would be used including project-based learning and evidence-based teaching. According to the applicant, the curriculum described could be modified to meet the needs of all learners (page 5); however, evidence of possible modifications or differentiation was limited, and the applicant failed to present a rationale for why the proposed curriculum and instructional model are likely to be successful with the targeted community and grade span. The application describes a personalized learning environment to allow for learning that could be “personal and relevant” to each student (page 7); yet, there is no reference to curriculum and instructional materials being culturally relevant and inclusive. As the applicant did not describe differentiation or cultural relevance of the curriculum, the absence of lessons plans in all subjects to be taught in Year 1 prevented evaluators from determining if these statements by the applicant would be realized. Further, the applicant makes conflicting references to the teacher’s use of the 6

curriculum; the applicant states both that the curriculum is scalable and easily modified to meet the needs of all learners (pages 8-9) but also that it is “highly scripted” (page 4) which appears to contradict an expectation that teachers would be actively modifying the curriculum to meet the needs of all learners in a culturally relevant and inclusive manner. In reviewing the curriculum, evaluators identified several gaps in alignment with the Pennsylvania Core Standards (PA Core) and noted several areas where a complete set of curricular materials were not provided. As the Charter School intends to open at full scale in Grades 6-8, curricular materials for all grade levels and subjects provided were reviewed; subjects provided were ELA, math, science, social studies, physical education/health and technology. Generally, evaluators found the curriculum to be narrowly focused in subject area and content with alignment to high stakes testing outcomes. As previously stated, lesson plans were not provided for any subject. Unit plans were only partially provided for ELA (via curriculum maps), science and social studies. Specific unit goals, objectives, assessments, instructional materials and resources were not identified for any subject area with the exception of ELA. The ELA curriculum was misaligned to the PA Core in that several Pennsylvania Academic Standards were not evident. For example, in Grade 7 ELA, alignment was not clearly evident for Informational Text and Writing, Informational Text, Reading Literature and Speaking and Listening. In Grade 8 ELA, Informational Text and Writing, Reading Literature, and Speaking and Listening were also not clearly aligned to the PA Core. The 8th Grade proposed math course is Geometry and is missing several standards from the Geometry section of the PA Core, as well as standards from other strands including solving equations and systems of equations. No curricular materials were provided for art or music or any specials beyond the aforementioned physical education/health and technology. There is also no information regarding student mastery included in the documentation even though the applicant states that mastery is a cornerstone of the educational program (page 8). Thus, the applicant failed to provide a clear and cohesive, locally developed curriculum with requisite curriculum materials for all grade levels and subjects to be taught in Year 1. The evaluation team found that in key aspects of the academic plan, instead of providing robust supporting details of the proposed school’s plan, the applicant instead relied on describing prior practices and the performance of other schools managed by FTCHS that serve different grade levels operated by this applicant (page 9-10). The applicant made minimal reference to the expected differences and likely challenges in serving students arriving in 6th grade and did not provide any data regarding the expected level of academic preparation of the incoming students. As such, the applicant failed to provide any evidence that the academic model, staffing model, curriculum or students supports would be able to meet student needs and ensure success. The applicant did however clearly identify how the curriculum would support gifted students or students seeking advanced learning opportunities. The applicant repeatedly made reference to the accolades received by their existing charter schools, yet evaluators found these references lacked full alignment to the proposed school. For example, for the 2016-2017 school year, 29.2% of fifth grade students in School District of Philadelphia (District) schools were below basic in ELA on the PSSA and 54.3% of fifth grade students in District schools were below basic in math on the PSSA. Conversely, at FTCES, 3.9% of fifth grade students were below basic in ELA and 6.9% of the same students were below basic in math in the 2016-2017 school year. The percent of fifth grade students scoring below basic in District schools, which presumably would be the target population for an applicant seeking to provide quality school choice options

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for students and families through the proposed Charter School, is seven times more than at FTCES. Yet, the application was mostly silent on how this achievement gap would be addressed and does not provide any rationale for why the proposed academic plan would best serve these students. Additionally, the budget lacked identification of targeted resources to assist academically struggling students (co-teachers, instructional coaches, multiple-tiered support service coordinators, etc.). The application mentions the success of the model at FTCHS and FTCES in supporting students with special needs and for accelerated students, but failed to provide clear programmatic details for how students with different disabilities and special needs, English Learners (ELs) and students who are below grade-level would be supported (pages 9-11). The application does include weekly progress monitoring for special education students and ELs, and teachers and other school staff would have access to student level data through Infinite Campus, the District’s student information system. Teachers are expected to meet the needs of individual students according to the plan; however, evaluators were concerned about the absence of clear details for how struggling students are supported through research-based interventions and supports. The application repeatedly advocates for the classroom teacher to be solely responsible for modifying instruction, and states that this approach allows the rigor level to stay high. The application notes pull-in and pull-out models as part of blended learning model, and the applicant believes that the teacher will “detect and resolves issues before they become more serious” (page 9). The RtII system is not incorporated in this response, nor any references to what triggers a more significant level of support. Evaluators indicated these plans appeared to generally focus on inputs instead of output (page 9, 15). In responding to how special education students and ELs would be supported inside and outside the classroom, the applicant only mentions after-school and office hour tutoring support and reinforces the success of FTCHS, which is a completely different grade band (page 10). In responding to the teaching methods, personnel and technology that would be used to support differentiated instruction, the applicant only highlighted IEP Writer, Edlio and Infinite Campus (page 13) all of which evaluators note are not instructional technologies but rather student information and caseload management systems. Evaluators were particularly concerned that no information was provided regarding expected enrollment levels of ELs, that the projected enrollment rate of special education students (12%) was 50 percent below that of the District average (18%) for Grades 6 through 8 and that the applicant did not indicate which of the 13 primary disabilities they would seek to serve via the proposed blended inclusion educational model. The submitted English as a Second Language (ESL) Policy appears outdated as it references No Child Left Behind (NCLB) and a Basic Education Circular (BEC) dated 2001 regarding Educating Students with Limited English Proficiency. The BEC, however, was updated in 2009 and 2017. The ESL Policy includes educational program descriptions that do not fully align with the recent 2017 BEC. The Language Instruction Education Plan (LIEP) suggested services outlined in the ESL Policy are not provided for Level 1 ELs, only Levels 2-5, which is noncompliant with PDE guidance. In addition, the narrative does not differentiate between special education support programs and EL support programs and primarily focuses on special education programming, not ESL programming (page 9). Based on the staffing plan provided, the special education teacher would be dual certified for ESL, which raised concerns about instructional staff capacity for evaluators. The degree of involvement of certified special education instructors or ESL instructors in differentiation and instructional shifts was also unclear (page 12). Further, 8

evaluators found no rationale for why W-APT evaluation would be done by a consultant as opposed to a directly employed certified ESL instructor (page 13), an instructor the proposed charter school would be required to employ if the Charter School enrolled any ELs. Evaluators found a lack of clarity and, in fact, contradictory elements in the proposed exit standards that could potentially lead to students being disproportionately affected. The applicant states that to pass Grade 8 in the Charter School, students must achieve a minimum grade of 70 in all core subject areas. Additionally, the applicant identifies retention factors such as: performing one or more grade levels below in reading; performing one or more grade levels below in math; poor classroom achievement; scores in the “lower range” on standardized testing data; or failing two or more core subjects. However, students failing two (or less) academic classes would have the opportunity to make up the credits during the summer (page 16). Evaluators were unable to determine which combination of retention factors reached a level of “significance” as stated by the applicant. Further, it was unclear if exit standards for Grade 8 were in addition to the retention standards or supplanted the retention standards. Further, it was not evident to evaluators what would happen to students who attempt the summer credit recovery but are unsuccessful in one or both of the courses and why students who fail three or more core subjects do not also have access to the summer credit recovery program. It was not clear to evaluators if students who failed one or both summer classes would then be denied promotion and therefore have high school acceptances rescinded or be prevented from transferring to other public schools prevented. There was also concern that the applicant’s promotion standards ignore the academic realities of many students coming into Grade 6 who may already be far below grade level and will struggle to reach grade-level proficiency in one academic year to allow for promotion to Grade 7. The “lower range” on standardized tests is not defined by the applicant but presuming the lowest range (below basic), in 2016-2017, 19.2% of all District students scored below basic in ELA and 57.1% scored below basic in math. This may have the effect of retaining a student because of prior learning environments that may have been insufficient or other access barriers that may have been present prior to entering the 6th grade at the proposed charter school. The applicant references the option for a direct instruction summer recovery program or an online credit recovery program (EduCere). However, the budget did not appear to include costs for summer instructional staffing or the EduCere program. It was unclear to evaluators how the summer credit recovery program would be funded. Evaluators found that the applicant’s description of interventions to prevent retention lacked specific details and questioned the credibility of the applicant’s statement that “It is recognized by this policy that retention is an option of last resort and all available options should be attempted first" (page 16). The applicant’s response regarding culture and climate did not describe a vision for the learning environment for the school. The content presented a broadly described incentive-based token system for students to earn rewards. The only behaviors described for receiving the awards in this system were “demonstrating appropriate and exemplary behavior both inside and outside of the classroom” (page 16). There was no vision stated of what one might see if looking in the classrooms and hallways at the proposed school. There was no plan offered for scaffolding the development of positive student-student relationships and student-teacher relationships in the school, nor were there mechanisms described for establishing and maintaining a positive culture. Evaluators had similar concerns with the proposed Code of Conduct, which is punitive and 9

seems to contradict the creation of a positive school environment. The co-mingling of academics and behavior in a merit system that is not research-based and the rationale for choosing this approach was were not clear (pages 16-17). Evaluators found that the applicant generally placed the burden for social-emotional health and the resulting behaviors on students. The application references the character education program as a way for at-risk students to overcome challenges that could affect their academic learning without specifically identifying the social-emotional supports the Charter School would provide. This left evaluators questioning whether the applicant understood the distinction between character education and values and student risk factors and social-emotional and behavioral health needs. Particularly concerning to evaluators was the applicant’s response to describing the Charter School’s programs or strategies to address student mental, emotional, and social development and health. In response to this prompt, the application includes two tables that list District school outcomes (achievement) compared to FTCHS and FTCES and follows with a statement that based on the data, “FTCMS will be able to meet the academic, social, and emotional needs of the student population” (page 19). The application was silent towards the identification of students experiencing trauma, students whom may be in foster care or who have health issues that may be chronic and that would impact their educational experience. There is no evidence provided anecdotally or via data in this section that the applicant team possesses a thorough understanding of the risk factors that students from Philadelphia may have and/or that there is a credible plan to serve such students. Further, evaluators indicated that the response from the applicant does not reflect a complete or comprehensive understanding of needs and supports that students who are at-risk have or might need. The application was silent towards the identification of students experiencing trauma, students n foster care or students with chronic health issues that would impact their educational experience. There is no evidence provided anecdotally or via data in this section that the applicant team possesses a thorough understanding of the risk factors that students from Philadelphia may have and/or that there is a credible plan to serve such students. Furthermore, while the application notes many trained professionals to call upon when necessary to address students’ needs,, including nurses, school counselors and psychologists, the budget only includes contract nurse services and one school psychologist/counselor. As a result, evaluators were uncertain whether necessary interventions, staffing shifts and budgetary adjustments to provide more intense interventions as necessary would be actualized (page 13). Evaluators found that the application lacked sufficient detail regarding the challenges that enrolled students may face or the expected percentage of students who may experience trauma, mental health issues, homelessness or other social-emotional risks to academic success. Further, the applicant failed to present social, emotional or physical health or risk factor student data and/or a qualitative, comprehensive awareness of likely student needs based on the Charter School’s proposed location or citywide enrollment (page 19). To engage students beyond the core curriculum, the Charter School proposes to offer a range of extracurricular activities that would meet at least weekly. The proposed activities include Towne Historical Society, video production, yearbook, photography, cooking, STREAM, best buddies, debate, National Honor Society, flag football, dodgeball, ultimate Frisbee, kickball and

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basketball. There are also student-led groups such as the student leadership committee, a “No Place for Hate” committee, student government and Towne Mentors (page 18). Although evaluators found the breadth of activities and student engagement opportunities to be a strength of the application, they were concerned that there appears to be no budget for extracurricular activities. Evaluators were unclear if there were fees or costs for students to participate in some or all of these activities; if so, evaluators would find such fees or costs to be a barrier to student access to the activities and an equity concern. Whereas there is mention of sponsorship and support for the student leadership and “No Place for Hate” committees, there are no letters of support, contracts or Memoranda of Understanding (MOUs) for community partners to operate, support and/or fund these activities at the Charter School. The applicant refers to a nearby Boys & Girls Club of America that would provide mentoring opportunities but the description of the proposed partnership lacked detail (page 17). Regarding proposed academic goals, evaluators noted that the goals for closing the achievement gap lacked performance thresholds or targets (page 20); specific subgroups were not identified (page 24); academic goals did not identify the thresholds at which Board involvement would be triggered (page 20), and the process for making any necessary program changes was unclear (page 24). The failure to establish performance goals and annual targets for all students and for student subgroups is not aligned to the expectations of the Every Students Succeeds Act (ESSA) or Pennsylvania’s response to ESSA as detailed in the PA Consolidated Plan. ESSA requires assessment, monitoring and evaluation of students at the subgroup level, and the PA Consolidated Plan establishes specific annual goals that public schools are to achieve to close achievement gaps with state performance averages on standardized tests and for specific student subgroups.

Organizational Compliance In the application’s organizational compliance section, evaluators noted the founding coalition’s experience and knowledge gained from operating charter schools in Philadelphia; however, some areas of expertise that evaluators would expect for a founding Board of Trustees opening an independently-operated urban public charter school serving middle school grades, including individuals with education and finance backgrounds, were not evident. The application does not consider the unique challenges associated with launching a standalone middle school. While the applicant’s other schools may have experienced prior success, the application fails to thoroughly demonstrate that the Charter School will have the necessary and dedicated resources in place to replicate the successes. The evaluation team found strength in the applicant’s proposed approach to recruiting and hiring staff, especially considering the amount of time that the Charter School would have before starting in school year 2019-2020. Additionally, the applicant proposes a teacher mentor program with the opportunity for peer observations to further staff development. However, evaluators noted several concerns in the Organizational section, beginning with the lottery and waitlist process as presented in the Admissions Policy. There appear to be conflicts about whom has first lottery preference in the admissions policy - siblings or Philadelphia residents - when the CSL requires first preference to be for Philadelphia residents. The Charter School also does not propose to use a waitlist based on initial lottery results, but rather rerun the 11

lottery results for each available new seat (page 39). This was a concern for evaluators as students on the waitlist would have their position reordered each and every time a seat became available providing no predictability in the school choice process for students and families. While resumes were provided for proposed board members, most resumes lacked sufficient detail to determine relevant expertise, experience or possible conflicts of interest. Additionally, based on the application narrative, the process for appointing the initial board of trustees for FTCMS created potential conflict issues because board members for the Charter School will be appointed by the incorporator, FTCHS, which is also a proposed management company of FTCMS and proposed landlord for FTCMS of the proposed facility (page 26). This appointment by the CEO of a related party with multiple interests in the Charter School is a conflict of interest concern for evaluators. Further, it appears that at least four of the five proposed Board members for the Charter School are also board members of FTCHS, suggesting a conflict of interest (Attachment 21). Evaluators also were concerned that parent members of the Board would not be how the voting members (pages 43-44). The Charter School submitted a business management agreement with as well as a management services agreement with FTCHS; Although it appears that FTCHS is the charter management company for the Charter School, it was not clear if there might be an overlap of business, budgeting and financial functions between FTCHS and Omnivest. The service agreement with FTCHS did not provide any information nor state as a requirement of the agreement a regular evaluation of the services provided by FTCHS by the FTCMS Board. The service agreement also lacked any clear accountability for poor performance by FTCHS, as charter manager, and there were no provisions giving FTCMS the right to terminate the agreement for poor performance by FTCHS (page 35). This is particularly concerning given that the included organizational chart shows the Charter School’s Board reporting to FTCHS, the charter school management organization. Additionally, the services agreement with FTCHS provides for a $250,000 management fee in Year 1; however, the services agreement does not clearly state what services are being provided for the $250,000 fee. The services agreement does state, however, that there is no fee for start-up services. (Attachment 24) The Charter School’s startup functions and responsibilities are not detailed and areas of responsibility for the Board of Trustees regarding school performance are unclear (page 49). There also were discrepancies between the management staffing allocation, overall organizational chart and services in the management agreement, such as technology and student services/special education. The Charter School’s school leader/principal has not yet been identified; failure to identify a school leader/principal during the formation of a charter school is a characteristic of charter schools that have failed nationally in the initial years after opening. The organizational chart suggests several degrees of separation between the Board of Trustees of the Charter School and the principal, which led to evaluator’s concerns for accountability and assumption of responsibility by the Board for the Charter School’s performance. The applicant’s responses regarding evaluation and accountability for instructional staff are vague and the performance evaluation narrative does not identify FTCMS’s efforts to support improvement for and

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intervention with struggling staff (page 34). The number of evaluation cycles for non-permanent teachers is also inconsistently stated as both two and four (page 31). Inconsistent statements are made in the application about the number of proposed special education instructors. The applicant narrative states that there will be three special education instructors; however, the staffing table indicates that there will be five special education instructors (pages 30 and 31). The applicant makes reference to hiring only “highly qualified teachers”; however, this designation was related to the federal accountability requirements, which preceded ESSA, and the highly qualified designation is no longer applicable. The absence of an on-staff, certified ESL instructor who does not also have a role within the special education team is an ongoing concern. Regarding school operations, the application includes compliant school calendar with over 1200 hours of proposed instructional time per year. The schedule also integrates weekly professional development (PD) time for teachers through scheduled early dismissal days for students. The application acknowledges the policies and procedures regarding transportation and working with the District to distribute SEPTA Transpasses to eligible students. The Charter School has identified a food service vendor and pledges to serve breakfast and lunch on a daily basis in accordance with state and federal guidelines (page 36). It was not clear to evaluators that the Charter School intends on participating in the National School Lunch Program (NSLP) and/or the School Breakfast Program (SBP) specifically. Employee benefits including healthcare and retirement appear to be appropriate and generally aligned with District benefits. A 403(b) retirement plan will be administered by PennServ and all employees are required to participate (page 34, Attachment 13). Although the applicant submitted a “PSERS Alternative Plan Start-up Kit” and questionnaire, it is not clear whether the proposed retirement plan has been approved by PSERS (Attachment 13). Healthcare benefits will be offered to all full-time employees of the Charter School (page 34). Included in the healthcare benefits are medical, prescription, dental and vision coverages that purport to be substantially similar to the District’s. The application also provided a thorough dissolution and communication plan with the community in the event that the proposed school would have to close, noted by evaluators as robust (page 47).

Finance and Facilities In the Finance section, evaluators noted a thorough and detailed discussion of budget assumptions and five-year projections, but also identified some areas of concern. Regarding staffing expenditures, there is no ESL instructor included in the budget, and the applicant instead proposes reliance on a teacher who is dually certified in ESL and Special Education. If the projected caseloads change and an ESL instructor needs to be hired separately, the Charter School would need to either add a position to its budget or eliminate one of the positions identified within the budget. The average percentage of ELs in Grades 6-8 in District schools is 10%; considering the Charter School’s Year 1 enrollment of 450 students, this could result in 45 ELs enrolled at FTCMS. The budgeted allotment for special education services, $30,000, is significantly below charter sector average expenditures per special education student and based 13

on the applicant’s projections, would allow for less than $600 per student in related and support services. Not only is this insufficient to support many high-incidence and all low-incidence special education students, if the Charter School’s enrollment approximates the District or charter sector averages of 18% special education enrollment, this allocation becomes much smaller. Evaluators also noted that the applicant does not address the question about non-realization of expected revenues and expenditures. A reiteration of expenditure assumptions is all that is provided (page 49). The applicant was also non-responsive to the prompt regarding “other funding opportunities” (pages 49-50). The comments following the prompt are addressing expenditure assumptions, not how the proposed charter school would raise revenues. Of particular concern was the assumption that Omnivest, the Charter School’s proposed business manager, and FTCHS would provide support and assistance during start-up phase through June 30, 2019 at no cost and with no evident reimbursement once the Charter School was open and operating (page 52). In the Financial Policies provided with the application (Attachment 28), there are references to “College” and “Vassar College” in the documents (Travel and Business Expense Reimbursement Guidelines II.D, III). There are also several references to FTCHS (pages 1 and 2, Attachment 28) that suggest the proposed charter school would be required to cover costs associated with the charter manager, and that FTCHS would hold funds from the Charter School in interest bearing accounts. There are also references to foreign travel as well as situations that warrant the use of first class and business class air travel; evaluators were unclear as to why these policies would exist or be necessary and if followed, the rationale for permitting use of public funds for business or first class accommodations. The travel policy also describes a per-diem reimbursement for meals and incidentals based on IRS guidelines but permits the CEO and Principal to receive either the rate recommended by the IRS or $200, whichever is higher. Evaluators questioned the decision to permit such a high reimbursement rate given that the IRS-recommended per diem for meals and incidentals is $64 for Philadelphia and caps at $74 for high-cost localities (GSA). In the provided Year 1 detailed budget, revenues match the application narrative and are reasonable. The Expenditures section, however, raised questions from evaluators about the lack of appropriated funds for extracurricular activities and/or overtime for staff. Evaluators also noted that there is no budget for substitute teachers and no apparent expenditures for staffing a summer school/credit recovery program. In the Purchased Professional and Technical Services section and in the application narrative (page 50), “Other Professional Services” are budgeted for $9,000. Evaluators could not identify the purpose of these services. The proposed budget also appears to have miscategorized certain line items based on the PA Chart of Accounts. For example, in the Purchased Property Services section, Electricity and Gas should be in supplies, and Classroom and Computer Equipment would be expected to be found in Property unless these expenses are not being capitalized. In the five-year budget, per pupil rates are assumed to increase 2% each year for both general and special education. Evaluators felt that these assumptions were optimistic; however, the expenditure assumptions are reasonable, and there may be sufficient fund balances in the out years to cover any per pupil rates that are lower than anticipated. Further, the school does not

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propose specific financial health metrics or targets for self-evaluation and monitoring of the Charter School’s own fiscal health. The proposed charter school did not provide a solid contingency plan if revenues are flat or decline (page 49). The proposed facility, listed with addresses at 2275 Bridge Street and 5301 Tacony Street, is owned by FTCHS, and it appears that FTCHS would serve as the Charter School’s landlord. Potential conflict of interest and related parties concerns were raised as FTCHS will also serve as the management organization, and FTCHS and FTCMS have overlapping membership for their respective charter school Board of Trustees. The Charter School submitted a draft lease agreement with an annual rental cost of $6.00 per square foot. The lease would be between FTCHS (landlord) and FTCMS (tenant). It is not clear who would negotiate or sign the lease on behalf of each party, and the arrangement calls into question the ability of FTCHS and FTCMS to meaningfully negotiate any potentials concerns that may arise regarding the lease and facility. It is also not clear why the Notice section of the proposed lease calls for communications under the lease for FTCMS to be sent to 4259 Richmond Street, the location of FTCES (Attachment 33). Currently the facility is still in need of renovations that the Charter School expects to fund with a $3.5m leasehold mortgage. Evaluators found that the proposed charter school’s facility description identifies only 17 classrooms (page 54); however, core classrooms needed per facility plan and expected enrollment levels is 18 (Attachment 34). Furthermore, the provided student capacity by room to reach 450 students ranges from 18 students to 35 students, raising questions of appropriateness for class sizes and scheduling. The proposed lease also does not sufficiently clarify the use of the gymnasium and other common areas, which are controlled by FTCHS, the landlord, and principally occupied by FTCHS.

Family and Community Engagement and Support Regarding the needs and priorities of the District and targeted population, the application does not include a thorough evaluation of the District's needs, student population or demographics of middle school students. There was also no comprehensive identification of student needs, risk factors or challenges which can affect academic success. The percentage of ELs at Bridesburg, Stearne and Disston is, respectfully, 2%,7%, and 8% . As of the 2010 Census, Bridesburg had a population of 8,638 (out of 1.6 million people in Philadelphia). Evaluators noted that the applicant did not make a compelling case for why such a neighborhood of less than 10,000 people needs another charter middle school. If, however, the Charter School does intend to serve a citywide population, even though comparative student demographic data was provided only for neighborhood District schools, then the projected enrollment of ELs and students with disabilities is too low and information regarding projected numbers of economically disadvantaged students and students of color were not provided. There was no acknowledgement of the larger EL and poverty enrollments at the schools in the table nor any indicating of wanting to serve students outside of the Bridesburg area. The applicant submitted 21 letters of support from community and business leaders in addition to five letters from elected officials. It appears that the applicant hosted community events but failed to provide any evidence or indication of who attended, how the events were advertised and what specific feedback was received at each event. The applicant submitted with the application 15

a total of 234 non-duplicate Intent to Enroll forms. Most of these forms were submitted prior to the start of the 2017-2018 school year; in fact, it appears that a large number of the intent to enroll forms were filled out by then current 7th graders in the 2015-2016 or 2016-2017 school year, Only 84 of the intent to enroll forms appear to be for grade and/or age eligible students for the proposed grade span in school year 2019-2020. These 84 grade and/or age eligible Letters of Intent represent only 19% of the requested Year 1 seats; evaluators did not find this to be sufficient evidence of demand or support for sustainable enrollment at the proposed charter school. Additionally, the applicant made statements about large waiting lists for FTCHS and FTCES (ages 61-62); however, applicant did not submit any waitlist information to support its claims of about the waitlist for Grades 6-8. The application includes a plan for engaging families through various means including online portals, plans to hold town hall style meetings monthly pre-opening and a stated intention to communicate with families in their native language. The student engagement section is not addressed at all in the application (the applicant was non-responsive to this section), and it is unclear what accommodations may be made to engage families with accessibility or availability challenges or without high speed computer access. The application does identify the production of an annual FTCMS report with performance data and real-time access to student level data via the various online portals.

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