From: Steve Brown

Several weeks ago, Bullis Charter School (BCS) submitted a 598-page document requesting a 7-year renewal of their SCCOE sponsored charter, triggering the requirement of a decision from the SCCOE Board by July 17.

As supported by the enclosed data and analyses, the BCS charter should not be renewed as submitted. BCS has not, and continues to not, enroll its share of the “academically low achieving” students, resulting in harmful unintended consequences to LASD and its larger community.

This letter and its attachments present publicly available data to show that BCS has not and continues to not comply with the California’s Charter Schools Act:

CALIFORNIA’S CHARTER SCHOOLS ACT

(enacted 1992, as amended through the 1996 legislative session)

Legislative Intent: 47601 (b)

Increase learning opportunities for all pupils, with special emphasis on expanded learning experiences for pupils who are identified as academically low achieving.

Charter Development Process: 47605 - Required Charter Elements (7)

The means by which the school will achieve a racial and ethnic balance among its pupils that is reflective of the general population residing within the territorial jurisdiction of the school district to which the charter is submitted.

For over a decade, BCS enrollment has not reflected LASD enrollment, and more specifically, BCS has consistently under enrolled academically low achieving students relative to the territorial jurisdiction of the school district (LASD+BCS); the Legislative Intent defines “pupils who are identified as academically low achieving” to include students who are identified as Hispanic, Socioeconomically Disadvantaged, English Learners, and Special Education.

As shown in the following chart, BCS’ enrollment as a share of LASD+BCS enrollment has grown from 9% to 23% over the past 13 years. BCS’ share of academically low achieving students, however, has not kept pace with their share of total enrollment. The chart illustrates BCS’ proportionate enrollment in each academically low achieving category over the last 13 years. In any given year, BCS’ share of each academically low achieving category should be at least equal to BCS’ share of total enrollment; BCS significantly under enrolls in each category. For example, in the most recent school year, BCS enrolled only 6% of the district’s Economically Disadvantaged Students (FRPM) despite enrolling 23% of the combined LASD+BCS enrollment. Other categories, such as Special Needs and English Learners may appear to have a less severe enrollment gap, but as shown in the attachments, the gap is larger than it appears (i.e., almost all BCS’ Special Needs students have mild disabilities and require much less investment, and BCS’ English Learners are concentrated in TK+K and in specific ethnicities that are not academically low achieving).

For your reference, the following chart shows BCS enrollment by ethnicity over time as compared to the original charter and current LASD benchmarks. As shown, BCS’ enrollment of Hispanic students was 3% in the most recent year as compared to 10% for LASD.

The California Department of Education (CDE) uses CASSP test scores to measure and assess academic performance of schools and to understand the performance of their students by subgroup. Individual student CASSPP test scores are primarily a function of a student’s family’s economic status, ethnicity, education, language skill, and disability status.

Attachment 1 proposes six strategic governance questions for the SCCOE Board, and includes data and analyses to assist in answering those questions, which are as follows:

What role do test scores play in the charter approval process?
Conclusion: Prima facia BCS and LASD test scores are not comparable unless adjusting for the mix of students. After adjusting for student mix, the difference in the 6th grade math test scores is insignificant (looking at 6th grade helps level out early grade enrollment selection bias).
What role does enrolling Hispanic students play in the charter approval process?
Conclusion: BCS under enrolled 40 Hispanic Students in the most recent school year, 47% of the number required to reflect the “territorial jurisdiction of the school district to which the charter is submitted.” As presented in Attachment 2, under enrolling Hispanic students provides a test score advantage to BCS.
What role does enrolling students who are “Economically” and/or “Socioeconomic Disadvantaged” play in the charter approval process?
Conclusion: BCS under enrolled 36 FRPM Students in the most recent school year, 57% of the number required to reflect the “territorial jurisdiction of the school district to which the charter is submitted.” As presented in Attachment 2, under enrolling Economically Disadvantaged students provides a test score advantage to BCS.
What role does enrolling students who are English Learners play in the approval process?
Conclusion: BCS enrolled 92 English Learner students (25 students, or 27% of the 92, were TK students) in the most recent school year, 90% of the number required to reflect the “territorial jurisdiction of the school district to which the charter is submitted.”
In the most recent school year, BCS’ English Learners as a share of total enrollment increased to 9%, from a 6% average over the prior four years. This jump was driven by English Learners in the TK+K group. To note: Statewide there have been concerns raised about the increase in identification of TK students as English Learners. The assessment tools used to identify English Learners were not developed for learners who are not yet reading or writing. Assembly Bill 2268 was signed into law in June 2024, halting the identification of English Learners in TK until more developmentally appropriate measures and tools can be developed.
The ethnic composition of BCS’ TK+K English Learners were 0% (None) Hispanic and 81% Asian. By comparison, LASD’s TK+K English Learners were 18% Hispanic and 49% Asian.
As presented in Attachment 2, under enrolling students who are English Learners provides a test score advantage to BCS.

5. What role does enrolling students with Special Needs play in the approval process?

Conclusion: BCS under enrolled 24 Special Needs students in the most recent school year, 24% of the number required to reflect the “territorial jurisdiction of the school district to which the charter is submitted.”

99% of BCS students with Special Needs have mild disabilities which have a lower cost to serve than more serve disabilities. For LASD and the surrounding districts, only 67% of the students with Special Needs have mild disabilities.

6. Where are BCS leaders in the change management process?

Conclusion: The data suggests BCS leadership has had trouble moving beyond denial and resistance, and recognizing a need for change. If a realistic plan has been developed, the implementation is unconvincing. Change can be difficult process and to make it stick, improvement will require multiple annual enrollment cycles and formal annual milestones and non-compliance consequences.

Attachment 2 is an in-depth analytical effort, using available data, focusing on 6th grade math test scores to determine if there is a difference in test scores between BCS and LASD. The conclusion: after adjusting for differences in the mix of student enrollment categories, difference in 6th grade math test scores appears insignificant.

A Bigger Issue than BCS: Significant County and State governance questions currently confront the SCCOE Board, particularly with respect to determining what are comparable test scores among schools/districts and then balancing the importance of serving academically low achieving student groups. If prima facia test scores are concluded to be the most important factor, then charter schools would have an incentive to under enroll academically low achieving student groups, and over enroll the highest scoring groups (i.e. students who are higher income, English-fluent, non-disabled, and Asian and White ethnicities). The unintended consequence of valuing prima facia test scores over service to “all pupils, with special emphasis on expanded learning experiences for pupils who are identified as academically low achieving” may become a repeatable strategy used by others to game the system, increase segregation in communities, and drain critical financial and facility resources from the public schools.

This reality has played out with BCS for over a decade and will continue to deteriorate without the SCCOE Board’s oversight. As a result of BCS carving out an enrollment pattern not reflective of the general student population, academically low achieving students are being underserved, and LASD’s limited resources are being wasted, be that in the form of leadership distraction, funding allocation, capital improvement delays, or community goodwill.

Rejecting BCS’ current charter renewal, and implementing annual accountability metrics is necessary to reduce further segregation and to begin to repair damage done.

Thank you for your service to the community and for your time in reading this letter and the attached materials.
If you have questions or comments, please let know.

Steve Brown
Stevebrown94022@gmail.com
650-996-4895

BCS Charter Should Not Be Renewed - Letter to SCCOE Board