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AQE Letter On Receivership
AQE Letter On Receivership
Billy Easton
Executive Director
cc: Members of the Board of Regents, Commissioner Berlin, Charles Szuberla, Ira Schwartz, Renee Rider
PROPOSED AMENDMENTS
Section 100.19 of the Regulations of the Commissioner Relating to School Receivership
These proposed amendments are designed to be considered individually or as a package.
Amendment Language #2
On page 24, in paragraph (2) of subdivision (d) the new language would be as follows:
. . .the commissioner shall consider in addition to the metrics specified in paragraphs (6) and (7)
of subdivision (f) of this section . . .
Amendment #3: Conducting a Comprehensive Needs Assessment is Essential to Developing a
Successful Plan
Under the proposed regulations independent receivers are required to conduct a comprehensive needs
assessment and analyze this needs assessment prior to developing a plan. Conducting a high quality
needs assessment seems like a necessary precursor to developing a high quality plan, yet there is no
comparable requirement for superintendent receivers. This amendment would apply the same
requirement on superintendent receivers and the language is taken from subparagraphs (8)(iii) and
(8)(iv) of subdivision (f) of the proposed regulations.
Amendment Language #3
The following amendment would be inserted on page 24 as a new paragraph (2) in subdivision (d) of the
regulations. The numeration of subsequent paragraphs would need to be adjusted accordingly.
(2) Superintendent receivers shall be required to conduct a comprehensive school and community
needs assessment in such form and format and according to such timeline as may be prescribed by
the commissioner and complete a thorough analysis of the needs assessment results unless they
can demonstrate to the satisfaction of the commissioner that no such needs assessment is needed.
This needs assessment shall be the basis for the development or modification of the
comprehensive education plan or department approved intervention and the plan must be
designed to meet the academic and other needs of students.
Amendment #4: Planning Process for Superintendent to Convert School into Community School
The proposed regulations state that although there is a requirement in law that independent receivers
convert schools into a community schools, these regulations state that there is no such requirement of
superintendent receivers. However, the regulations should specify the process to be followed if the
superintendent receiver opts to do so.
Amendment Language #4
The following amendment would be inserted on page 25 as a new paragraph prior to current paragraph
(4) in subdivision (d) of the regulations. The numeration of subsequent paragraphs would be adjusted
accordingly. It provides that they have the same timeframe as an independent receiver to develop such
a plan should they choose to convert the school to a community school and would fulfill the same
process and requirements.
(4) If a superintendent receiver opts to convert the school into a community school then they shall
be granted the same six month timeframe to develop and issue a plan that is allotted to the
independent receiver under subdivision (f) of this section and they shall follow the same process
and meet the same requirements pursuant to paragraph (8) of subdivision (f) of this section.
(ii)
(iii)
(iv)
For schools receiving state funds for the department approved plan or intervention,
whether under superintendent receiver or independent receiver, these funds shall be
used to supplement and not supplant existing funds;
If the school district makes no across the board budget cuts, there may be no cut in
existing resources for these schools.
If the school district makes across the board budget cuts, then cuts to these schools
may not exceed on a per pupil basis the cuts to any other school in the school district.
If the school district makes funding increases in their district budget then the increases
to these schools must be no smaller on a per pupil basis than those at any other school
in the district.