Anonymous wrote:

Anonymous wrote:My School DC is part of OSSE. So one part of OSSE is saying that these kids can enroll in charters but another part of OSSE is saying they can’t. Seems like a mistake right? Which one gets precedence over the other?

I agree that My School DC/OSSE is the only entity that can decide which guidance the school is supposed to follow. I feel bad for the mom, Early Stages, and the charter school. Seems like they’re all trying to follow policy but the policies are conflicting.

It's even weirder than that: OSSE itself is specifically saying - in its only formal, vetted, written, and publicly available guidance - that they can enroll, because their official policy in full compliance with DC law which gives charters the same obligations as public schools. And another part of OSSE is saying they can't enroll based on...vibes, apparently? They have given absolutely no official basis for their objections, presumably because none exists. The officials here were also completely unaware of the formal OSSE policy contained in the only written regulations and public guidance on this issue, which...isn't great.

Call me crazy, but my assumption would be that the only policy that was formally codified in writing, is actually in compliance with legal guidelines and has been publicly available for years "would get precedence" over one that has never been written down anywhere, is at odds with DC law and apparently exists only in the minds of MySchool officials who never bothered to check the published OSSE regulations that govern their departments.

I get that quite a few posters here seem to find this situation complicated....what I don't get is why.

Anonymous wrote:Please work with the team at early stages. Once the IEP is completed, your case manager will discuss which LEA you want to consider for your child' DCPS or Charter. If you choose charter, they will contact the school to see if they have space for your child in their program. This process is completely outside of MySchoolDC

Anonymous wrote:My School DC is part of OSSE. So one part of OSSE is saying that these kids can enroll in charters but another part of OSSE is saying they can’t. Seems like a mistake right? Which one gets precedence over the other?

I agree that My School DC/OSSE is the only entity that can decide which guidance the school is supposed to follow. I feel bad for the mom, Early Stages, and the charter school. Seems like they’re all trying to follow policy but the policies are conflicting.

Anonymous wrote:"Given the fact that Early Stages and My School DC quote the same thing about this only being for DCPS schools, and given that the OSSE guidance goes into excruciating detail about what happens to students that are level 4 enrolled at charters after the April 1 lottery, I almost think that line about students being able to enter any LEA at age three is a mistake. Either that or they meant it, but then literally no one at OSSE or My School DC considered what that meant for children with birthdays between October 1-April 1."

What on earth does this mean? You can forget to include something by "mistake." You can issue conflicting written guidance by "mistake." Issuing the correct guidance as your sole policy: there is no universe under which this can be hand-waved away as a "mistake." It was both deliberate and accurate. The only existing published guidance correctly acknowledges the legal reality: that there is no distinction between public and charter schools in terms of the universe of students they serve or admissions policies. It's correct! How on earth is that a "mistake"?

And re: "Either that or they meant it, but then literally no one at OSSE or My School DC considered what that meant for children with birthdays between October 1-April 1." Well, it means the same exact thing for those children as it says on the page, and as it does in practice for the hundreds of them that attend DCPS under this policy. Why would they need to "consider" it? They wrote a policy that is in compliance with current law. It was vetted and published. Now, all they need to do is follow it. That, or they can unilaterally decide that charter schools, which take public money, should be required to reject a group of special needs students DCPS is required to accept - even if those charter schools WANT to follow the same inclusive policy as DCPS, and even if such a bifurcated policy violates existing city regulations.

Anonymous wrote:

Anonymous wrote:Also this — charter schools hate enrolling new students after count day. They get no additional funding for them. So the charter school is potentially being nice to you because you are a current family while telling ES they are not setup to support your daughter.

This is what I came to say. You are asking them to take a very young student (will be youngest in the class) with special needs that cost them $, but they will not get credit for it. Not going to happen. Enroll in your local DCPS for this year, OP.

Anonymous wrote:Also this — charter schools hate enrolling new students after count day. They get no additional funding for them. So the charter school is potentially being nice to you because you are a current family while telling ES they are not setup to support your daughter.

Anonymous wrote:This is a very smart strategy. And yet I must ask: if MySchool has arbitrarily decided charters can’t do a thing the OSSE regulations clearly say charters can absolutely do - why would this workaround protect the charter accepting the transfer from their misplaced wrath? That student would still eventually be enrolled at the charter “in violation” (eyeroll) of the birthday cutoff. It still feels necessary for MySchool to finally read the OSSE regulations that make an exception for IEP students - and no distinction between DCPS and charter when it comes to said exception - and start abiding by them. Just my two cents.

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:I think the differences are:

Early Stages is the Part B coordinator for the transfer from IDEA Part C FOR DCPS. Early Stages would not know anything about enrollment in charters, they are a DCPS entity that is responsible for part C to B transfer. Early Stages C to B transfer process will either develop an IEP and place you at DCPS, agree to extend your IFSP, or drop you once you show proof of enrollment at a charter.

Part C is run by Strong Start.

For Strong Start Part C to charter Part B transfer, the student would already have to be enrolled in the charter. In this case, Early Stages would not be invoked at all. The only way to be enrolled in a Charter is via My School DC lottery between April 1-October 5 for the following school year, for a child turning 3 before Sept 30. There is no way for a charter to enroll a child who didn’t make the cutoff and isn’t in My School DC.

So put together that means that only kids who are on an IFSP, have been accepted into a charter and have enrolled via the regular lottery, and are still 2 at that time, could engage in a C to B transfer with a charter. So we are talking about kids with summer birthdays. They wouldn’t be placed into a charter “early” because school isn’t in session. They could attend ESY though.

This is the kind of knowledge base that made this board so great.

Except that they’re wrong. The OSSE regulations specifically state that a child who receives an IEP on their third birthday but misses the birthday cutoff can still enroll in PK3 any LEA that accepts midyear transfers - and they explicitly state that this applies to both DCPS and charter schools. Using those exact words.

The wrinkle is that Early Stages was created to serve the (giant) DCPS LEA before charter schools even existed, and no individual charter school LEA can functionally replicate it. So the retcon is that Early Stages performs the assessments and issues the IEP … and while they can’t list any specific school on the document except a DCPS school, OSSE is quite clear in their only public guidance that the same document could also be used to enroll at any charter that is willing to accept that student.

Is it a perfect workaround? No. But it’s a way of making reality match the policy, even in the absence of funding and personnel.

Are they wrong? OSSE's policy does not match My School DC requirements nor does it match Early Stages policies.

From Early Stages -- "The Early Stages process ends with an offer to enroll at a DCPS school... Early Stages can only
offer enrollment with DCPS. If you enroll your child in a public charter school, you can transfer the IEP. If you enroll your child in a private or religious school, you can request a services plan instead."

My School DC legal agreements with charter schools state that "schools participating in My School DC are required to use a September 30th age cutoff for PK3, PK4 and Kindergarten. In other words, schools may not accept applicants younger than these cutoffs in those grades." There is no exception listed for students with IEPs or for students referred from Early Stages.

My School DC also prohibits enrollment outside of their process. "All participating schools opt-in to use the MSDC application and common lottery, and MSDC collects applications from new students on behalf of participating schools. Participating schools may not collect
applications from new students outside of the MSDC process."

My School DC also says that schools that they will "take appropriate next steps" for schools that break their rules including "referral to the Office of the Inspector General or other governmental authority, limiting future participation, censure, report to chartering authority or other oversight body."

OSSE, My School DC and Early Stages need to get together and align their policies and rules.

Yes. They are wrong. For the reasons outlined above.
The OSSE guidance, which you can read here for yourself https://osse.dc.gov/sites/default/files/dc/sites/osse/publication/attachments/Early%20Childhood%20Transition%20FAQ%20July%202020.pdf - is that "To be eligible for Pre-Kindergarten 3 (PK3), a child must turn age three by September 30. However, three-year-old children with active IEPs are entitled to enroll in DCPS or public charter LEAs with available seats that accept midyear transfer students at any time once the child is three years old, regardless of when in the year they turn three."

An IEP without any placement option whatsoever, even a non-binding one based on a pool of only some of the available options, would be pretty useless in this city. And Early Stages - the only official assessment process and personnel funded by the city - is an arm of the DCPS LEA, so they can only direct a DCPS placement for a child, even if that recommendation does not represent the full range of available options. Of course it is unlikely that a charter would accept a midyear special ed PK3 placement - but it is by no means impossible...most PK3s in the city are fairly good, most charters have PK3s, and there are more than a few charters who are otherwise struggling for enrollment and would like to be able to get a new kid in the system anytime, looking ahead to the following year when the kid would be fully funded.

I agree that OSSE, Early Stages and MySchoolDC should get on the same page. For many reasons, there can't be a separate charter version of Early Stages. Nor can Early Stages dictate any actions (such as individual enrollment decisions) to charter schools. That said, it's also not possible for charter schools to just not be in the business of serving an entire group of special ed students for whom they already have the personnel and city mandate to do so. So the best workaround is actually the current imperfect policy. All that's necessary is for everyone who deals with OSSE enrollment policies at MySchool to, you know...be aware of the actual OSSE enrollment policies. Maybe read OSSE's posted guidance on existing policy once in a while, just for kicks. The end.