2013-14 Charter

Review Report
DC Bilingual
Public Charter School

June 16, 2014

DC Public Charter School Board

3333 14th Street, NW, Suite 210
Washington, DC 20010
(202) 328-2660
www.dcpcsb.org

TABLE OF CONTENTS

FINDINGS AND RECOMMENDATION.................................................................................. 1

INTRODUCTION......................................................................................................................... 1
ANALYSIS .................................................................................................................................... 6
SECTION ONE: GOALS AND ACADEMIC ACHIEVEMENT EXPECTATIONS ............... 5
SECTION TWO: COMPLIANCE WITH APPLICABLE LAWS ........................................... 24
SECTION THREE: FISCAL MANAGEMENT AND ECONOMIC VIABILITY ................. 30

SUMMARY OF FINDINGS AND RECOMMENDATION

The District of Columbia Public Charter School Board (PCSB) has conducted a charter review of the
District of Columbia Bilingual Public Charter School (DC Bilingual PCS), as required by the School
Reform Act (SRA), and recommends continuance with conditions. 1
The school fully met its elementary program goals and academic achievement expectations (academic
expectations), and achieved Tier 1 status on the 2012-13 Performance Management Framework. Its
early childhood performance is mixed, with the school missing progress and achievement targets it
established related to literacy and numeracy achievement from 2010-11 to present. However, the school
scores well on the Classroom Assessment Scoring System (CLASS) tool, which focuses on classroom
interactions that boost student learning.
The schools high percentage of English Language Learners and its dual-language immersion program
may contribute to lower student progress and achievement scores in the early grades despite evidence of
exemplary teaching and learning. This is further substantiated by the schools third grade DC CAS
proficiency. In 2012-13, 62% of DC Bilingual PCS students score proficient or advanced on the DC
CAS in reading, compared to the citys average of 44%. 50% of these students scored proficient or
advanced on the DC CAS in math, compared to the citys average of 43%.
DC Bilingual has repeatedly violated the School Reform Acts requirements related to procurement
contracts. The schools continuance should be conditioned on the school adhering to these requirements.
For the last three fiscal years, the school has been identified as a fiscally low performing school.
Operating deficits and declining net assets, among other things, threaten its economic viability. Its fiscal
problems are further complicated by its intertwined relationship with CentroNa, its charter management
operator. The school has in the past year taken steps to strengthen its financial position and clearly
segregate its financials from CentroNas; however this process is not complete.
Based on these findings, the PCSB Board voted on June 16, 2014, to conditionally continue the schools
charter, based on the conditions described below.

INTRODUCTION
School Overview
DC Bilingual PCS began operation in 2004 under authorization from PCSB to serve students in prekindergarten through fifth grade. 2 Its mission is as follows.

1
2

SRA 38-1802.12(a)(3).
DC Bilingual PCS charter agreement, dated July 8, 2004, attached to this report as Appendix A.

DC Bilingual PCS is a learning community that ensures high academic achievement for all students in
both Spanish and English, develops leadership, and values all cultures.
DC Bilingual PCS es una comunidad de aprendizaje que asegura un alto rendimiento acadmico para
todos los estudiantes en espaol e ingles, desarrolla el liderazgo y valora todas las culturas.
65.8% of the schools students are classified as English Language Learners (ELLs), one of the highest
rates in the DC charter sector. CentroNa, a nonprofit organization focused on bilingual communitybased education, manages the school. The school implements a dual language program, with students
receiving 50% of their instruction in English and 50% in Spanish.
The schools elementary school performance has shown annual consistent improvement on its
Performance Management Framework (PMF) score since the 2010-11 school year, with the school
achieving Tier 1 status in the 2012-13 school year. Information about the school and an overview of its
performance data are summarized in the table below.

Grade
Levels
PK3-2
3-5

Ward

Year
Opened

2004

2013-14
Student
Enrollment
216
169

2010-11
PMF

2011-12
PMF

2012-13
PMF

2 of 6
targets
56.8%

5 of 7
targets
60.3%

3 of 7
targets
65.2%

Charter Amendments
Since the 2009-10 school year, DC Bilingual has executed three charter amendments.

3
4

In June 2009, the PCSB Board approved the schools request to amend its charter to also serve
grades six through eight starting in the 2010-11 school year (however, DC Bilingual PCS
currently serves students through the fifth grade).
In June 2013, the PCSB Board conditionally approved a charter amendment request from the
school to join a consortium of charter schools in creating the District of Columbia International
School, which will serve students in grades six through twelve, and focus on language
immersion. 3
In March 2014, the PCSB Board approved an amendment to the schools charter agreement for it
to adopt the Early Childhood and Elementary/Middle School PMFs as its goals and academic
expectations. 4

See DCI Charter Amendment Request Board Memorandum, attached to this report as Appendix B.
See 2014 charter amendment board memorandum, March 17, 2014, attached to this report as Appendix C.

Previous Charter Review

In 2008-09, PCSB conducted a preliminary five-year review (a practice of PCSB at that time) of DC
Bilingual PCS and determined that the school did not meet any of the three academic performance
standards (a) it met a minority (4 of 11) of its academic targets; (b) it did not achieve a schoolwide
middle performance level (answering at least 50% correctly) on the DC CAS reading and math exams;
and (c) it did not make Annual Yearly Progress as required at that time by the Elementary and
Secondary Education Act. 5 The school also missed all of the three academic targets it set for its prekindergarten students. It did, however, meet three of four non-academic performance standards in place
by PCSB at that time. Based on this preliminary review, the PCSB Board placed DC Bilingual PCS in
charter warning status in January 2009. 6
In 2009-10, PCSB conducted a charter review of the school. In this review, it was found that the school
met two of the three academic standards in place (met a majority of its academic targets, scored higher
than middle performance on the DC CAS, but did not make Adequate Yearly Progress). It also met two
of its three pre-kindergarten academic targets. PCSB noted that the school demonstrate[d] notable
progress. Based on this review, PCSB granted the school full charter continuance in January 2010. 7
Charter Review Standard
The SRA stipulates that PCSB shall review [a schools] charter at least once every [five] years. 8 As
part of this review, PCSB must determine whether:
(1) The school committed a material violation of applicable laws or a material violation of the
conditions, terms, standards, or procedures set forth in its charter, including violations relating
to the education of children with disabilities; and/or
(2) The school failed to meet the goals and student academic achievement expectations set forth in
its charter. 9
If PCSB determines that a school has committed a material violation of law, or has not met its goals and
expectations, it may, at its discretion, revoke the schools charter, or grant the school a conditional
continuance.
Additionally, there is a fiscal component to the charter review. PCSB is required by the SRA to revoke a
schools charter if PCSB determines in its review that the school (1) has engaged in a pattern of
nonadherence to generally accepted accounting principles; (2) has engaged in a pattern of fiscal
mismanagement; and/or (3) is no longer economically viable.
5

See DC Bilingual 5-Year Review, Executive Summary, p. 1-2, attached to this report as Appendix D.
See Appendix D, p. 6; PCSB Board Meeting Minutes, dated January 26, 2009, attached to this report as Appendix E; PCSB
Decision Memorandum, DC Bilingual Public Charter School: Candidacy for Charter Warning Based Upon Preliminary
Charter Review Findings, dated Jan. 21, 2009, attached to this report as Appendix F.
7
See PCSB Board Meeting Minutes, dated Jan. 25, 2010 at http://www.dcpcsb.org/agenda/?id=39.
8
SRA 38-1802.12(a)(3).
9
SRA 38-1802.12(c).
6

PCSB renewal analysis and finding

DC Bilingual PCS fully met its elementary program goals and academic achievement expectations
(academic expectations), and achieved Tier 1 status on the 2012-13 Performance Management
Framework. Its early childhood performance is mixed, with the school missing targets it established
related to literacy and numeracy achievement from 2010-11 to present, but showing annual consistent
improvement in some measures that remained the same over the three-year period. The school received
high scores in two independent observation protocols, the Classroom Assessment Scoring System
CLASS (research-based tool which measures teacher-student interactions) and PCSBs Qualitative
Site Review, which uses the Danielson framework to evaluate schools climate and instructional
approach. The schools high percentage of English Language Learners and dual language immersion
program may contribute to its lower scores on student progress and achievement in reading and math for
the younger grades. It is important to note that in 2012-13, 62% of DC Bilingual PCS students score
proficient or advanced on the DC CAS in reading, compared to the citys average of 44%. 50% of these
students scored proficient or advanced on the DC CAS in math, compared to the citys average of 43%.
Regarding the schools legal compliance, DC Bilingual has repeatedly violated the School Reform Acts
requirements related to procurement contracts, despite its auditor identifying this deficiency each year
since 2010. Additionally, in three recent quarterly compliance assessments conducted by the Office of
the State Superintendent of Education, the school failed to reevaluate its special education students in a
timely manner.
For the last three fiscal years, the school has been identified as a fiscally low performing school.
Operating deficits and declining net assets, among other things, threaten its economic viability. Its fiscal
problems are further complicated by its intertwined relationship with CentroNa, its charter management
operator. The school has in the past year taken steps to strengthen its financial position and clearly
segregate its financials from CentroNas; however this process is not complete.
Given these findings, the PCSB Board voted to continue the schools charter, along with requiring the
school to fulfill the following conditions:
(1) that over the next four years, the school must fully comply with the SRAs requirements
regarding procurement contracts (which will be assessed as part of the schools renewal in 201819);
(2) that the school develop with PCSB staff a milestone-based plan to strengthen its financials and
segregate them from CentroNa; and
(3) that PCSB have access to review the financial books and records of CentroNa to the extent
needed to fully understand the financial position of the school.

SECTION ONE: GOALS AND ACADEMIC ACHIEVEMENT EXPECTATIONS

The SRA requires PCSB to review whether a school has met its goals and student academic achievement
expectations (expectations) at least once every five years. Goals are specific aims that are measurable
and usually related to a schools mission, which may be categorized as academic, non-academic, and
organizational, whereas expectations are student academic aims measured by state or externally
validated assessments. Goals and expectations are only considered as part of the renewal analysis if they
were included in a schools charter, charter amendment, or accountability plans approved by the PCSB
Board (collectively, the Charter).
In March 2014, DC Bilingual PCS amended its charter to adopt goals and expectations related to two
separate PCSB Performance Management Frameworks (PMFs):

Early childhood PMF indicators as the goals and academic expectations for its pre-kindergarten
through second grades; and
Elementary/middle school PMF as the goals and academic expectations for its third through fifth
grades. 10

Consistent with PCSB policy, when a school adopts the PMF as its goals and academic expectations,
PCSB will assess whether a school has met its goals and academic expectations starting in the school
year that the respective PMF was formally adopted by the PCSB Board. As such, the Elementary/Middle
School PMF is considered to be DC Bilingual PCS goals and academic expectations for its third
through fifth grades starting in school year 2010-11. Per PCSB policy and the schools 2014
amendment, these grade levels will be deemed to have met their goals and academic expectations at the
schools tenth-year review if it:
(a) Demonstrates annual consistent improvement in performance on the PMF, with no PMF score
below 40% in school years 2011-12 and 2012-13; and/or
(b) Earns a PMF score of 45% or more in 2011-12 and 2012-13, the two academic years prior to the
review assessment. 11
Per the schools 2014 amendment, it adopted the Early Childhood PMF indicators as its goals academic
expectations for its early childhood grades. However, consistent with PCSB policy, because the Early
Childhood PMF was in pilot status at the time the 2014 amendment was approved, the amendment
details that the school will be deemed to have met its early childhood goals and expectations in its tenyear review based on:

10

See Appendix C.
See Appendix PCSB Policy on Adopting the PMF as Goals and Academic Expectations, attached to this report as
Appendix G.
11

(a) Attainment of the targets outlined in the schools Early Childhood Accountability Plans for
school years 2009-10, 2010-11, and 2011-12; and
(b) Attainment of at least the floor of each indicator in the Early Childhood Pilot PMF for school
years 2012-13 and 2013-14. 12
Additionally, per PCSB policy, when a school adopts the PMF as its goals and expectations, PCSB may,
at it its discretion, determine that the school has met its goals and expectations if the school
demonstrates consistent annual improvement.
The school did not have targets in place in 2009-10, and the 2013-14 school year is still in progress. As
such, the following determinations are based on the schools performance in the 2010-11, 2011-12, and
2012-13 school year.
The chart below summarizes PCSBs determinations of whether each academic program met their
respective goals and academic expectations. These determinations are further detailed in the body of this
report.
Goals and Academic Expectations
Early Childhood
1

Literacy Progress

Partially

Literacy Achievement

No

Math Progress

No

Math Achievement

Partially

Attendance
Third through Fifth Grades
DC Bilingual PCS third-fifth grade program will
demonstrate annual consistent improvement on the PMF,
with no PMF score below 40% in school years 2011-12 and
2012-13; and/or earn a PMF score of 45% or more in 201112 and 2012-13.
Mission-Specific Goal
To measure Spanish language acquisition, 70% of students
will score proficient on the DC CAS science test, as science
is taught only in Spanish at the school.

Yes

12

Met?

Yes

Yes

See DC Bilingual 2014 charter agreement amendment, attached to this report as Appendix H.

EARLY CHILDHOOD PROGRAM

Pre-Kindergarten-Three through Second Grade
English Language Learner Population
A significant percentage of DC Bilingual PCS early childhood students are identified as ELL, as noted
in the table below. In 2013-14, the majority of the schools ELL students (119 of 154) were in its early
childhood program.
% Early Childhood ELL Students, 2013-14
Grade

PK3

PK4

% ELL

57.9%

81.0%

61.5%

40.5%

75%

All EC
grades
63.3%

As early childhood students progress through DC Bilingual PCS education program, many of them exit
their ELL status. For example, the table below details how many early childhood students in 2009-10
exited ELL status over the course of the next four academic years.

Grades

# of ELL
students in
2009-10

Exited
2009-10

Exited
2010-11

Exited
2011-12

Exited
2012-13

27

101

11

25

62

25

16

K2
Total

190

13

38

43

Total
Exited
10
(37.0%)
44
(43.6%)
41
(66.1%)
95
(50.0%)

Standard of Review
Per the schools 2014 charter amendment, it adopted the Early Childhood PMF indicators as its goals
and academic expectations for its early childhood grades. However, consistent with PCSB policy,
because the Early Childhood PMF was in pilot status at the time the 2014 amendment was approved, the
amendment details that the school will be deemed to have met its early childhood goals and expectations
in its ten-year review based on:
(a) Attainment of the targets outlined in the schools Early Childhood Accountability Plans for
school years 2009-10, 2010-11, and 2011-12; and

(b) Attainment of at least the floor of each indicator in the Early Childhood Pilot PMF for school
years 2012-13 and 2013-14. 13
Additionally, per PCSB policy, when a school adopts the PMF as its goals and expectations, PCSB may,
at it its discretion, determine that the school has met its goals and expectations if the school
demonstrates consistent annual improvement.
The school did not have targets in place in 2009-10, and the 2013-14 school year is still in progress. As
such, the following determinations are based on the schools performance in the 2010-11, 2011-12, and
2012-13 school year.

1. Goal: Early Childhood Literacy Progress.

Assessment: DC Bilingual PCS has partially met this goal. Its performance in pre-kindergarten
literacy progress has increased since 2010-11, and it has met associated targets in two of three years.
The schools kindergarten through second grade literacy progress increased from 2010-11 to 2011-12
(these targets are not comparable to its 2012-13 target) and it has not met the majority of these targets.
DC Bilingual PCS Pre-Kindergarten Literacy Progress
Year

Target Met? 14

Target

2010-11

70% of pre-kindergarten-3 and 80% of prekindergarten-4 students will master 70% and
80%, respectively of the pre-kindergarten
benchmarks by the spring administration on
The Creative Curriculum [Gold]
Assessment

2011-12

70% of pre-kindergarten-3 and prekindergarten-4 students will show

improvement on 70% and 80%, respectively,
of all non-mastered indicators by the spring
administration on the Gold Assessment.

Yes
77.3% of students
demonstrated improvement
on non-mastered standards.

2012-13

60% of pre-kindergarten-3 and prekindergarten-4 students will make appropriate

growth for their age on the Gold assessment.

Yes
97.2% of students met this
goal.

No
50% and 51% of students
scored at least 70% or
80%, respectively on the
assessment

DC Bilingual PCS K-2 Literacy Progress

13

See Appendix H.
In 2010-11, all early childhood results were rounded to the nearest whole number. In 2011-12 and 2012-13, early
childhood results were rounded to the nearest tenth decimal.

14

Year

Target

2010-11

70% of kindergarten through second-grade

students will demonstrate a year of growth in
reading on the Terra Nova assessment.

2011-12

60% of kindergarten through second-grade

students will demonstrate one year of growth
in reading by the spring administration on the
Terra Nova assessment.

2012-3

60% of kindergarten through second-grade

students will make 0 or greater normal curve
equivalent (NCE) in reading on the Terra
Nova assessment.

Target Met?
No
56% of students
demonstrated at least a
year of growth.
Yes
62.4% of students
demonstrated at least one
year of growth.
No
46.0% of students met this
goal.

2. Goal: Early Childhood Literacy Achievement.

Assessment: DC Bilingual PCS has not met this goal. The school has not met any early childhood
literacy achievement targets over the past three academic years but shown improvement from 2010-11 to
2011-12. In the last year, the target changed from the 50th to 40th percentile due to the implementation
of the Early Childhood PMF Pilot, which DC Bilingual PCS joined. The schools high percentage of
English Language Learners and dual language immersion program may contribute to its lower scores on
student achievement in reading for the younger grades.

DC Bilingual PCS Early Childhood Literacy Achievement

Year

Target

2010-11

70% of first- and second-grade students will

score at or above 50 NCE in reading on the
Terra Nova assessment.

2011-12

50% of first and second-grade students will

score at the 50th percentile or higher in
reading on the Terra Nova assessment.

2012-3

60% of kindergarten through second-grade

students will score at the 40th percentile or
higher in reading on the Terra Nova
assessment.

Target Met?
No
35% of students
scored at 50 NCE or
higher.
No
37.8% of students
scored at the 50th
percentile.
No
52.0% of students met
this goal.

3. Goal: Early Childhood Math Progress.

Assessment: DC Bilingual PCS has not met this goal. The schools performance has decreased from
2010-11 to 2011-12.
DC Bilingual PCS Early Childhood Math Progress
Year

Target

2010-11

70% of kindergarten through second-grade

students will demonstrate a year of growth in
mathematics on the Terra Nova assessment.

2011-12

60% of kindergarten through second-grade

students will demonstrate one year of growth
in math by the spring administration on the
Terra Nova assessment.

Target Met?
No 15
68% of students
demonstrated at least a
year of growth.
Yes
64.0% of students
demonstrated at least one
year of growth.

2012-3

60% of kindergarten through second-grade

students will make 0 or greater NCE in
mathematics on the Terra Nova assessment.

No
47.0% of students met this
goal.

4. Goal: Early Childhood Math Achievement.

Assessment: DC Bilingual PCS has partially met this goal. The school has not met any targets related
to early childhood math achievement since 2010-11 but showed improvement from 2010-11 to 2011-12.
In the last year, the target changed from 50th to 40th due to the advent of the Early Childhood PMF Pilot,
which DC Bilingual PCS joined.

DC Bilingual PCS Early Childhood Math Achievement

Year
2010-11

2011-12

15

Target
70% of first- and second-grade students will
score at or above 50 NCE in mathematics on
the Terra Nova assessment.
50% of first and second-grade students will
score at the 50th percentile or higher in math
on the Terra Nova assessment.

Target Met?
No
39% of students scored
at 50 NCE or higher.
No
42.9% of students
scored at the 50th
percentile.

If the school were using the same target (60%) as in subsequent years, the school would have met this.
10

2012-3

60% of kindergarten through second-grade

students will score at the 40th percentile or
higher in mathematics on the Terra Nova
assessment.

No
48.0% of students met
this goal.

5. Goal: Early Childhood Attendance.

Assessment: DC Bilingual PCS has met this goal. The school has met all early childhood attendance
targets since 2010-11.

DC Bilingual PCS Pre-Kindergarten Attendance

Year
2010-11

2011-12

2012-13

Target
On average, preschool and prekindergarten students will
attend school 88% of the days.
On average, pre-kindergarten-3
and pre-kindergarten-4 students
will attend school 88% of the
days.
On average, pre-kindergarten-3
and pre-kindergarten-4 students
will attend school 88% of the
days.

Target Met?
Yes
The average daily
attendance was 92%.
Yes
The average daily
attendance was 91.2%.
Yes
The average daily
attendance was 93.7%.

DC Bilingual PCS K-2 Attendance

Year
2010-11

2011-12

2012-13

Target
On average, kindergarten
through second-grade students
will attend school 92% of the
days.
On average, kindergarten
through second-grade students
will attend school 92% of the
days.
On average, kindergarten
through second-grade students
will attend school 92% of the
days.

Target Met?
Yes
The average daily
attendance was 96%.
Yes
The average daily
attendance was 94.0%.
Yes
The average daily
attendance was 94.8%.

11

Qualitative Evidence
PCSBs Qualitative Site Review of DC Bilingual PCS, conducted in November 2013, supports that the
school has a strong early childhood program. Overall, 97% of the teaching staff for grades PK through
5th grade scored proficient or advanced in climate and 87% in instructional strategies. Reviewers
recorded many instances of early childhood teachers challenging students to think critically and teaching
Common Core State Standards in both English and Spanish:
Teachers taught Common Core State Standards across all grade levels and
promoted critical thinking through questioning and discussion techniques.
Teachers asked open-ended, challenging questions for students to grapple
with as they worked through assignments. In one class, the teacher asked
first grade students to complete a thinking bubble to show what a
character in a short, silent movie was thinking. The assignment required
students to define thinking and to figure out someones thoughts from
facial expressions. Students enjoyed using small white boards at their
tables to display the assignment and the teacher gave critical, specific
feedback to elicit evidence of understanding. 16

Observers saw teachers teaching the Common Core State Standards in both
languages and preparing students to move to increasingly higher levels of
reading. In Spanish reading, a first grade teacher asked students to analyze
text by asking specific exploratory questions. 17

Additionally, PCSB reviewers observed teachers employing techniques to maximize learning in early
childhood classrooms:
In the pre-kindergarten classrooms, teachers took every opportunity to
increase pre-literacy skills by talking with students about their interests and
reading books to them, even during transitions. Starting with prekindergarten-3, teachers asked higher level thinking questions about texts
read and teachers asked students to explain their answers across all
grades. 18

16

See PCSB November 2013 QSR report, pp. 2-3, attached to this report as Appendix I.
See Appendix I, p. 3.
18
See Appendix I, p. 4.
17

12

In the pre-kindergarten classrooms, one teacher continued to read to tables

of students who were still eating while another teacher led a group to the
bathroom and the third teacher helped two tables clean up. Students
actively participated in transitions by cleaning up books, moving baskets
to the tables, or clearing snack. 19

Teachers structured learning tasks to keep students engaged and active.

Students had choice in the approach or through the results of many tasks. In
a kindergarten classroom, students chose from a variety of books, and had
the choice of reading with a partner or asking one of the teachers to read
with them. 20

CLASS Performance
All DC charter early childhood programs that participated in PCSBs Early Childhood PMF Pilot,
including DC Bilingual PCS, were assessed by independent reviewers using the Classroom Assessment
Scoring System (CLASS) tool, which focuses on classroom interactions that boost student learning.
The CLASS tool measures emotional support, classroom organization, and instructional support. Each
indicator is scored on a scale from 1-7, where 1-2 is low, 3-5 is medium, and 6-7 is high.
DC Bilingual PCS demonstrated charter-sector average or medium performance according to the
CLASS tool in Emotional Support and Classroom Organization and scored well above the sector
average on Instructional Strategies, as detailed in the table below.
Average Performance on CLASS
DC
Bilingual
PCS

All
Participating
DC Charter
Schools

Emotional Support

5.04

5.56

Positive Climate
Negative Climate 21
Teacher Sensitivity
Regard for Student
Perspectives
Classroom Organization

5.10
1.45
4.50

5.65
1.28
5.29

4.00

4.61

5.15

5.24

19

See Appendix I, p. 7.
See Appendix I, p. 9.
21
This indicator is scored inversely, with a 1 being the best score, and the 7 the lowest score.
20

13

Behavior Management

5.35

5.60

Productivity
Instructional Learning

5.75

5.54

4.35

4.60

4.08

2.50

3.65

2.27

4.00
4.60

2.68
2.62

Formats
Instructional Support
Concept Development
Quality of Feedback
Language Modeling

14

2010-11 Early Childhood Performance Report

15

2011-12 Early Childhood Performance Report

16

2012-13 Early Childhood Performance Report

17

ELEMENTARY SCHOOL
Third through Fifth Grades
6.
Goal: DC Bilingual PCS third-fifth grade program will demonstrate annual consistent
improvement in performance on the PMF, with no PMF score below 40% in school years 2011-12
and 2012-13; and/or earn a PMF score of 45% or more in 2011-12 and 2012-13.
Assessment: DC Bilingual PCS elementary school has met its goals and academic expectations.
Standard to meet Elementary/Middle School PMF Goals and Academic Expectations
Per the schools March 2014 charter amendment, 22 DC Bilingual PCS third through fifth grade program
will be deemed to have met its goals and academic expectations if it fulfills either or both of the two
following conditions:
(a) Demonstrates annual consistent improvement in performance on the PMF, with no PMF score
below 40% in school years 2011-12 and 2012-13; and/or
(b) Earns a PMF score of 45% or more in 2011-12 and 2012-13, the two academic years prior to the
review assessment.
DC Bilingual PCS elementary school has met its goals and expectations it fulfilled both of the above
two review standards. The schools elementary school PMF Scorecards are detailed in full on the
following pages of this report.

DC Bilingual PCS Elementary

School PMF Performance
2010-11

2011-12

2012-13

56.8%

60.3%

65.2%

Tier 2

Tier 2

Tier 1

Qualitative Evidence
PCSBs Qualitative Site Review of DC Bilingual PCS, conducted in November 2013, supports that the
school has a strong elementary program. Below are some excerpts from this review.
The review team observed students reading texts in both languages and
teachers challenged students with in depth questioning and analysis to
increase understanding of the passages. One class was analyzing a novel,
22

See Appendix H.

18

explaining vocabulary line by line. The teacher also asked the students to
support their opinions of issues raised in the novel. 23

To prepare students to be proficient in 8th grade math, teachers focused on

higher order questions and requested students to explain their thought
processes when working through problems. 24

In over 95% of the observations, teachers stated a clear purpose for the
lesson and checked for understanding through questions or hand signals. A
high level of student comprehension was evident by students responses
and the ability of students to complete the assigned tasks. Teachers pointed
out possible areas for misunderstanding and gave clear explanations of
concepts. All teachers observed used rich, age appropriate language to
introduce students to a wide range of vocabulary terms and explained the
definitions. 25

23

See Appendix I, p. 4.
See Appendix I, p. 5.
25
See Appendix I, p. 8.
24

19

2010-11 Third through Eighth Grade PMF Performance Report

20

2011-12 Third through Eighth Grade PMF Performance Report

21

2012-13 Third through Eighth Grade PMF Performance Report

22

7. 70% of students will score proficient on the DC CAS Science Test.

Assessment: DC Bilingual PCS has met this academic expectation.
The school notes in its charter agreement amendment the following about this academic expectation:
DC Bilingual PCS is a two-way immersion school taught with a 50/50
balance in Spanish and English. Our mission is to ensure high academic
achievement in Spanish and English. Science instruction is taught entirely
in Spanish through the entire program. Literacy instruction is delivered
within an interdisciplinary collaboration. Therefore, the science assessment
measures both Science and Spanish Literacy achievement.

DC Bilingual PCS science proficiency rate has increased each year, with 80.6% of students proficient
in 2012-13.

DC Bilingual: Grades 5 and 8

DC CAS Science Proficiency
100%
90%
80%
70%
60%
50%
40%

80.6%
61.1%

30%
20%

42.1%

44.7%

10%
0%
2009-10

2010-11
DC Bilingual PCS

2011-12
2012-13
State Average (Grades 5 and 8)

23

SECTION TWO: COMPLIANCE WITH CHARTER AND APPLICABLE LAWS

The SRA requires PCSB to determine at least every five years whether a school has committed a
material violation of applicable laws or a material violation of the conditions, terms, standards, or
procedures set forth in its charter, including violations relating to the education of children with
disabilities. 26 The SRA contains a non-exhaustive list of applicable laws, and PCSB also monitors
charter schools for compliance with additional laws in annual compliance reviews. Since 2009-10,
PCSB has found in its annual compliance reviews that DC Bilingual PCS has been in substantial
compliance with all applicable laws detailed in the table below.
Compliance Item

Description

Fair enrollment
process
SRA 38-1802.06

DC charter schools must have a fair and

open enrollment process that randomly
selects applicants and does not
discriminate against students.

Notice and due

process for
suspensions and
expulsions
SRA 381802.06(g)

DC charter school discipline policies

must afford students due process 28 and
the school must distribute such policies
to students and parents.

Student health and

safety
SRA 38-1802.04
(c)(4); DC Code 41321.02; DC Code
38-651

The SRA requires DC charter schools to

maintain the health and safety of its
students. 29 To ensure that schools adhere to
this clause, PCSB monitors schools for
various indicators, including but not limited
to whether schools:
- have qualified staff members that can
administer medications;
- conduct background checks for all
school employees and volunteers; and
- have an emergency response plan in
place and conduct emergency drills as
required by DC code and regulations.

Schools Compliance Status

2009-10 to present
In 2011-12, the schools
application included
language that is not
allowable. 27 This has been
resolved and the school
participated in the My School
DC common lottery in 2014.

Compliant since 2009-10

In November 2010, the school

received a Notice of Concern for
not submitting its DC Fire
Inspection report to PCSB in a
timely manner. This Notice was
lifted in December 2010. 30
At the time of the 2011-12
compliance review, three staff
members had not undergone a
background check. 31

26

SRA 38.1802.12(c).
See DC Bilingual PCS 2011-12 Compliance Review, attached to this report as Appendix J.
28
See Goss v. Lopez, 419 U.S. 565 (1975).
29
SRA 38.1802.04 (c)(4)(A).
30
See November 22, 2010 from Brian Jones, PCSB Chair, to Gretchen Ellsworth, DC Bilingual PCS Board Chair; see also
PCSB board memorandum, dated December 20, 2010, attached to this report as Appendix K.
31
See Appendix J.
27

24

In November 2010, the school

received a Notice of Concern
for not submitting its
employee handbook to PCSB
in a timely manner. This
Notice was lifted in December
2010. 32

Equal employment
SRA 381802(c)(5)

A DC charter schools employment

policies and practices must comply with
federal and local employment laws and
regulations.

Insurance
As required by the
schools charter

A DC charter school must be adequately

Compliant since 2009-10
insured.

Facility licenses
DC code 472851.03(d); DC
regulation 14-1401

A DC charter school must possess all

required local licenses.

Highly Qualified
DC charter schools receiving Title I
Teachers
Elementary and
funding must employ Highly Qualified
Secondary Education Teachers as defined by ESEA.
Act (ESEA)

In November 2010, the school

received a Notice of Concern
for not submitting its
Certificate of Occupancy to
PCSB in a timely manner.
This Notice was lifted in
December 2010. 33
In 2010-11, the school did not
upload a required letter to
parents regarding compliance
with the ESEA; several
teachers did not have required
action plans in place. 34

Proper composition
of board of trustees
SRA 38-1802.05

A DC charter schools Board of

Trustees must have:
an odd number of members that does
not exceed 15;
a majority of members that are DC
residents; and
at least two members that are parents of
a student attending the school.

Compliant since 2009-10

Accreditation
Status
SRA 381802.02(16)

A DC charter school must maintain

accreditation from an SRA-approved
accrediting body approved by the SRA.

Compliant since 2009-10

32

See 2010 Notice of Concern, and letter lifting this Notice, both attached to this report as Appendix L.
See Appendix L.
34
See Appendix J.
33

25

Procurement Contracts
SRA 38-1802.04(c)(1) requires DC charter schools to utilize a competitive bidding process for any
procurement contract valued at $25,000 or more, and within three days of awarding such a contract, to
submit to PCSB all bids received, the contractor selected, and the rationale for which contractor was
selected. To ensure compliance with this law, PCSB requires schools to submit a Determinations and
Findings form to detail any qualifying procurement contract that the school has executed.
In the schools 2009-10 fiscal audit, the school was found to have not consistently engaged in
competitive bidding for contracts valued at $25,000 or more, which the auditor classified as a
significant deficiency. 35 In each subsequent audit FY2011, FY2012, and FY2013 the auditor
found that the school was not consistently engaging in competitive bidding for qualifying contracts. 36

Year

2009-10
2010-11
2011-12
2012-13

Qualifying
contracts
executed by
DC Bilingual
PCS
6
4
1
2

Corresponding
documentation
submitted to
PCSB
0
1
0
0

Special Education Compliance

Charter schools are required to comply with all federal and local special education laws, including,
among others, the Individuals with Disabilities Education Act37 (IDEA) and the Rehabilitation Act of
1973. The following section summarizes DC Bilingual PCS special education compliance from 201011 to the present.
References to Special Education in School Charter
References in a schools Charter to special education must comply with special education laws.
DC Bilingual PCS description of serving special education students is appropriate.
OSSE Special Education Compliance Reviews
The DC Office of the State Superintendent of Education (OSSE) monitors charter schools special
education compliance and publishes three types of reports detailing these findings: (1) Annual
Determinations; (2) On-Site Monitoring; and (3) Quarterly Findings (also called Special Conditions
Reports). OSSEs findings of DC Bilingual PCS special education compliance are summarized below.
Annual Determinations
As required by a federal regulation, OSSE annually analyzes each LEAs compliance with 20 special
35

See DC Bilingual PCS 2009-10 audit, attached to this report as Appendix M.

See Appendix M.
37
20 USC 1413(a)(5).
36

26

education compliance indicators, and publishes these findings in an Annual Determination report. 38
Each years report is based on compliance data collected several years earlier. As such, OSSE does not
require schools to cure any compliance issues detailed in these reports. In 2012, OSSE published its
2010 Annual Determination reports (based on the schools 2009-10 performance).
In 2011, OSSE found that DC Bilingual PCS was 71% compliant with special education requirements,
with OSSE noting that the school Needs Assistance in fulfilling all applicable federal and local special
education regulations. 39 In 2010, OSSE found that DC Bilingual PCS was 75% compliant, and again
designating the school as Need[ing] Assistance with special education compliance. 40
On-Site Monitoring Report
OSSE periodically conducts an on-site assessment of an LEAs special education compliance with
student-level and LEA-level indicators, and publishes its findings in an On-Site Monitoring Report. At
the time, if a school was less than 80% compliant with a student-level and/or LEA-level indicator, it was
required to implement corrections and report these corrections to OSSE. (Beginning in 2013, LEAs are
responsible for being 100% compliant with student-level indicators and LEA-level indicators on On-Site
Monitoring Reports.) 41
In 2013, OSSE published an on-site Compliance Monitoring Report of DC Bilingual PCS based on the
schools performance in 2012-13. 42 The school was required to implement corrections in the following
areas:

38

As required by federal regulation 34 CFR 300.600(c).

See FFY 2011 IDEA Part B LEA Performance Determination, attached to this report as Appendix O. OSSE assigns to each
LEA one of the following Determination Level: (1) meets requirements; (2) needs assistance; (3) needs intervention; or (4)
needs substantial intervention.
40
See Appendix N.
41
If the school was found to be less than 100% compliant with a student-level indicator that could not be cured retroactively,
OSSE would identify the point of noncompliance as an LEA-level violation.
42
See 2011-12 On-Site Monitoring Report Attachments, attached to this report as Appendix O.
39

27

Student-Level Compliance

LEA-Level Compliance

Compliance Area

Number of
indicators where
school was less than
80% compliant

Compliance Area

Number of
indicators
where school
was less than
100% compliant

Initial Evaluations
and Reevaluations

3 out of 6

Data Verification

0 out of 1

IEP Development

6 out of 10

Dispute Resolution

0 out of 3

Least Restrictive
Environment

1 out of 2

Access to Instructional
Materials

0 out of 1

Discipline

0 out of 2
Fiscal Requirements

0 out of 21

Data Verification

4 out of 8

Total

14 out of 28

Total

0 out of 26

OSSE has since verified that DC Bilingual PCS has implemented corrections for all identified student
level findings.
Special Conditions Quarterly Reports
OSSE submits quarterly reports to the U.S. Department of Educations Office of Special Education
Programs detailing District of Columbia LEAs compliance in three areas: (1) Initial and Reevaluation
Timelines; (2) Early Childhood Transition Timelines; and (3) Secondary Transition Requirements.
In recent special conditions reporting on OSSEs DC Corrective Action Tracking System Database
(DCCATS), DC Bilingual PCS was found to be noncompliant for Initial Evaluation Timelines during
the span of October 1, 2012- December 31, 2012 and then again from January 1, 2013- March 31, 2013
(FFY 2012 Quarter 3 and 4). According to OSSE, the LEA has since corrected this issue of
noncompliance. 43
During FFY 2013 Quarter 1, DC Bilingual PCS was found to be noncompliant for Reevaluation
Timeliness during April 2, 2013-June 31, 2013. 44 OSSE has since verified that the LEA has
implemented corrections for all identified findings.
Blackman Jones Implementation Review
With compliance requirements pursuant to the Individuals with Disabilities Education Act (IDEA) and
the 2006 Blackman Jones Consent Decree, OSSE manages and oversees the Blackman Jones database
43
44

See Quarterly Findings Summaries, attached to this report as Appendix P.

See Appendix P.

28

that tracks each LEAs timely implementation of Hearing Officer Determinations (HODs) and
Settlement Agreements (SAs).
As of April 2014, the Blackman Jones Database shows DC Bilingual PCS has no HODs or SAs.

29

SECTION THREE:
FISCAL MANAGEMENT AND ECONOMIC VIABILITY

Separate and apart from the standard for charter renewal, the SRA requires that PCSB Board shall
revoke a schools charter if PCSB determines that the school:

Has engaged in a pattern of nonadherence to generally accepted accounting principles;

Has engaged in a pattern of fiscal mismanagement; or
Is no longer economically viable.

In the following section, PCSB has analyzed DC Bilingual PCS financial record in these areas. For the
last three fiscal years, the school has been identified as a fiscally low performing school. While the
school has recently established fiscal stability, consecutive operating deficits, poor cash liquidity, and
declining net assets over the past fiscal years remain as trends dangerous to the schools economic
viability. While there has been no pattern of fiscal mismanagement, auditors findings indicated that
improvements in internal controls were necessary. DC Bilingual PCS has no pattern of nonadherence to
GAAP.
Adherence to Accounting Principles and Fiscal Mismanagement
Audits of DC Bilingual PCS federal funds establish that the school adhered to generally accepted
accounting principles. Unqualified opinions on the financial statements in the past four audits were
issued. However, material weaknesses 45 and significant deficiencies 46 were identified for internal
control over financial reporting. Over the past three years, FY2013 was the first year with no material
weakness and significant deficiency identified.
Internal Control over Financial
Reporting
Material Significant
Fiscal
Weakness Deficiency
Year
Identified Identified
2009-10
No
No
2010-11
Yes
Yes
2011-12
Yes
Yes
2012-13
No
No

45

A material weakness is defined as a deficiency, or a combination of deficiencies, in in internal control, such that there is
a reasonable possibility that a material misstatement of the entitys financial statements will not be prevented, or detected and
corrected on a timely basis.
46
A significant deficiency is identified as existing when the design or operation of a control does not allow management
or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, misstatements on
a timely basis.

30

Also, in FY2011 and FY2012 the school had qualified opinions in its single audits, 47 with both material
weaknesses and significant deficiencies identified. In FY2011, the school did not appropriately maintain
employees timesheets, resulting in a questioned cost of $2,028. In addition, there were findings about
financial statement closing process and reporting of each federal program, nonadherence to its revenue
recognition policies of federal grants, and lack of cost or price analysis for goods and services for federal
programs. In FY2012, the same findings were not fully addressed. Also, the establishment of appropriate
procurement contract bidding and documentation continues to be an unresolved finding for DC
Bilingual PCS over the last four years.
Internal Control over Major
Programs
Material Significant
Fiscal
Weakness Deficiency
Year
Identified Identified
2009-10
N/A
N/A
2010-11
Yes
Yes
2011-12
Yes
Yes
2012-13
No
Yes
Related Party
DC Bilingual was established under the auspices of CentroNa, Inc., an education organization that
provides education, professional development and family-support services. CentroNa appoints three
members of the schools board of trustees. CentroNa provides management services to DC Bilingual
and pays personnel costs and certain direct expenses on the schools behalf. In FY2013, DC Bilingual
paid a management fee of $962,185 to CentroNia. Also, the school paid CentroNa about $4.6 million to
reimburse personnel and other direct costs paid by CentroNa on behalf of the school, compared to about
$5.5 million in FY2012. DC Bilingual leases office space with CentroNa and in the most recent fiscal
year had a rent expense of $931,669, including a proportionate share of taxes. CentroNas financial
position has followed a downward trend similar to DC Bilingual, with total net assets of $2.4 million in
FY2012 (December 31) from $4.1 million in FY2010. The primary driver for the consecutive operating
deficits from FY2010 to FY2012 has been increased program service expenses.
Economic Viability
DC Bilingual PCS has been in danger of being not economically viable from FY2010 to FY2012. In
FY2013, the school exhibited some early sign of fiscal stability based on the schools financial
performance, sustainability, liquidity, and debt burden, as described below. The schools fiscal health
remains a concern, which will continue to require routine monitoring.

47

Per the federal Single Audit Act of 1984, as amended by the Single Audit Act Amendments of 1996, any entity that
receives $500,000 or more in federal funding is required to undergo a Single Audit conducted by an independent, external
auditor, in accordance with the Office of Management and Budgets Circular A-133 (OMB A-133).

31

Financial Performance
PCSB assesses a schools financial performance with two key indicators. The first indicator is a schools
operating result how much its total annual revenues exceed its total annual expenditures. In general,
PCSB recommends that a schools annual operating results equal at least zero. Another indicator of a
schools financial performance is its earnings before depreciation (EBAD), 48 a financial performance
measure that eliminates the effects of financing and accounting decisions.
DC Bilingual PCS financial performance according to these two indicators weakened in FY2011 and
has not full recovered as of June 30, 2013. The school has produced three consecutive operating deficits
since FY2011, most recently with a $83,417 deficit in FY2013. DC Bilingual PCS management
attributed the past operating deficits to increased costs of operating a bilingual model and serving special
education students with greater needs. The school experienced a similar trend with its earnings before
depreciation in the past four years, with a positive EBAD only in FY2010.
Fiscal
Period
Operating
Result
EBAD

2010

2011

2012

2013

$681,917

$(308,791)

$(667,456)

$(83,417)

$778,468

$(212,895)

$(568,023)

$(3,824)

Expenditures
DC Bilingual PCS spending decisions, illustrated in the graph below, are aligned with PCSBs financial
metrics for general education public charter schools. 49

DC Bilingual PCS:
Expenditures as % of Revenues (FY2010 - FY2013
averages)
Personnel expenses
Direct student costs

57%

9%

15%

21%
Occupany expenses
Office and General
expenses

0%

48
49

20%

40%

60%

80%

100%

EBAD is the change in net assets plus amortization and depreciation.

Note that the percentage does not equal 100% because expenditures exceeded revenues on average.

32

Sustainability
A schools net assets 50 and primary reserve ratio demonstrate its sustainability. 51 PCSB recommends
that schools accrue net asset reserves equal to three to six months of operating expenditures, and PCSB
would be concerned with net assets reserves below zero. Over the past four years, the schools net asset
position has remained positive, but the rapid decline from $1.5 million in FY2010 to $456,334 in
FY2013 is a concern. The schools FY2013 primary reserve ratio was 0.06, meaning that its net asset
reserves equal 6% of its annual expenditures, a modest decline from FY2012. PCSB recommends that a
schools primary reserve ratio be at least between 0.2 and 0.3. The table below details the schools net
assets and primary reserve ratios over the past four years.

Fiscal Period
Net Assets
Primary
Reserve Ratio

2010
$1,515,998

2011
$1,207,207

2012
$539,751

2013
$456,334

0.24

0.17

0.07

0.06

Liquidity
Two indicators of a schools short-term economic viability are its current ratio 52 and its days of cash on
hand. 53 A current ratio (current assets divided by current liabilities) greater than one indicates a schools
ability to satisfy its immediate financial obligations. Since FY2010, DC Bilingual PCSs current ratio
has remained strong, though it has steadily declined since 2011. It stands at 1.96 in FY2013, indicating
that the school can meet its short-term financial obligations with current assets.
Typically, 90 days or more of cash on hand indicates a school can satisfy immediate obligations with
cash. Fewer than 30 days of cash on hand is a liquidity concern. DC Bilingual PCS days of cash on
hand has been weak over the last three fiscal years, with the schools days of cash on hand decreasing
from 19 days in FY2011 to 16 days in FY2013. The days of cash on hand remains a concern. The
schools current ratio and days of cash on hand trends are detailed in the table below.
Fiscal Period
Current Ratio
Days of Cash on
Hand 54

2010
4.05

2011
6.35

2012
2.90

2013
1.96

68

19

16

50

Net Assets equals total assets minus total liabilities.

Primary Reserve Ratio equals total net assets divided by total annual expenses.
52
Current assets divided by current liabilities. Current refers to the 12 months or normal operating cycles that a school can
convert certain assets into cash or use up or settle certain obligations.
53
Cash on hand equals unrestricted cash and cash equivalents divided by total expenditures divided by 360 days.
54
Because there was no breakdown for unrestricted and restricted cash in FY2009, total cash was used.
51

33

Cash flow from operations indicates whether a school produces adequate cash flow to meet its operating
needs. Since FY2009, DC Bilingual PCS has maintained positive cash flow from operations for two of
the past four years, as detailed in the below table.
Fiscal Period
Cash Flow from
Operations

2010

2011

2012

2013

$821,322

$(758,541)

$(230,377)

$222,449

Debt Burden
A schools debt ratio 55 indicates the extent to which a school relies on borrowed funds to finance its
operations. PCSB recommends that a schools debt ratio equal 0.6 or less. DC Bilingual PCSs debt
burden has steadily increased over the past three years from 0.17 in FY2010 to 0.47 in FY2013 due to
primarily declining total assets and increased account payables, but remains below the threshold of
concern.
Fiscal Period
Debt Ratio

55

2010
0.23

2011 2012
0.17 0.34

2013
0.47

Debt ratio equals total liabilities divided by total assets.

34