The Massachusetts Board of Elementary and Secondary Education
Career and Vocational-Technical Education: Review of Policies Relating to Program Approval and Enrollment
Career and vocational-technical education programs at the high school level are provided in a variety of settings in Massachusetts: in regional and municipal vocational high schools; in comprehensive high schools; and in partnerships with educational collaboratives, post-secondary institutions, and other organizations. Many of these programs are designated by the Department as "Chapter 74 approved" vocational programs, indicating that they meet the high standards outlined in Chapter 74 of the General Laws and in the Board's regulations on vocational-technical education (603 CMR 4.00). Chapter 74 approval entitles districts to higher funding levels under the Chapter 70 state aid formula. Comprehensive high schools can also offer career education courses without seeking Chapter 74 approval; these courses allow students to learn about career opportunities without the need to enroll in a full-time vocational program.
There is broad agreement that career and vocational-technical education is an important part of our K-12 educational system. The growing popularity of our vocational schools demonstrates that parents and students share in this belief. At the same time, the fiscal pressures of recent years require us to be prudent in our investments. Vocational classes in general, and Chapter 74 programs in particular, tend to be considerably more expensive than academic classes. It is important that our policies strike an appropriate balance between providing students with access to educational opportunities and ensuring that all of our schools have a fair share of fiscal resources.
In response to issues and concerns raised by superintendents and others, I convened an informal working group of school district and municipal officials and Department staff last year to review our policies relating to Chapter 74 program approval and enrollment. Based on these and other discussions, I am proposing a number of policy changes, described below, to address many of these concerns. I recognize that these proposed policies will have an impact on vocational schools, sending districts, and students. Accordingly, I am proposing to implement these changes through amendments to the Board's regulations. The regulatory process will provide full opportunity for all interested parties to comment on these proposals prior to final action by the Board in the fall of 2014.
Chapter 74 program approvals
Vocational programs that meet the statutory requirements of M.G.L. c.74 and the Department's regulations and guidance are designated by the Department as approved Chapter 74 programs.
- I propose establishing a formal two-stage process for Chapter 74 program approval. The first stage will focus on establishing the need for a proposed program, and will require the submission of clear evidence of both student demand and labor market demand. In assessing need, the Department may also take into account available capacity in other nearby programs. The first stage approval will serve as support for the district's school building assistance application to the Massachusetts School Building Authority.
- Under state law, a town that belongs to a regional vocational district may not offer a Chapter 74 program in its municipal high school if that program is offered in the regional district, unless the Commissioner approves an exception. Requests for exceptions will need to undergo the same determination of need described above. As part of its review, the Department will solicit comments on the application from the regional vocational district's school committee.
- The second stage of the approval process will focus on compliance with all program requirements, many of which cannot be judged until the program is in operation. In the initial year of a program's operation, if the Department is unable to complete its review prior to October 1, it will provide provisional approval for purposes of the student data submission.
- All Chapter 74 approvals will be reviewed and signed by the Commissioner.
Chapter 74 program admissions
Many of our regional vocational schools do not have sufficient space to accommodate all of the students interested in attending. It has been suggested by some that vocational schools should be required to admit students based on a lottery, as is required for Commonwealth charter schools. Although I am not seeking such a change at this time, I am proposing several other changes related to admissions.
Vocational schools are currently permitted to establish minimum admissions requirements.1 In the case of students who are deemed ineligible for admission because they do not meet the minimum requirements, I propose to require each school to maintain documentation as to the specific requirements that were not met, and to provide such documentation to the Department or to the student's parent/guardian upon request.
I propose requiring vocational schools to admit all qualified resident students before admitting non-resident students. Schools would be prohibited from skipping over a resident student who meets the minimum requirements in order to admit a non-resident student or an out-of-state student who is deemed more qualified.
I propose to clarify and improve the use of recommendations from students' current guidance counselors in the admissions process, in an effort to better serve those students who could benefit from vocational education but who might not score as high on other criteria.
I propose to require all districts to provide directory information (e.g., student names, mailing addresses, and email addresses) for 8th grade students to a public vocational school upon the school's request, so that students can be fully informed of their options for high school.
Non-resident tuition rates
The Chapter 74 non-resident program allows students to attend a vocational school outside of their home district if they are enrolling in a Chapter 74 program that is not offered in their home district. Tuition is paid by the student's home town. The tuition rate is calculated by the Department based on the vocational school's per pupil spending.
In FY05, the Department established a cap on the non-resident tuition rates equal to 150% of the foundation budget rate for vocational students, and announced plans to reduce the cap over time to 125% of foundation. For FY14, the cap was reduced to 142% of foundation. I propose to maintain the 142% cap for FY15, and then reduce it to 134% in FY16 and 125% in FY17 and subsequent years. (It should be noted that under current statutes, county agricultural schools are not subject to this tuition process and would not be subject to the proposed cap.)
I will be proposing some adjustments to the calculation of the per pupil spending amounts used in setting the tuition rates. These adjustments would eliminate the use of current year budgeted amounts for certain spending categories, recognizing that budgeted amounts do not always reflect actual spending. We will also clarify the accounting for extraordinary special education costs.
In general, the Chapter 74 non-resident tuition rates do not reflect the capital costs of constructing school buildings, because in most instances these students occupy seats originally planned for resident students. In rare instances, the Massachusetts School Building Authority, in consultation with the Department, may determine that it is in the public interest to design and construct a vocational school to accommodate a significant number of non-resident students. In these instances, I am proposing to allow an additional increment to the tuition rate to reflect the local share of the debt service attributable to the extra space required.
I propose to clarify that the Chapter 74 non-resident tuition rates do not apply to tuition agreements entered into by two school committees under the authority of M.G.L. c.76, s.12. When school committees voluntarily enter into a tuition agreement for students in one district to attend school in another district, the tuition rates are negotiated between the two school committees.
Exploratory programs
Vocational high schools with five or more approved Chapter 74 programs are required to offer a half-year or full-year exploratory program for incoming ninth graders. In an exploratory program, students rotate through the different occupational programs offered at the school to learn about the programs and help them decide which program they want to enroll in. Currently, these exploratory programs are open to non-resident students under the Chapter 74 non-resident program described above. Under the proposed regulatory changes, students would no longer be permitted to enroll in an out of district exploratory program if their home district, or the regional vocational district to which their home town belongs, offers an approved Chapter 74 exploratory program. The Chapter 74 non-resident program is intended for students who have already decided on a particular vocational program. Students will continue to have the opportunity to apply for an out of district placement for a particular full time program area when it is not offered in the student's home district(s).
Transportation limits for non-resident students
For students attending a vocational school under the Chapter 74 non-resident program, the student's home town must also pay the full cost of transporting the student to and from the school. Although there is a state program to reimburse cities and towns for this transportation cost, it has not been fully funded in recent years. As a result, there have been some instances where the financial burden on a student's home town has been unreasonable. To address this problem, I am considering a proposal to establish a mileage limit for this transportation requirement. Under this proposal, students living beyond the mileage limit could still apply for admission under the Chapter 74 non-resident program, but if admitted they would either provide their own transportation or have it provided on a voluntary basis by the vocational school or their home community. Students admitted to a vocational school before this change in policy takes effect would continue to be entitled to transportation without mileage limits.
Expanded opportunities for career education
There is a growing recognition that we need to offer more career education to all our students, not just those enrolled in full-time vocational programs. We are seeing strong student performance at many of our vocational schools, but getting local approvals and financing for expansion is a difficult process at best. I want to encourage districts to seek out and experiment with other models for delivering career and vocational education, including expanded offerings in our academic and comprehensive high schools, programs sponsored through our educational collaboratives, and partnerships among academic high schools, vocational high schools, and community colleges.
To encourage these alternative delivery models, I am planning to propose an amendment to the Board's school finance regulations (603 CMR 10.00). This amendment would permit a district to report a student as a vocational student for purposes of the Chapter 70 foundation budget calculation if the student attends an approved part-time vocational program in another district, or in another non-traditional setting, pursuant to a tuition agreement. I invite districts to suggest other ways in which we can encourage the adoption of new models of career education.
I am planning to bring these proposed amendments to our regulations to the Board for initial review in May. If the Board concurs, we will solicit public comment on the proposed amendments. I will then bring back recommendations for final approval in October 2014. Given this timetable, the proposed changes relating to non-resident students (tuition rates, transportation limits, and eligibility for ninth grade exploratory programs) would take effect during the admissions cycle for the 2015-16 school year.
Deputy Commissioner Jeff Wulfson and Associate Commissioner Pati Gregson will be available at the March 25 Board meeting to answer any questions you may have.
1 Under the Board's regulations, 603 CMR 4.03(6)(a)(1)," Each selective vocational technical secondary school in Massachusetts shall use a combination of selection criteria to determine which applicants have an ability to benefit, and therefore be admitted to the school unless the school opts to use first come-first served or a lottery for admissions. The criteria used shall include academic grades, attendance record, discipline/conduct record, recommendations from sending-school personnel and may include student interview, provided however, that no one criterion exceeds 50% of the total. Schools shall condition admission on a student having been promoted to the grade that they have been admitted to enter. Schools may condition admission on a student having passed courses in English Language Arts or its equivalent and mathematics for the school year immediately preceding their enrollment in a selective vocational technical school or program."