The Massachusetts Board of Elementary and Secondary Education

Charter Schools - Amendment Request of Pioneer Valley Chinese Immersion Charter School (Enrollment)

Pursuant to the Charter School Regulations, 603 CMR 1.10(1), the Board of Elementary and Secondary Education (Board) must approve changes to the maximum enrollment of Commonwealth and Horace Mann charter schools. This year, the Department of Elementary and Secondary Education (Department) received requests from fifteen charter schools to increase enrollment. This month, I recommend that the Board approve amendment requests from three Commonwealth charter schools and one Horace Mann charter school. Each recommendation is outlined in a separate memorandum for your review. This memorandum details the request from the board of trustees of Pioneer Valley Chinese Immersion Charter School (PVCICS), a K-12 school serving students in 39 communities in western Massachusetts, and my recommendation.

The Department's assessment of PVCICS's request is described below, in preparation for a discussion and vote at the Board's meeting in February. The memorandum is organized into the following sections: (1) the school's request and plan for implementation; (2) the Department's review; (3) proven provider consideration; (4) public comment; and (5) a recommendation for growth. The following information is attached to this memorandum for your review:

• the original amendment request and additional materials subsequently submitted by the school, as applicable;
• a summary of the school's credentials as a proven provider, including a summary of the school's academic performance, student demographics, attrition rates, and five-year financial summary; and
• public comment.

An overview of the terms of the school's charter follows.

School's Request and Plan for Implementation

The board of trustees of PVCICS requests approval of an amendment to increase its maximum enrollment by 452 students to reach a maximum enrollment of 1,036 students in grades K-12. The school reports that the request for an increase in student enrollment will increase access to the school's Chinese language immersion and International Baccalaureate programming, increase the diversity of curricular and extra-curricular options for older students, and address the facility needs of the school community. I recommend approval of this request.

PVCICS seeks to grow to 1,036 students over approximately thirteen years and reach full enrollment no later than 2029-2030. The growth plan follows a slow and gradual increase to enrollment by increasing enrollment in kindergarten and by increasing enrollment for new students in grades 6 and 9. Additional growth will occur in subsequent years as the cohorts from increased admissions in kindergarten advance into other grades. The school intends to increase the number of students per grade to 88 students in grades K-6. PVCICS has also committed to accepting new students in grades K-6 and to expand enrollment of new students to fill vacancies in grades 6-9, which exceeds the statutory requirement to fill vacant seats. The school anticipates the cohort size in grades 6-9 to decline gradually due to attrition and estimates approximately 65 students per grade in high school.

The school's request includes updated financial statements and staffing projections for the proposed enrollment increase. The primary increases in revenue will support increased staffing and improvements to employee benefits, including annual salary increases of 4 percent; the purchase of a second facility, including renovations and improvements; and increased student extracurricular opportunities and the elimination of student fees associated with International Baccalaureate testing.

The school leases its current facility from its associated foundation, the PVCICS Educational Foundation. In 2015, a four-story addition to the existing facility was completed, creating additional space to accommodate increasing enrollment at the school. The school reports that expanding beyond its current maximum enrollment of 584 requires additional facilities. The school has identified real estate close to the current facility that would create multiple campuses for the K-12 school.

Department Review

Section 1.10 of the Charter School Regulations contains several criteria to consider in determining whether to grant a school's request to amend its charter. The Department's comprehensive review was based upon these criteria.

The Department's review included the following considerations:

• the charter school's compliance with applicable state, federal, and local law;
• affirmative, credible evidence regarding the faithfulness of the school to the terms of its charter, including the extent to which the school has followed its recruitment and retention plan and has disseminated best practices;
• affirmative, credible evidence regarding the success of the school's academic program;
• affirmative, credible evidence regarding the viability of the school as an organization;
• the merits of the school's amendment request when judged against the criteria outlined in the Department's Charter Amendment and Notification Guidelines and the Charter School Performance Criteria;
• the eligibility of the board of trustees for proven provider status based upon the criteria described in 603 CMR 1.04(4); and
• the public comment received regarding the request.

Overall, the Department's records indicate that PVCICS's academic program is a success, that the school is a viable organization, and that it is faithful to the terms of its charter.

• PVCICS provides a unique educational option for families in western Massachusetts, aligned with its mission. China's Vice Premier Liu Yandong recently recognized PVCICS at the Confucius Institute World Conference in Shanghai, China, as one of three schools in the United States and ten schools globally to be awarded the 2015 Confucius Classrooms of the Year award.

  • The school offers an immersion program in Mandarin Chinese language and culture; students will be highly proficient in two languages, English and Mandarin Chinese. Students in grades K-1 spend 75 percent of the school day in Chinese immersion classes where they learn mathematics and science as well as Chinese language. Students in grades 2-5 are instructed in Chinese for 50 percent of their day, and students in grades 6 through 12 spend two hours daily in Chinese language classes.

  • In grades K-5, no English is used by the teacher during the Chinese portion of the day when core subjects, such as mathematics, Chinese language arts, and science are taught. During the English portion of the day, English language arts and social studies are taught. In grades 6 and higher, English is used as the language of instruction for core subjects; all students, however, continue to take Chinese language arts for two hours daily.

  • In high school, all PVCICS students prepare to take rigorous International Baccalaureate (IB) Diploma Programme (DP) courses in 11th and 12th grades. In the 2015-2016 school year, the first cohort of 11th grade students were taught using "IB for All" DP curriculum, and this cohort will graduate from the IB DP program in 2016-2017.

• PVCICS achieved Level 1 accountability status beginning in 2013. PVCICS was not assigned a level prior to 2013 due to insufficient data. For the past four years, the school has exceeded the Progress and Performance Index (PPI) target for all students, including PPIs of 100 in 2014 and 2015. The school achieved a PPI of 81 for the high needs subgroup in 2016. PVCICS did not have a PPI for the high needs subgroup in previous years.

• PVCICS has administered MCAS during its second charter term. MCAS scores are designated by levels of proficiency, with proficient and advanced levels meeting or exceeding performance standards, respectively. The percent of PVCICS students identified as proficient or advanced in English language arts (ELA) has annually exceeded the statewide average in comparable grades from 2012-2016. The percent of PVCICS students identified as proficient or advanced in mathematics has annually exceeded the statewide average in comparable grades from 2012-2016. The same pattern of high performance is demonstrated by students identified as economically disadvantaged from 2012-2016. The school has also exceeded the average performance of the two lowest 10 percent districts within its charter region, Holyoke and Springfield, during the same time period.

• The school's enrollment of students identified as economically disadvantaged, students with disabilities, and English learners has been consistently below the rate of comparison schools through the most current charter term. Over the school's two charter terms, PVCICS has enrolled an increasing percentage of students from Holyoke and Springfield. PVCICS has exceeded the comparison index4 as it relates to students whose first language is not English and enrolls such students at rates consistent with comparison schools. See attachments for proven provider credentials.

• The school has generally demonstrated low rates of attrition and discipline over its second charter term. The school's overall rate of attrition increased from approximately 5.0 percent in 2015 to approximately 8.5 percent in 2016 as the school increased enrollment in the middle and high school grades. In 2014 and 2015, attrition rates were below 6 percent. The school's rate of attrition for the high needs subgroup is lower than the overall attrition rate but demonstrated a similar increase from 3.8 percent in 2015 to 6.4 percent in 2016. During its second charter term, the school had no suspensions in 2012, 2013, and 2014. In 2015 and 2016, in-school and out-of-school suspension rates were approximately 2 percent and less than 1 percent respectively.

• PVCICS was successfully renewed in 2012 and 2017. In the school's most recent renewal, the school received a rating of meets in all areas of performance of the Charter School Performance Criteria rated during the renewal process with two exceptions, in Access and Equity and in Governance. The school has not enrolled comparable populations of students in various subgroups and the school's rate of attrition for students with disabilities has been variable. The composition of the board of trustees of PVCICS has changed substantially during the second charter term with only one of the current 11 trustees an active member in 2014-2015. With the changes in board composition, the school has made strides to strengthen oversight systems and structures, as noted in the school's 2017 summary of review.

• As noted in its previous renewals and evidenced by the current fiscal dashboard, PVCICS has a consistent history of strong performance on key financial metrics and is financially sound and stable. The school received unqualified audit opinions for all years of its first and second charter term. The school's audits have no findings or instances of noncompliance throughout the current charter term.

Prior and Current Requests for Growth

In 2012, PVCICS submitted an expansion request to change the grades served from K-8 to K-12 and to increase its maximum enrollment by 384, from 300 to 684 students. In February 2013, the Board granted the school's change in grade span to become a K-12 and granted a modified version of the proposed increase in maximum enrollment.5 The Board granted an increase of 284 seats rather than the 384 seats requested by the school. The modified award by the Board allowed the school to implement its growth plan until the school's renewal in 2017. My recommendation to modify the school's request for seats highlighted the Department's concern that the school had not yet established evidence of demand for the projected enrollment proposed by the school at that time. I also stated that I would consider any future requests to increase maximum enrollment at the school's next renewal.

In 2014, the school submitted a request to increase enrollment by 384 students. Because the school had not fully implemented its earlier expansion and had only limited evidence of demand, I did not bring the school's amendment request to the Board for consideration and again encouraged the school to submit a request with its renewal application in 2016. In 2016, the school submitted a modified version of its request to increase enrollment based upon discussions with the Department regarding demand and its educational model. The request included a proposed enrollment increase to 1,144 with higher cohort sizes in the elementary school grades, where the school has experienced consistent demand in recent years, and lower cohort sizes in the middle and high school grades, where the school has not yet established the same evidence of demand.

The executive director, principal, chair of the board of trustees, and my staff members have discussed specific concerns that arose during the review of the amendment request in 2016 to grow from 584 to 1,144 students. During the discussions, school leadership explained the reasons for the request and the rationale for the cohort size at the elementary school grades. The Department asked the PVCICS board of trustees to consider a smaller expansion to address concerns regarding the size and pace of the expansion. The Department also requested additional information regarding the planning for staffing and school finances under a revised growth plan.

The school submitted additional materials in response to the Department's requests. The additional materials included a revised growth plan, staffing plan, and budget for an enrollment increase from 584 to 1,036 students. These materials are attached for your review.

Proven Provider Consideration

Proven provider status6 is required to award additional seats to PVCICS. The school's charter region includes Holyoke7 and Springfield8, school districts that perform in the lowest 10 percent of all districts based on state assessment test scores in 2013-2014 and 2014-2015. As a result, 18 percent of each of these districts' net school spending (NSS) may be allocated to charter school tuition.9 The Department has determined that there are approximately 540 seats available in Springfield and 158 seats available in Holyoke for charter award under the 18 percent NSS cap.

After evaluating the performance of PVCICS against the criteria for proven provider status, I identified the board of trustees of PVCICS as a proven provider for the purposes of the current amendment request. Included in your materials are the relevant student achievement and indicator data used to determine that the board of trustees of PVCICS is eligible for proven provider status. Pursuant to 603 CMR 1.04(4)(b), the award of proven provider status to an existing board of trustees must include successful student academic performance over a three-year period. This is measured by using proficiency/achievement levels and growth measures on the state assessment test or equivalent assessments for English language arts and mathematics in comparable grades for all students and for one or more targeted subgroups. The Department compares the school's student performance data to statewide averages and to relevant district averages for the grades served by the charter school.

Public Comment

At the time of the school's submission to the Department, PVCICS also submitted copies of its request to the superintendents of its charter region, pursuant to 603 CMR 1.10(5). The Department subsequently solicited written comments from superintendents. Superintendent John Robert of Hatfield Public Schools submitted comment in opposition to the request. His comment is attached. The Department received public comment in support of the school's request from community stakeholders. Comments are attached. The school also submitted various letters from community stakeholders within the school's request. These letters can be found at pages 93-103 of the school's request.

Recommendation for Moderate Growth

As noted in the request submitted in August 2016, the board of trustees of PVCICS requested an expansion from 584 to 1,144 students. During the Department's review, concerns were identified regarding the evidence of sufficient demand to support the additional 560 students, particularly in middle and high school grades. In response to the Department's concerns, the school identified the addition of 452 students as a possible modification that would permit the school to grow at a reasonable pace and support successful implementation of the school's educational model.

I have reviewed the school's modified request, and it appears reasonable and consistent with the charter school statute and regulations. Overall, the amendment request, renewal of the school's charter in 2017, and the Department's accountability records indicate that the school's academic program is a success, that the school is a viable organization, and that it has been faithful to the terms of its charter.

While waitlist trends indicate the school can enroll 90 students at the kindergarten entry point, it remains unclear whether the school can maintain 88 students in grades 6-12, as proposed in the original request to increase enrollment to 1,144 students. In light of limited evidence of demand in the upper grades and my interest in ensuring the school does not overextend its financial resources if it does not reach its projected enrollment, I recommend that the Board approve the modified request for a maximum enrollment of 1,036 with a condition. If the school should fail to increase student enrollment in accordance with the growth plan contained within the school's revised enrollment policy10, and reports fewer than 800 students enrolled at the school on October 1, 2021, the Board of Elementary and Secondary Education may reduce the school's maximum enrollment accordingly. A motion for approval is attached for your consideration.

If you have any questions regarding this amendment or require additional information, please contact Alison Bagg, Director of the Office of Charter Schools and School Redesign (781-338-3218); Cliff Chuang, Senior Associate Commissioner (781-338-3222); or me.

Attachments:

 

Correspondence from Pioneer Valley Chinese Immersion Charter School, including comment submitted by the school

 

Comment from Superintendent of Hatfield Public Schools

Pioneer Valley Chinese Immersion Charter School's Academic Performance Data, Student Enrollment Demographics, Student Attrition Rates, and Five Year Financial Summary

 

Public Comment

 

Motion for Board Action on Pioneer Valley Chinese Immersion Charter School

1 The 39 districts are: Agawam, Amherst, Amherst-Pelham, Belchertown, Chesterfield-Goshen, Chicopee, Conway, Deerfield, East Longmeadow, Easthampton, Frontier, Gill-Montague, Granby, Granville, Greenfield, Hadley, Hampden-Wilbraham, Hampshire, Hatfield, Hawlemont, Holyoke, Leverett, Longmeadow, Ludlow, Mohawk Trail, Northampton, Pelham, Pioneer Valley, Shutesbury, South Hadley, Southampton, Springfield, Sunderland, West Springfield, Westfield, Westhampton, Whately, Williamsburg, and Southwick-Tolland.

2 The current school year is the school's first year of operations as a K-12 school.

3 As reported in the Massachusetts Charter School Waitlist Updated Report for 2016-2017 from October 1, 2016.

4 The comparison index is derived from data of students who reside within the charter school's sending district. The comparison index is a statistically calculated value designed to provide a fairer and more realistic comparison measure that takes into account the charter school's size and the actual prevalence of selected populations within those grade levels served by the charter school.

5 At the same meeting, the Board removed conditions related to governance that had been imposed at the school's renewal in February 2012.

6 Proven providers must meet the performance criteria described in 603 CMR 1.04(4) ("evidence, satisfactory to the Commissioner, to demonstrate a significant management or leadership role at a school or similar program that is an academic success, a viable organization, and relevant to the proposed charter school").

7 In the 2016-2017 school year, 5.1 percent of the student population at PVCICS were residents of Holyoke.

8 In the 2016-2017 school year, 10.6 percent of the student population at PVCICS were residents of Springfield.

9 Under charter school law, no more than 9 percent of a district's net school spending may be allocated to charter school tuition, except for the state's lowest performing districts in which the cap on charter tuitions is up to 18 percent.

10 PVCICS will be required to amend its enrollment policy to include a growth plan that describes how the school will increase its maximum enrollment every year until it reaches the proposed enrollment of 1,036 students. Amendments made to the school's enrollment policy, including the proposed growth plan, are subject to approval by the Commissioner and must be approved by the Commissioner prior to implementation.