Testimony of Irene Holtzman — Performance Oversight Hearing: Committee on Education & Committee of the Whole

Thank you for the opportunity to testify today. My name is Irene Holtzman and I am the Executive Director of FOCUS. Since 1996, we have empowered the District’s public charter schools by advocating for and strengthening school autonomy, equity, quality and choice.

DC is nationally recognized for its work in expanding educational opportunity for those who need it the most. We have one of the oldest laws authorizing public charter schools in the country; we were one of the first districts to take a strong stance on charter school quality with the creation of the PCSB’s Performance Management Framework; we have a robust example of cross-sector collaboration in driving equity through city-wide Equity Reports; and we also were one of the first places to utilize a universal application system to further drive equity in the city.

Public charter schools that successfully serve their populations and have demand grow; those that are not serving the best interests of their students close. Yet despite these successes, we find ourselves at a crossroads — with a public narrative that has a tenuous relationship with the facts. As a city, our work is not done in closing the opportunity gap, but we are far closer to that day than we were when I began my career in DCPS nearly 20 years ago.

I’m here to address two components of this false narrative that have caught the public’s interest over the last year. One, the misconception that accountability in charters is weak, and two, that charters are not transparent.

First, the DC Public Charter School Board is a national leader in accountability practices among charter school authorizers. Most importantly, the PCSB holds schools accountable for academic outcomes. The Performance Management Framework, developed over time and refined over the years, provides a common yardstick for measuring school quality within the sector. Prior to the PMF, there were several cumbersome ways for a community stakeholder to assess school performance. One, look at individual school goal attainment in a school’s annual report. Two, track down state assessment performance. Three, visit the school and ask questions about performance. While not perfect, the PMF is a very strong tool. Families, policymakers, legislators, and public stakeholders have access to clear, transparent information about key performance indicators. But beyond this, they also have an added layer of assurance that the data is valid — that is, the PCSB’s oversight function.

What many don’t realize is that the PCSB does not just take the word of the school that the data they produce is accurate. On both equity reports and the PMF the data is collected periodically, compared to other existing data sets, and often validated against source documents by PCSB staff. For example, PCSB compares discipline data to attendance data to ensure that both are being correctly submitted. If you have suspended a student and they are marked present, or you have marked a student’s attendance as suspended but there is no accompanying record on the discipline report, those items are flagged and reconciled. Other data, such as PSAT and SAT data from the College Board, are verified against official reports. PCSB’s transcript monitoring process digs into the congruence of report cards, transcripts, and graduation plans to ensure that schools are engaged in accurate record-keeping and adherence to their policies.

In addition to academic and program data, PCSB also uses a common metric for analyzing and reporting financial data, called the Financial Analysis Review, or FAR report. Each LEA has an individual report, covering 9 individual metrics, as well as key indicators from school financial audits and activities. To give additional insight into sector performance, PCSB also compiles metrics into aggregate tables that compare LEAs for easy reference. There are consequences for underperformance on financial metrics — notices of concern, charter warnings, up to charter revocation. Financial accountability is built in to PCSB’s authorizing practices.

PCSB’s work on the accountability front has been highlighted by the National Association of Charter School Authorizers, The National Charter School Resource Center, and others. More importantly, the share of students in Tier I seats across the city has been increasing over time. While other states may have variable authorizer quality, DC has been and remains a city with strong authorizing and accountability practices that centers the needs of students.

The second misconception that I would like to address is the idea that charters are not transparent. DC’s public charter schools have more data available about their performance and finances than traditional public or private schools. Here is just a sample of what one can find on the PCSB website — now easily organized for the public in their Transparency Hub:


  • Budgets
  • Audited financial statements
  • 990s
  • Breakdown of how schools spend their money
  • At-risk funding plans
  • FAR report cards

Programmatic Information

  • Charter applications
  • Charter agreements — which include mission, ages and grades, goals and achievement expectations, graduation requirements, bylaws, enrolling ceiling, and agreements with management organizations
  • Annual reports
  • Calendars
  • Student Handbook
  • Healthy School Profiles

Performance Information

  • PMF Reports
  • PCSB school quality reviews (observational data)
  • DC School Report Card
  • Equity Reports

PCSB is also, with feedback from schools, teachers, parents, and the community, revising its transparency policy to meet the needs of educational stakeholders. Additional items being discussed are Board calendars and minutes, employee handbooks, current salaries of the five most highly-compensated individuals in the organization, and other items.

There are some who claim that public charter schools aren’t public until they are subject to laws that only pertain to the government, like open meetings and the Freedom of Information Act. They point to other states, with vastly different landscapes, as evidence that this is justified. However, in other states, schools are authorized by traditional school districts that are, by design, part of the government. In some other states, all nonprofits that receive any government funding are subject to these laws. Carving out a special circumstance for some nonprofits in the District but not others is not legally defensible or practical.

The fact of the matter is that public charter schools are public but also intentionally free from government bureaucracy. In exchange for that freedom and flexibility, we are held to a higher standard. The consequences for academic underperformance, not meeting financial expectations, or breaking the law are severe. Those who claim that FOIA is neither burdensome nor expensive are not familiar with the law. Most public charter schools do not have in-house counsel. The cost of review alone can run to $350 an hour — not to mention upgrading all document retention and technology assets to facilitate complying with the production of books, records, and documents.

Does that mean no transparency? Absolutely not. It means that we shouldn’t treat independent nonprofits like they have the same resources as the DC government. DCPS benefits from the services of city legal counsel, OCTO, and others that support them in retrieving, reviewing, redacting, and producing FOIA requests. Charters are already underfunded as compared to DCPS — missing out on extra formulary funds that support building maintenance through DGS, and teacher retirement. FOCUS supports continuing to make essential information available through PCSB’s FOIA compliance and ensuring that charter schools’ limited dollars are spent where they are needed most, on their student bodies.