January 24, 2018

The School District of Philadelphia

New Charter School Application Evaluation Report New Charter Application for: Philadelphia Hebrew Public Charter School

Submitted by: Hebrew Public

Application Evaluation Team: Team Lead:

Lauren Iannuccilli, Charter Schools Office

Evaluators:

Ashley Sobrinski, School District of Philadelphia Chester County Intermediate Unit Francheska Howard, External Evaluator Natalie Wilson, 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 Philadelphia Hebrew Public Charter School (PHPCS or Charter School)

Application Summary The applicant proposes that PHPCS would serve 702 students in Kindergarten through Grade 8 at scale. The proposed charter school would serve students beginning in the 2019-2020 school year. The Charter School does not propose to reach scale until school year 2026-2027 in its proposed eighth year of operation. In Year 1, the Charter School plans to serve 156 students in Kindergarten and Grade 1; in Year 2, the Charter School plans to serve 234 students in Kindergarten through Grade 2; in Year 3, the Charter School plans to serve 312 students in Kindergarten through Grade 3; in Year 4, the Charter School plans to serve 390 students in Kindergarten through Grade 4; in Year 5, the Charter School plans to serve 468 students in Kindergarten through Grade 5; the Charter School would continue to phase-in and increase enrollment by 78 students and one grade level per year after Year 5 reaching scale as a K-8 with 702 students in Year 8. The proposed location for the Charter School is 3300 Henry Avenue, Philadelphia, PA 19129 in the East Falls section of the city. This location is known as the “Falls Center” and is the current location of several other tenants that are businesses, medical service providers, and educational institutions, including Eastern University Academy Charter School. The proposed school would utilize components of the Hebrew Public educational model. The applicant, Hebrew Public Charter Schools (Hebrew Public) is an experienced charter operator with three charter schools under direct management in New York that collectively serve approximately 1250 students in Kindergarten through 8th Grade. Hebrew Public is also affiliated with five schools not under direct management. Hebrew Public has not managed any charter schools in Pennsylvania.

Analysis Summary Although the applicant included a comprehensive high-level description of the proposed school, the application did not clearly differentiate the Charter School’s mission and vision, and evaluators indicated feasibility concerns regarding the creation of a deliberately diverse student body with the core content focus and targeted community area proposed. Evaluators indicated that the response from the applicant in this section reflects high expectations for students, but measuring the success of the proposed mission and vision may be difficult in the initial term of the charter. For example, it is not clear how the applicant will determine whether students have become “ethical” and/or have developed “a strong sense of social and civic responsibility,” as is stated in the application. The applicant was responsive to the questions and prompts from the application instructions, but evaluators noted certain areas of concern in the Organizational Compliance section including, but not limited to, the recruitment and hiring of staff, staffing plan and alignment of the Code of Conduct with the climate and culture description. There were also concerns noted in the Finance section related to assumptions for the cost of benefits and overall fund balance. Budget flexibility

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does not appear to be included should added costs arise and the Charter School could be in a deficit in Year 1. Evaluators indicated that the Community Engagement and Support sections demonstrated a robust engagement of potential community partners, especially considering that the applicant has not previously operated a school in Pennsylvania. There were concerns, however, regarding the targeted community and evidence that the Charter School would be able to attract and enroll as per its projections.

Mission of the School “Philadelphia Hebrew Public will provide its students with the foundation necessary to pursue advanced studies and become ethical and informed global citizens. PHP will offer a rigorous K8 curriculum, which includes four periods each week of immersive instruction in Modern Hebrew. Our diverse student body will develop a strong sense of social and civic responsibility through the integration of service learning.”

Proposed Location The proposed charter school would be located at 3300 Henry Avenue, Philadelphia, PA 19129 in the East Falls section of Philadelphia.

Focus of the School/Academic Program The applicant’s proposed model aims to operate an academically rigorous dual-language charter school that teaches children of all backgrounds to become fluent and literate in Modern Hebrew and prepares students to be productive global citizens. The essential elements of the academic program as presented by the applicant include immersive Hebrew language instruction four days a week; integration of the Culture and History of Israel and its Immigrant Communities (CHIIC) curriculum into the overall curriculum; implementation of service learning and related activities for social responsibility and understanding diverse cultures; and serving the full range of students in the community. The Charter School proposes to recruit and enroll an intentionally racially and economically diverse student population, “diverse by design”, and develop ethical and global citizens. The instructional model will rely upon a gradual release framework, “I-We-You”, and utilize co-teaching and small group instruction to deliver targeted instruction. All students will have an Individual Learning Pathway (ILP).

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Enrollment Projections Academic Year

Proposed Enrollment

Grades Served

2019-20

156

K-1

2020-21

234

K-2

2021-22

312

K-3

2022-23

390

K-4

2023-24*

468

K-5

*The Charter School would not reach scale of grades served or maximum authorized enrollment until Year 8, 20262027, when the proposed charter school would be a Kindergarten through Grade 8 school serving 702 students.

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 applicant did not clearly state and present the mission and vision as separate, distinct concepts and instead discussed them together. As such, it was not clear to evaluators what the proposed charter school intended as its purpose versus the long-term hope for what the charter school would seek to realize. Additionally, there were variations of a mission “statement” presented throughout the application with a more expansive purpose that included “teach(ing) children of all backgrounds” in the Management Agreement (Attachment 24) than in the application narrative (page 4) in which the students to be served were not identified. However as noted later, the Management Agreement does not appear to be for PHPCS; therefore, evaluators were unclear if the identification of the students to be served in that document was consistent with the proposed mission and purpose for this Charter School. Additionally, the mission and vision do not clearly identify in a measurable way what will be achieved; it was not clear to evaluators what standardized metrics PHPCS would use to evaluate a foundation for pursuing advanced studies or at what level this pursuit was expected (i.e. high school, college, career) or how the Charter School would measure and evaluate the degree of being an ethical and informed global citizen. Evaluators did note that one of the primary components of the mission and purpose as identified in one part of the application, operating an academically rigorous duallanguage charter school, is aligned with the applicant’s stated intent in the academic plan to develop and deliver a rigorous K-8 curriculum and that this reflects high expectations for students and is readily measurable. The Hebrew Language program and diverse by design model are not currently options in K-8 public schools in Philadelphia and reflect some innovation on the part of the applicant team; both these components are also evidence-based as supported by recent research. However, evaluators noted that it is not clear how the immersive teaching of Modern Hebrew language, one of essential elements of the educational program identified by the applicant, aligns with or is likely to be sought out by the target student population and community as presented in the application. Concerns were raised with realizing the stated goal to recruit a truly diverse student body with this core content focus.

Academic Plan The Charter School’s proposed academic plan has three primary components: a rigorous K-8 curriculum, a school community that is diverse by design and immersive Modern Hebrew language instruction. The applicant proposes to build its culture based on diversity in the student

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body, global citizenship values, personalized instruction and a school vision supported by Restorative Practices. The applicant’s stated educational philosophy is that “students learn best when they are in a context of diversity, surrounded by clear, consistent systems of support, and when given opportunities to learn individually and together” (page 4). The proposed charter school would be managed and operated by a Charter Management Organization (CMO), proposed by the applicant to be Hebrew Public, that uses an approach that purports to combine “research-based elements in its program design, including: a partial immersion program in Modern Hebrew; racial and economic diversity; and a rigorous academic program” (page 4). Evaluators found the educational philosophy to be aligned to the mission and vision, proposed instructional techniques and the CMO’s academic model. Evaluators also noted the applicant’s prioritization of developing students who engage their civic responsibility and see themselves as global citizens. However, evaluators noted that it was unclear exactly how global citizenship would be infused across the curriculum beyond annual service learning projects. The Charter School would place a focus on empathy, teamwork and cross-cultural communication and, while the evaluation team indicated that there may be difficulty in terms of measuring success for these areas, the aspirational nature and relevance in a 21st century society was seen as a strength in this section. Evaluators also noted that there is a research basis for intentional diversity in a school’s student population and that the research demonstrates academic benefits for all student subgroups. While evaluating the proposed curricular components, evaluators noted that the applicant specified adopting the Modern Hebrew curriculum to be aligned with the Pennsylvania Academic Standards but merely indicated that the other subject areas were aligned to the Pennsylvania Core (PA Core). As the other subjects utilize curriculums not developed specifically for the PA Core, evaluators were concerned about full alignment. Evaluators identified that the Eureka Math program and components of the English Language Arts (ELA) curriculum are aligned to national Common Core Learning Standards and not fully aligned to PA Core. Further, the social studies curriculum is aligned to PA Core standards for reading and writing in social studies and the Social Studies 3C framework but not fully aligned to PA Academic Standards for social studies. As such, a comprehensive analysis of the standards gaps in those subjects is not possible. In Kindegarten and Grade 1, full packages containing student activities and assessments from the Eureka program are provided, but it was not possible to determine student mastery – the extent to which it provides appropriate, ample educational opportunities for students’ application, practice and mastery of each standard, what practices are being used and why they are likely to be effective with the expected student body. Based on what was provided, it also was not feasible to determine the instructional goals and objectives beyond what may have been included in the broad lesson plans from the publisher; lesson plan templates were provided but not completed for math. The standards for Kindergarten through Grade 8 were clearly organized within the ELA curricular standards map which addressed all categories of ELA (foundational skills, reading, informational text, literature, writing and speaking and listening). For grade levels that would be taught in Year 1, ELA standards were not clearly evident for Kindergarten in the areas of Foundational Skills, Informational Text, Literature and especially Writing and for Grade 1 in the areas of Informational Text, Reading Literature and especially Writing. In regards to non-core courses, there is a plan to offer physical

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education in Year 1; however, the applicant indicates that art and music would be incorporated into other subject areas initially. Lesson plans were provided for social studies and partially provided for ELA and Math, but for no other subject. Unit plans were provided for social studies, science and math, but only partially provided for ELA, art, music and physical education. Evidence of differentiation was not provided for math or physical education and only partially provided in all other subject areas for which curricular materials were submitted (Attachment 1). In response to the Academic Data & Goals section, the applicant included all requested information including the goals, performance benchmarks, progress monitoring procedures and other assessments that would be used to measure academic success. Also included is a comprehensive data-driven program including how data will be reviewed, collected, analyzed and used to monitor the achievement gap. Clear and compelling details regarding the frequency and type of training that would be provided to teachers and how data would be used by teachers in decision-making and instructional shifts is also present, along with what might trigger corrective actions (pages 33-36). Evaluators also noted that the applicant made an attempt to incorporate measures from the draft Pennsylvania Consolidated Plan, developed in response to requirements of the Every Student Succeeds Act (ESSA), including chronic absenteeism, career readiness for Grades 5 and 8 and academic performance for some, but not all, ESSA identified student sub-groups (pages 31-33, Attachment 3). Evaluators did note in the assessment plan that students who score basic or below basic on the PSSAs will receive interventions, which could be a significant portion of the student population, particularly in math, given current city performance on the exams. This led to concerns for the school’s capacity to deliver interventions successfully on that possible scale, based on the staffing plan (Attachments 1,4). The applicant provided a robust intervention program that builds on the proposed data-based, individualized instructional planning (page 10). The applicant intends to use a Gradual Release of Responsibility (GRR) framework to support peer learning and differentiation. This “I-WeYou” model will be coupled with small-group instruction and the ILPs which will incorporate differentiation and targeted instructional practices for all students inclusive of their academic as well as social-emotional needs. The applicant also provided sufficient research-based evidence of the positive academic outcomes of diverse student populations to support this component of the educational philosophy. The applicant proposes a clear, systematic process to identify a range of student needs and ensure those students receive the appropriate supports. This system for identification is followed by clear processes for referral and evaluation of student needs. The proposed charter school would use a multi-tiered system of supports (MTSS) to differentiate between the levels of student need ranging from Tier 1 to Tier 3 (page 18). Child Find procedures are clearly delineated and compliant; in addition to special education staff, general education staff would also receive training in the Child Find process (Attachment 37) and provide proactive accommodations to all students in the Tier 1 general education environment. Teaching methods, personnel and budget prioritizations are identified to indicate capacity to differentiate instruction for all students. The proposed charter school will engage in regular assessment cycles, with a particular emphasis on the MAP assessment. Although the assessment plan provided is comprehensive; evaluators note concern with an assessment program relying so heavily on the MAP assessment and not

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incorporating more of the tools available for PVAAS at the student, classroom/teacher, grade and school level. The applicant has detailed a comprehensive plan to support at-risk and accelerated learners. However, evaluators did note that, although the applicant provided a significant level of detail regarding poverty, race, student and resident demographics and density for Philadelphia neighborhoods, the application lacked sufficient detail regarding the projected at-risk student population the Charter School might serve with no identification of enrollment, services or supports for students in foster care, court involved youth, youth in temporary housing or students experiencing trauma. In terms of social emotional support for students, evaluators indicated that the proposed Charter School’s plan is reactive and relies heavily on staff recognition of issues (page 31). The applicant is projecting a Special Education population of approximately 14% for Year 1 increasing to 17% at scale; 17% is between the rate for the School District of Philadelphia (District) and Philadelphia charter sector. Evaluators found the staffing plan for supporting Special Education students to be sufficient (page 20); the plan includes two full-time special education teachers in Year 1 with a projected special education population of approximately 24 students. At scale, the proposed charter school estimates that it would have nine Special Education teachers for approximately 120 special education students (Attachment 8). Evaluators indicated that there appeared to be intentionality in forecasting the diversity amongst the Special Education population with inclusion, co-teaching and resource room models proposed. The applicant presents a clear plan for assessments, additional accommodations and modifications in accordance with Individualized Education Programs (IEPs) and provides sufficient details regarding the plan for progress monitoring of student IEP goals. Students are assessed using MAP and classroom-based assessments three times per year. The applicant offers a comprehensive plan to communicate progress of students with IEPs to families through formal and informal means (page 20). The applicant presents a clear, cohesive and highly detailed plan for English Learners (ELs) including appropriate processes for identification, notification, annual assessment and exit monitoring process. It appears to be aligned with the updated Basic Education Circular (BEC) published by the Pennsylvania Department of Education (PDE). The applicant submitted a detailed Language Instruction Educational Program (LIEP) and included academic goals so that ELs would reach an expected level of proficiency within a target number of years based on baseline (Attachments 2 and 3). Evaluators did note concern for staffing to support ELs; the applicant plans for a part-time English as a Second Language (ESL) teacher in Year 1 unless enrollment of ELs exceeds 10% which would be sufficient for 9-16 students in Year 1. When the school is at scale in Year 8, however, the Charter School has planned for only one ESL teacher, which would be inadequate if 6-10% of the student population is ELs; the District average is 10% (page 20). Further, it was not clear to evaluators how one staff member would support a case load of 42-70 ELs as well as manage evaluation, notification, annual assessment and post-exit monitoring across nine grade levels at scale. The applicant’s academic outcomes in their currently operating charter schools generally reflect outperforming comparison groups (New York City and peer schools) and a narrowing of the achievement gap for at-risk subgroups (page 8), with the exception of the applicant underperforming New York City district schools in ELA for economically disadvantaged 9

students. It was not clear to evaluators if this performance data was relevant to Philadelphia or Pennsylvania as different assessments and academic standards exist in Pennsylvania and as the current achievement gap between Philadelphia students and the Commonwealth is far greater than that of New York City. The applicant does propose a variety of measures to evaluate the achievement gap including performance on the PSSA and the MAP assessment; however, only growth, not proficiency, for selected student sub-groups is being evaluated by the Charter School, which is not consistent with the PA Consolidated Plan. The exit standards reflect rigor and high expectations, in addition to an emphasis on career exploration; however, evaluators had some concerns. Regarding credit recovery offerings, it was not clear to evaluators if the applicant intends to provide summer school and/or if there would be a cost to families associated with taking summer courses (page 24). Evaluators did not note any budgeted expenses for summer programming or extended school year. The applicant’s plan for students not meeting benchmarks at the end of summer school includes being retained, if it is determined to be in the child’s best interests by school leadership in collaboration with the parents. Evaluators noted concern for the case-by-case determination, which being subjective, could result in disproportionality for students. Additionally, considering the rigor of their promotion criteria, there could be a significant number of students requiring summer school and potentially not being promoted to the next grade. Evaluators also noted that there appeared to be discordance between the promotion criteria for Kindergarten to Grade 7 for Hebrew language, where proficiency was not required for promotion, and exit standards for which Hebrew language proficiency is identified as a requirement (page 25). In the culture and climate section, the applicant provided an extensive plan outlining a positive, student-centered learning environment, which is based on three mutually-reinforcing sets of beliefs. The applicant states “we believe that our students excel when school builds on the cultural capital of diverse community members – when all students gifts are recognized, developed, and celebrated. Second, we believe that school must be a place where our students learn and practice global citizenship values of mutual respect and fairness, the core tenets of a successful democracy. And third, we believe that students learn best when the learning environment is designed to effectively scaffold engaging, customizable instruction” (page 26). Evaluators indicated that these beliefs are in alignment with the school’s mission and vision and are appropriately aspirational. The application includes a plan for a commitment to diversity, the use of Restorative Practices, family participation, student centered-learning and engaging the community. The application also highlights the Charter School’s character education program that blends the five components of social and emotional learning: self awareness, self management, social awareness, relationship skills, and responsible decision-making (page 14). The applicant identified a wide range of possible extracurricular activities for students and has begun to identify and engage potential community partners, yet Memorandums of Understanding (MOUs) and/or contracts were not provided for all of these proposed partnerships (page 30). Based on the information presented in the application, it did not appear that there would be barriers to participation in the form of fees or other requirements; however, in light of the absence of MOUs for all partnerships, it was not clear that partners would pay for all program costs for proposed activities and the Charter School budget does not include expenses for extracurriculars in Year 1. As the application does not clearly reflect that the proposed school has secured the services or funding from any community-based organizations to provide

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activities, only noting possible partnerships of interest in the future, it was unclear what activities would be available to students in Year 1 and out years (page 27 and Attachment 36).

Organizational Compliance Evaluators indicated that the founding coalition and applicant team and proposed business vendor have the range of required expertise to support the various facets of opening and operating a charter school and detailed resumes have been submitted. The founding coalition includes expertise in real estate, non-profit organizations, K-8 urban education and charter schools, special education, mental health, literacy, real estate, dual-language and communications. Although evaluators noted that failing to identify a school leader during the development of the charter proposal is a common cause for charter school failure according to research, evaluators found the applicant team’s commitment to hiring an Executive Director one year prior to serving students and a Head of School by January 2019 a strength. The Charter School will utilize U.S. Department of Education Charter School Program (CSP) grant funds to support this early onboarding of key school leadership team members. A timeline for activities and associated dates in hiring both leaders was presented and job descriptions were provided for both roles, but evaluators had concerns about the proposed school’s leadership capacity in Year 1 based on the progression of dates provided by the applicant (page 38 and Attachment 6). The applicant states they are committed to hiring certified staff,; however, some of the statements made were non-committal. The applicant stated that they would make “every effort” to hire certified teachers and an “extra effort” to hire certified special education instructors, although this certification is required in Pennsylvania, and that it would be their “goal” to directly employ professional staff (pages 41-42). The applicant identifies potential future partnerships with the Relay Graduate School of Education to recruit teachers of color and Bellwether Associates to develop a Talent Framework. Evaluators did note that the proposed recruitment pipelines would primarily provide new teachers, namely the Philadelphia Teacher Residency and Teach for America (page 41). The applicant clearly detailed employee hiring and evaluation processes. The Operations Manager (Y0-Y2) and later the Director of Operations (Y3-Y8) owns the process of ensuring all employees have completed the required clearances and background checks. The applicant provided a very detailed draft of an employee handbook for the Charter School; it clearly notes that leadership and staff are directly employed by the Charter School. Teachers would be observed informally three times per year and formally twice per year according to the plan (page 44). Evaluators did raise a concern over staff expected to give 30 days notice to resign, but the Charter School has the right to terminate employment or otherwise discipline, transfer or demote employees at any time, with or without cause. The Charter School’s professional development (PD) plan calls for a 10-day induction prior to the first day of school for students as well as daily staff development time four days per week after school (page 45). The plan provides detailed descriptions of opportunities that will be offered to staff and include the topic, objective, duration, facilitator and participants for each 11

session (Attachment 10). Evaluators noted that the PD plan could be better tailored to the specific needs of teachers as it was unclear how unsatisfactory performance would be handled. The application also includes a description of the opportunites that the Charter School would provide for the staff to grow. The application highlights career development pathways that will be available for instructional staff. For example, teachers with instructional expertise and leadership skills will have opportunities to become mentors, team leaders or data leaders (page 46). The applicant expects that the development of career pathways for teachers will support the retention of high-quality staff. Regarding proposed employee benefits, the Charter School will not participate in PSERS, but will instead provide employees with a 403(b) plan. The application indicated that the proposed retirement program would provide a dollar-for-dollar match of three percent (3%) of an employee’s salary contributed by PHPCS or as otherwise determined by the Board of Trustees from time to time. Evaluators noted that 3% is below the level necessary for PSERS approval of an alternate retirement plan which requires a minimum of a 5% employer contribution. The alternate 403(b) plan is not currently approved by PSERS. For health insurance (medical only), the applicant had budgeted $7,485 per employee; based on average costs, this is low for health benefits and likely too low to ensure that the coverage offered is comparable to that of the District as required by the Charter School Law. Further review of the health care plans proposed for PHPCS employees indicated they are comparable in deductible amounts ($0 deductible), preventative care coverage and copay amounts for in-network primary or specialist visits; however, the plans are not comparable specifically for participants who may need additional non-preventative care, where there are significantly higher out of pocket maximums (more than $2-3,000) and copays for lab work, radiology/imaging, outpatient surgery, ER and hospital services (page 48 and Attachment 12). Based on these coverage comparison gaps, the proposed budget for health insurance is likely reasonable but reflects coverage levels that are not comparable to those of the District. The Organizational Chart is detailed and thorough. It reflects initial (Year 1) as well as interim (Year 5) and at-scale (Year 8) staffing and reporting structures and clearly shows the Executive Director directly reporting to the Board of Trustees with dotted line accountability to the CMO. As the Charter School phases-in, additional leadership team positions are identified by year (page 39) and direct reports and operational responsibilities are outlined (Attachment 8). There is a detailed service agreement, organizational profile and key staff resumes provided for the contracted business manager, Charter School Business Management (CSBM). Additionally the quoted rate for business services appears lower than what is typically observed for the Philadelphia charter sector (Attachment 24). Based on information provided, it appears that CSBM has the requisite expertise and strong track record in New York State and elsewhere. The staffing plan presented in the narrative does not fully align with the proposed budget. In Year 1, the staffing table identifies 18.5 staff members whereas the budget identifies 19.5 (page 42 and Attachment 26). It appears that the budget includes an Office Support Position that is not identified in the narrative. Based on the organizational charts provided, it appears that specials teachers are removed from the elementary school in Year 8 and there will be one fewer teaching assistant in Year 8 than in Year 5 (Attachment 8).

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The applicant has proposed a CMO for the Charter School, Hebrew Public, which would receive a management fee of 5% of state and local revenue. Based on Philadelphia charter sector averages and the proposed services which include educational program design and curricular components, business operations, human resources, budgeting, financial support services, student recruitment, governance, marketing and communications, fundraising support and research and evaluation, the 5% proposed management fee is reasonable. Based on the professional experience summaries provided for key CMO staff members, the CMO team who would support PHPCS appears to have the requisite experience to open and manage a charter school (Attachment 24). Assuming that PHPCS would be the fourth school that is directly managed by Hebrew Public, the CMO staff time allocation does not consistently add up to 100%. As such, the CMO staff time allocation was unclear to evaluators, as the allocation for PHPCS does not get to 25%. Generally, evaluators found that there was an appropriate balance of independence and oversight between the Charter School and the CMO. The management agreement has a required provision for annual performance evaluation of the CMO by the Charter School with continued poor performance being a right for termination of the agreement by the Charter School. Furthermore, the management agreement does not contain directives to the Charter School for expected approval of staff or budgets and the management agreement clearly states that the Charter School’s Board is to select and retain its own legal, accounting and auditing service providers. However, evaluators did note a concern regarding the terms for “proprietary works” which include curricular and educational program materials as well as materials created by employees of the Charter School based on the propriety works. Evaluators felt these terms could negatively impact the Charter School’s continued operation should the Charter School and CMO end their contractual relationship. Evaluators also note that the management agreement submitted with the application did not appear to be for PHPCS; it contains reference to the management fee beginning September 1, 2017 and also indicates that a “provisional charter from New York State Regents” existed (Attachment 24). Infinite Campus, the District’s student information system, will be maintained concurrently with Powerschool, the Charter School’s proposed student information system, and all duplicate information will be cross-referenced at least monthly, if not more frequently, to ensure accuracy between the two systems. The Charter School’s Operations Manager/Office Manager will monitor attendance and refer to the Student Assistance Program (SAP) Team as needed based on the truancy elimination plan. The plan, which appears to be compliant with applicable truancy regulations, utilizes a three-tiered system that couples a trigger (e.g. number of unexcused absences) with an action (e.g. referral to additional services, establishment of an attendance improvement plan) (page 49). The applicant acknowledges that students in Kindergarten do not receive transportation; however, the applicant provides incorrect information about the District’s transportation policy for charter school students in certain grades. The applicant states, “Per statute, the School District of Philadelphia will provide all bus service for grades 1-8 and Transpasses as appropriate for grades 7-8” (page 50). However, the District provides SEPTA Transpasses to students in Grades 6-12, not yellow bus service, unless a student has an IEP with different transportation requirements.

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The applicant plans to participate in the National School Lunch Program and provide daily breakfast, lunch and afternoon snack to all students. Food supplies are included in the budget and the proposed Charter School obtained an estimate from Lintons Managed Services, a Philadelphia-based meal-provider, to provide breakfast and lunch prepared off-site and served at the school. The applicant further stated that during the school opening process, they would solicit bids from local vendors to provide this service (page 50). For student health services, the applicant plans to contract with the Mid-Atlantic Consortium of Charter Schools (MACCS) Health Services, Inc., which would provide a nurse who would be only part-time in Y1-Y2, and increase to full-time once the school adds additional grades. MACCS would be responsible for immunizations and mandated health screenings according to the applicant (page 50). The evaluation team did raise questions about the $14,180 contract rate identified for per pupil health services because such an amount appeared low for even a part-time on-site nurse. The applicant did not address issues about how student health services would be met when the nurse was not on-site and what training would be provided for non-medical school staff related to allergies, mandated reporting, medication administration and chronic health management, and school medical procedures for confidential and secure record keeping as the school staff would need to provide these services when the part-time nurse was off-site. Further, the required health services and screenings are stated generally, but not broken out to specify what exactly will be provided to which students by year or grade level. The applicant’s enrollment plan by grade level and year is clear, and there is an explicit intent to enroll a diverse student body while maintaining low class sizes and low (positive) teacher to student ratios (page 52). However, evaluators raised concern for whether the projected enrollment targets would be met. There is no clear evidence of the strategic outreach necessary to achieve the diversity by design levels desired and projected. Evaluators noted that the projected poverty and racial demographics of the Charter School are significantly different from citywide charter averages in Philadelphia which suggests that a unique, intentional and targeted student recruitment and engagement strategy is necessary. Further, the 2.5-mile radius identified in the application excluded adjacent sections of 19140 that are predominantly Hispanic, especially when compared to the demographics within the radius (page 73). Evaluators noted that a slight shift in targeted zip codes and area of focus for the Charter School may facilitate diversity and questioned why this was not acknowledged in the application. The Charter School proposes to adopt the Philadelphia Charter School Standard Application, which is available in seven languages, to ensure equal opportunity and limit barriers to entry for interested families. The application will be available from October 1st to March 1st and, should a lottery be required, all families who applied to the school will be informed of the details of the lottery, including the date, time and location where it will be held. It was not clear, however, whether all communications to families would be provided in their home language. PHPCS will not carry the wait list over after the conclusion of a school year and intends on backfilling seats in all grades and throughout the year (page 66). The applicant, however, did not provide any proposed enrollment materials or the enrollment packet and the Admission Policy was silent on what materials and information would be required or requested for enrollment; as such, evaluators were not able to evaluate full compliance with state requirements (Attachment 16). Regarding student discipline and the Code of Conduct, evaluators noted a few concerns. Persistent Level 1 offenses can lead to Level 2 consequences up through Level 4, so ultimately 14

Level 1 actions could lead to suspension or expulsion, which does not align with federal guidance for proportional response – minor, non-violent behaviors should have associated minimal consequences. Additionally, although the applicant claims to have a Restorative Practice approach, the Code of Conduct did not reflect a positive framing of expected behaviors, rather it was focused on a standard listing of infractions and consequences (Attachment 17). The Code of Conduct does include compliant policies regarding manifestation determination and due process provisions for students with disabilities. The applicant states that data will be tracked for student discipline actions, but no clear information was provided for tracking of subgroup information for violations and infractions to identify disproportionality in identifying, reporting or resolving student discipline incidents (page 55). Regarding school safety, the Safety Plan submitted by the applicant demonstrates knowledge of the Safe Schools and Gun Free Schools Acts. The Safety Plan includes fire drills as well as processes for both hard and soft lockdowns. The plan explicitly identities the different roles of members of the Building Response Team (BRT) and student and staff expectations during each situation. Evaluators did note however that there appear to be multiple entry points into the school building that people can enter or students can leave undetected and did not see a plan to address this concern (Attachment 18). The applicant presented a clear plan for establishment and transition of the Charter School’s entity and governance. The Articles of Incorporation were provided. The applicant indicated that upon approval of the charter, the Founding Coalition would immediately convene and move to create the PHPCS Board of Trustees, constituted from members of the Founding Coalition. The Founding Coalition members who would transition to the PHPCS Board are clearly identified and detailed resumes for each person were provided. Further, members of the Founding Coalition who do not become full Trustees would transfer to an Advisory Board (Attachments 19 and 21). According to representations in the application, the Board of Trustees would also reserve one seat for a voting parent representative of a current student. The Board of Trustees would also appoint the Executive Director and confirm the service providers, proposed as Hebrew Public as the CMO and CSBM as the business manager. Based on the application, the Charter School’s Board would delegate the performance of certain functions of the proposed charter school to Hebrew Public. Hebrew Public, as detailed in the management agreement and application, would be held accountable formally for performing the services, responsibilities and duties set forth in the Education Service Agreement (ESA) (page 59, Attachment 24). Evaluators did note a concern about the authority granted to committees in the PHPCS bylaws, as there is allowance for committees to act in place of the Board in a large majority of matters outside of four items outlined. Additionally, the frequency of scheduled board meetings is only six per year, which evaluators noted as a major concern for a proposed charter school’s opening year as a new school in a new region. Further, in out years, with a non-local CMO, this infrequency of scheduled meetings limits publicly transparent engagement between the CMO and Charter School and among the Charter School, CMO and school community, namely families and staff. According to representations in the application, PHPCS has allocated $10,000 to invest in the 2018-2019 fiscal year to support intensive board training. A detailed and comprehensive board reporting tool, a dashboard, was presented with the application to represent the level of school and student information that would be reported to the board on a regular basis (Attachment 45). Although a thorough and detailed Conflict of Interest policy was presented in

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the application, evaluators were concerned that one of the proposed Board members is employed by Relay GSE, a key partner that the applicant identifies in the application (Attachment 21). The applicant did not submit a proposed contract between the Charter School and Relay GSE, however, so the evaluation team was not able to determine whether a conflict exists. The proposed dissolution plan sufficiently includes a designation of a manager to oversee the dissolution and closure process, a detailed policy for processing and transferring student records, and provision of an escrow account as needed. Evaluators did note a concern that the plan is to keep personnel records for only two years, however (page 64).

Finance and Facilities As a general note, evaluators indicated that GASB is a more appropriate standard than the Charter School’s proposal to use FASB in terms of Internal Financial Controls (page 68). In the budget presented by the applicant under Year 1 detail in the Revenues section, Fundraising is identified as $230,000. The applicant has identified $50,000 to date from one donor, Seed the Dream Foundation. However, the commitment is preliminary and subject to terms and conditions that were not disclosed to the commitment team. In the application, the applicant team highlights their fundraising efforts for the three schools they operate in New York City, citing nearly $1.2 million raised over two years (page 67). Although this sum represents just under $200,000 per year per school, less than the amount budgeted in their application, the evaluators also noted that more than $600,000 of the funds raised were funds awarded by the City of New York government. The evaluators are unaware of any such equivalent funds available from the City of Philadelphia or any other government agency within the Commonwealth of Pennsylvania. As such, evaluators raised concerns that fundraising projections may be overly optimistic, particularly considering the operator has no current presence in Philadelphia. In the Expenditures-Personnel/Benefits section, evaluators indicated that there is no budget for extracurricular activities/overtime and that health care costs of $7485 per staff member are below national averages (Attachment 26). Evaluators also noted that the medical benefits budgeted do not appear to cover all personnel, as the difference between total salaries and salaries eligible for health insurance is $111,857.50. There is no documentation detailing who would not be eligible; whether this would be in compliance with the Affordable Care Act; and this value does not correspond to any combination of salaries listed. The evaluation of health care benefits costs was based on average health insurance costs as reported in the Kaiser Family Foundation and Health Research & Educational Trust Employer Health Benefits 2017 Annual Survey. Average employer costs in this survey for all plans is $5,477 for individual plans and $13,049 for family plans. The applicant’s stated 3% match on 403(b) is below the allowable level for approval of an alternate 403(b) plan by PSERS. To reach the 5% minimum employed contribution required, the applicant would need to add $22,371.50 to expenditures for Year 1 when the Year 1 fund balance is only $23,507.35. Under purchased Professional and Technical Services, the pupil health costs for the contracted nursing services are under Philadelphia charter sector averages at $14,180 and under Other Purchased Services, the Field Trip budget of $780 seemed low to evaluators, representing only $5 per student in Year 1.

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In the five-year budget, Personnel Services section, evaluators were unclear what expenditures were included in the other column, particularly since this category is not used in the Year 1 budget. Evaluators also raised concerns regarding the ending year Fund Balances for each of the five years submitted. Year 1 is projected to end with a Fund Balance of $23,507.35, or 0.96%. Based on concerns regarding overly optimistic revenue projections from fundraising and underbudgeted or missing expenditures, the budget as presented will likely lead to a deficit in Year 1. Years 2 through 5 continue with insufficient fund balances. Without adjustments to the current budget projections, which may require programmatic changes, it is possible that the current budget plan leads to budget deficits in each of the five years (Attachment 26). Regarding the proposed facility, the applicant submitted a draft lease and facility plan for 3300 Henry Avenue in the East Falls neighborhood of Philadelphia in the Falls Center complex. Although evaluators noted that the proposed rental cost $19 per square foot appeared high compared to Philadelphia charter sector averages, it is comparable to the rental fees per square foot for similar tenants within the proposed complex. Additionally, upon a detailed review of the lease and lease terms, the lease is inclusive of most common area maintenance and services (building operating expenses and all the shared services for the complex including sanitation, snow removal and grounds keeping) as well as being inclusive of the renovations necessary for the space to be turnkey to “building standard finishes”. These terms differentiate what is included under the lease cost for this lease and most other Philadelphia charter school leases. However, evaluators did note that the lease term proposed is for 10 years which is five years longer than the maximum permitted charter term in Pennsylvania and could create a burden for the Charter School and encumber public funds unnecessarily should the Charter School not remain in operation. The proposed lease states that, if the applicant fails to obtain a charter, the Charter School may terminate the lease. There is no clear termination option if the Charter School is not renewed or fails to retain the charter (Attachment 33). The applicant presents a clear plan for ensuring building readiness. The applicant also provided two backup options for a proposed facility if they are unable to lease the East Falls location or if it is not ready for occupancy. The two alternative locations are relatively close to the primary location proposed, one of which formerly housed the New Media Charter School on Thouron Avenue. Evaluators did raise concerns related to contingencies for any cost overruns in preparing the proposed school for Year 1 opening and what financial responsibility the Charter School might have with respect to securing a Certificate of Occupancy.

Family and Community Engagement and Support Regarding the applicant’s response to the Family and Community Engagement and Support section, evaluators found that the applicant did not demonstrate significant evidence of clear support from families of age and grade eligible students. As submitted by the applicant, evaluators noted only fifty-four (54) unique letters of intent to enroll forms for prospective students who would be grade or age eligible for the grades operated during Year 1 of the proposed school (Kindergarten and Grade 1). This represents only one-third of the Year 1 seats, raising significant concern from the evaluation team about the applicant’s ability to meet enrollment and budget projections. Furthermore, only just over half of the letters of intent to enroll forms were from zip codes identified as areas of outreach and canvassing to date, raising further concerns regarding the engagement efforts and interest to date. Evaluators also did not

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find a clear and compelling rationale for which zip codes and neighborhoods the applicant team was targeting for engagement during the application development phase especially in consideration of reaching the Charter School’s intent on ensuring diversity (page 76 and Attachment 35). In addition to the intent to enroll forms, the applicant provided four (4) letters of support from elected officials and twenty-two (22) letters of support from churches, educational institutions, civic organizations and area businesses. The applicant also committed to engaging childcare providers and included a map of all childcare providers identified and contacted by the applicant team. The applicant claims to have reached out to childcare centers that provide seats to families who may be economically disadvantaged and includes plans to conduct outreach with materials in multiple languages; while MOUs with multiple childcare centers were not provided, two letters of support from surrounding childcare providers were included (Attachments 35 and 36). Parent engagement throughout the life of the proposed charter school is thorough and detailed (page 78). Prospective parents would sit on the Charter School’s advisory board and the school intends on facilitating the development of a Home and School Association. The applicant team expressed consideration of their families by offering flexible schedules for parents to come to school for conferences and have events planned that will engage the community. The Charter School would house the majority of student related data in PowerSpeak. Parents and students would have an account to access their respective student data and information. The Charter School will also provide access to school computers at the proposed school facility for parents to use as well as trainings on how to use the PowerSpeak portal. PHPCS would provide an annual report on the overall progress of the school, but it is not clear how the annual report would be published or distributed to families nor if it will be in multiple languages and written in a user/family friendly way to maximize understanding.

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