Memorandum

As each of you may know, the Florida Catholic Conference and Catholic school community recommend that all scholarship schools be accredited and for the schools’ accreditation to be recognized by the Florida Association of Academic Nonpublic Schools or another legitimate entity that could serve as a gatekeeper to ensure that the accreditation is reputable.

It is our position that the accreditation provision is essential to provide a much needed credibility boost to the scholarship programs and serve as a standardization of quality to ensure that students are receiving a quality education when they utilize a scholarship to transfer from a public school to a private school.

The accreditation provision, if adopted, would:

·        Provide a baseline of standardization/quality for all participating private schools that would benefit children on scholarships;

·        Force non-accredited scholarship schools to become accredited within an acceptable timeline or exit from the programs;

·        Serve as a deterrent effect for those who are motivated to establish schools in order to receive scholarship dollars;

·        Delay the establishment of a private-school formation, financed primarily by scholarship dollars;

·        Provide legitimate accountability in the scholarship programs that satisfies “moderates,” who represent the overwhelming majority of legislators in the state House and Senate;

·        Once moderates are satisfied with accountability, the Legislature will move past this issue.

Following is elaboration on the above – stated rationale for the accreditation provision:

1. -- In Florida, school choice was enacted on the premise that when the state has failed in its constitutional obligation to provide a safe, secure and quality education for children, the state has a responsibility to provide a viable option that serves parents and children well.  The First District Court of Appeal ruled that the Legislature is well within its authority to legislate programs that will provide a better opportunity for children who have been failed by the public-school system.

It follows that the state, by legislating the Opportunity Scholarship Program, McKay Scholarship Program for Students with Disabilities and the Corporate Tax Scholarship Program, has a responsibility to ensure that scholarship programs are utilizing public funds, directly or indirectly, for children to achieve academically.

Note – We are not proposing that accreditation or any other provision be inserted in the Opportunity Scholarship Program while it is under legal review.  In addition, program participation in the OSP is approximately 800 students and the OSP has not been a target for negative news stories.

But the Corporate Tax Scholarship Program and to some extent, the McKay Program, have come under scrutiny.  A disproportionate number of private schools (more than 50%) participating in the CTSP and McKay Programs are non-accredited.  This means there is no standardization to ensure that the participating private schools require any self-imposed credentialing, professional development and/or qualifications to meet the needs of students who have not received a good start in life educationally.  Because the scholarship students have attended the lowest performing public schools, or at-risk as economically disadvantaged, from single-parent households, developmentally delayed or disabled, it is essential that the participating private schools have a baseline of quality such that the academic needs of scholarship children are met.

If all participating schools were to be accredited by a legitimate organization, then there would be assurance that the inner-city schools, which are located in close proximity to the majority of eligible scholarship students, have the wherewithal to serve these students in need.

If a non-accredited school is willing to pay for the costs to be accredited, then it follows that the motivation to participate in choice programs is to academically serve students.  On the other hand, if a non-accredited school is not desirous of accreditation, then it is reasonable to assume that the school(s) is in need of scholarship dollars in order to be solvent.

As each of us knows, scholarship dollars are to be utilized to educationally serve children, not to keep private schools solvent.

2. -- The accreditation provision, if adopted, would require all participating schools to petition to an accrediting association, recognized by FAANS or a FAANS counterpart (the McKay Coalition and the Florida Association of Choice in Education want to be separate and a part from FAANS) for affiliate or candidate status.  Another option would be for non-accredited independent schools to be accredited by the Southern Association of Colleges and Schools. SACS would like to expand the number of schools it accredits at the K-8 level.

The time line for non-accredited schools to become accredited would have to be determined.  One plausible recommendation would be an initial accreditation visit within three years from the date of obtaining affiliate candidate status.  The school would then receive a two-year grace period, if needed, following the initial accreditation visit to correct any standard violations.

Although the state would have no authority over the accrediting organizations, the accrediting association would be required to submit its standards, a copy of the initial accreditation visitation report and a follow up report, if need be, to document that deficiencies were corrected, to the Florida Department of Education’s School Choice office.

Note – Requiring accreditation organizations to forward the above-stated documentation to the FDOE would make the information a public record and as such serve as an impetus for all accrediting associations to possess strong academic standards and motivate accreditation organization’s to undertake corrective action, if necessary.

As of the 2004-2005 school year, non-accredited schools already participating in scholarship programs would have until the 2009-2010 school year (three year period to be accredited, followed by two year grace period to correct violations) to be fully accredited.  Accredited schools would be required to correct any deficiencies by the end of the school year.  Schools that did not take timely corrective action would not be permitted to enroll scholarship students during the following fall school year.  Once a school corrected violations, the school could re-register to participate in scholarship programs.

New schools or non-accredited schools not already participating in choice programs could not do so until obtaining full accreditation status.

3 & 4 -- Over the past few years, a disproportionate number of fledgling non-accredited schools have enrolled students on scholarships. There is little doubt that the opportunity to receive public dollars, indirectly, to use as discretionary costs has led to the establishment of new schools and two new nonpublic school associations.

By requiring schools to be accredited, the financial incentive to participate in choice programs is less attractive and would have a deterrent effect on schools motivated by accessing scholarship funds to participant in the programs.  As a result, children would only be placed in private schools on scholarships in which there is willingness to provide essential academic services for them.

Obviously, children benefit when school administrators are willing to pay for the fees/costs of accreditation.

Those who are motivated to provide the supply – vacancies in non-accredited private schools – based on demand, are desirous of establishing schools to enroll scholarship students. This initiative has several consequences, which include:

·                    Creating a class of lower-performing private schools;

·                    Because these schools would be dependent on public dollars and as such, any newfound state-mandated accountability measures, the schools ultimately would be forced to comply with onerous intrusive accountability.  In time, these schools would be regulated much the same as public schools.  However, because these schools would utilize scholarships as capitol outlay and be at a disadvantage in attempting to hire outstanding teachers, particularly in light of the class-sizes mandates, the schools would be perceived as a mirror image of lower performing public schools. If this occurs, many children would not be served well educationally. They would be transferring to a private school much like the public school they attended.  From a children’s perspective, consider a child from a lower-performing public school utilizing a scholarship to attend a lower-performing private school, regulated much like a public school. Not only is the child not served well.  But the opportunity for parents to choose from a plethora of different schools is greatly diminished.  Accreditation would deter the expansion of private school formation based on scholarship funding.

--If private school formation based on scholarship funding were to be implemented, the credible-accredited schools would eventually exit from the scholarship programs, leaving parents to choose from a list of fledgling or non-accredited schools.

Note –Private school formation may appeal to those who would like to dismantle the public school system through choice. That has never been our intent. We know that many families are satisfied with their children’s public-school education. Moreover, we are on record as striving to be partners with our public-school counterparts in the important work of providing a quality education to all Florida’s children.

5 & 6 – Accreditation, as framed in this overview, is a viable accountability measure. It represents a level of assurance that the private schools are equipped to meet the needs of scholarship students. The accreditation provision would:

--Head off onerous provisions that each of us fear;

--Be much more preferable, as a private-sector accountability measure, than state-mandated licensure, inspections etc;

--Provide moderate legislators (those that genuinely are attempting to solve programs, not destroy the programs) with a comfort level that the accountability issue has been adequately addressed and thus does not require further debate. This would be much like the legislative provisions in respect to home schooling. Once home schoolers were required to register through the school district and undergo an annual evaluation, the Legislature did not revisit home-school accountability.