Mary Levy Testimony – At-Risk School Funding and School Based Budgeting and Transparency Amendment Acts of 2019 – June 26, 2019


 Joint Public Hearing on B23-0046, the “At-Risk School Funding Transparency Amendment Act of 2019” and B23-0239, the “School Based Budgeting and Transparency Amendment Act of 2019”

Mary Levy      July 26, 2019

As an education finance lawyer, a budget and policy analyst, and a long-ago DCPS parent, I have spent almost 40 years dealing with DCPS budget transparency, including annual analyses of system-wide and local school budgets.  After study of the two bills that are the subject of today’s hearing, I urge that the Council (1) pass the At-Risk School Funding Transparency legislation and (2) rework the School Based Budgeting and Transparency, which as written has multiple practical problems.

The At-Risk Funding bill is particularly good in requiring a narrative description of the use of at-risk funds and in going back to the original at-risk legislation’s directive that DCPS plans be formulated by the principal and LSAT at each school, subject to review and justified change by the Chancellor.

As to the School Based Budgeting bill, essentially we lack sufficient understanding of what the questions are that transparency is to answer and how its mandates are to be enforced.  It needs to be considered in tandem with Bill 23-199, which covers the same ground and more with important additional transparency provisions and application of FOIA to charter schools.  Specifics:

First, the School Based Budgeting bill includes some useful proposals:

  • The sec. 3(c) change in DCPS pupil count to account for enrollment increase in the course of the school year;
  • The sec. 4 requirement that meetings of public charter school boards of trustees be open;
  • The sec. 2 general idea that some DC government agency should create a chart of accounts with standard definitions enabling full disclosure of “administrative” (unfortunately undefined) costs, and comparability across schools and sectors. However, this major task with major implications and potential for unintended consequences needs much further development.

Second, no matter what the questions are, there will be no meaningful transparency unless:

  • The Council stops the practice of DCPS keeping two inconsistent, non-comparable, and confusing sets of books for local school budgets, i.e., those given to schools and posted on the DCPS website versus those in the city’s financial system, including the Mayor’s budget submission. The mess this makes was exemplified in the budget oversight hearing where DCPS witnesses and Council members were operating out of altogether different numbers.
  • The Council ceases to accept the DCPS definition of “central administration” as limited to the highest management levels plus business services, while allowing DCPS to treat the remaining central accounts as a mash of services directly benefiting students (e.g., special ed therapists, athletic trainers, security guards, utilities) and of costs of offices where hundreds of employees tell teachers and principals how to do their jobs. These are very different functions.


Third, the amendments to DC Code § 38–2907.01[1] obviously intend to make central office costs and local school budgets transparent, but the attempt is not successful:

  • “Central administration,” as currently defined leaves most central office costs unaccounted for, and not separated from costs directly benefitting students.
  • Attributing “central administration” expenditures to each of the many categories of the UPSFF is a waste of effort. It can be done automatically but since these functions almost all apply equally to each student, it will produce no useful information.  Separating central office expenditures that directly benefit students and then identifying how much goes to each school would be useful and important, but that is not what the bill proposes.
  • Local school budgets in both different sets of books, have considerable, though different detail in many regards, but mysteries exist: (1) general ed teacher allocation is a black box; (2) special education personnel allocation is a black box; (3) many schools receive local funding outside the Comprehensive Staffing Model, but there is no explanation of why some receive money for these programs and some do not.


Finally, there seems little point to enacting any of this legislation unless the Council provides for enforcement.  The DC Code already includes numerous mandates intended to provide budget transparency for DCPS that both DCPS and the Mayor ignore, without consequence or accountability.  A list follows:

  • 38–2903(b), the algorithm determining the UPSFF foundation level, including variables for personnel costs. The Mayor’s report does not include the variables.  There is no indication of why the amount proposed is what it is.
  • 38–2907.01(a)(2), limiting DCPS annual local school budget decreases to 5%.
  • 38–2907.01(b)(3), requiring DCPS at-risk funds to supplement, not supplant all other funds to which a school is entitled.
  • 38–2831(a), requiring the DCPS budget submission to include FTEs with job titles by program and revenue source.
  • 38–2831(b)(3)(A), requiring the DCPS budget submission to identify funds not allocated directly to a school or central administration that support costs provided at the school level or directly to students.
  • 38–2831(c), requiring the Chancellor to make available on the DCPS website a detailed estimate of funds required to operate DCPS for the ensuring year no later than 21 days before the Mayor’s budget submission.
  • 38–2831(d), requiring that the Mayor’s budget submission include the compilations of Schedule A positions and DCPS employees as of the preceding March 31.

[1] Sec. 3, the second subsection (b) as posted in LIMS, following subsection (c).


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