Additional Information on the 2019-2020 Community School Sponsor Evaluation

The ordered statewide school-building closure caused a significant disruption to educational activity in Ohio. This interruption created challenges to the successful completion of the 2019-2020 community school sponsor evaluation. The Ohio General Assembly passed emergency legislation, House Bill 197, canceling the spring administration of Ohio’s State Tests and waiving report card requirements (other than reporting of some limited, available data). HB 197 did not waive the requirements to implement a sponsor evaluation process. Rather, it specified that the 2019-2020 sponsor evaluation would not include an academic component. Subsequently, the legislature passed a follow-up bill, HB 164, that made additional adjustments to the evaluation.
 
HB 164 states the following: “For community school sponsor evaluations required under section 3314.016 of the Revised Code, the Department shall not issue a rating for the components under division (B)(1) of that section to any sponsor, nor shall the Department issue an overall rating for the sponsor. The Department shall allow a sponsor to indicate that it could not comply with an applicable law or administrative rule or fully adhere to a quality practice because the required action was unable to be completed due to the Director of Health's order under section 3701.13 of the Revised Code."
 
With this law in place, sponsors still are required to submit relevant documentation for the evaluation. The Department will score each item but will not issue ratings, making the 2019-2020 school year a “report-only” year.  


No effect in determining sanctions or penalties

As stated in the law: “The absence of community school sponsor ratings for the 2019-2020 school year shall have no effect in determining sanctions or penalties of a sponsor under Chapter 3314. of the Revised Code and shall not create a new starting point for determinations that are based on ratings over multiple years. The sponsor ratings of any previous or subsequent school years shall be considered when a sponsor is subject to sanctions or penalties under that chapter. A sponsor shall remain eligible in the 2020-2021 school year for any incentives that the sponsor was eligible for in the 2019-2020 school year, and the 2019-2020 school year shall not count toward the number of years in which a sponsor subject to division (B)(7)(b) of section 3314.016 of the Revised Code is not required to be evaluated.”
 

Deadlines extended to July 15

Sec. 17 (I) of Am. Sub. HB 197 of the 133rd General Assembly grants the state superintendent of public instruction the authority to:

“…extend or waive any deadline for an action required of the State Board of Education, the Department of Education, or any person or entity licensed or regulated by the State Board or Department during the duration of the Director of Health's order under section 3701.13 of the Revised Code "In re: Order the Closure of All K-12 Schools in the State of Ohio" issued on March 14, 2020, or any local board of health order, and any extension of any order, based on the implications of COVID-19, as necessary to ensure that the safety of students, families, and communities are prioritized while continuing to ensure the efficient operation of the Department and public and private schools in this state.”
 
The Compliance documentation submission deadline is specified in Ohio Administrative Code 3301-102-08(D), which reads as follows: 
 
Beginning with the 2018-2019 sponsor evaluation, the sponsor shall certify to the department, no later than the thirtieth of June…”
 
The superintendent has extended the deadline for the submission of documentation into Epicenter for the Compliance component from June 30 to July 15, 2020. The Department also is extending the deadline for the Quality Practices component to July 15. (This extension does not require the use of the HB 197 waiver authority because the original deadline of May 15 is set by the Department.)
 

No penalties for some items

HB 164 requires the state to evaluate sponsors on the Quality Practices and Compliance with All Laws and Rules components. However, the legislation says the Department shall allow a sponsor to indicate that it could not comply with an applicable law or administrative rule or fully adhere to a quality practice because the required action was unable to be completed due to the Director of Health's order under section 3701.13 of the Revised Code.”
 
To implement this requirement, the Department has developed the following procedures:
 

Compliance

To implement this provision, the Compliance component will have a new Epicenter submission type — “ordered-closure affected.” This submission type will be used by sponsors to indicate which items were affected by the ordered school building closure. Sponsors will need to include a brief explanation of why the closure affected the ability to complete the requirements for the respective item.
 
The Department also will add a new Compliance label on the worksheets the evaluation vendor uses to identify items sponsors indicated could not be completed or documented because of the ordered school building closure. These items will be identified as “closure-affected” and will be considered “substantiated” in the calculation of a sponsor’s Compliance component score.
 

Quality

For the Quality component, there are several items for which the school building closure or stay-at-home order may have impeded completion of required processes or submission of documentation. Accordingly, the Department has made modifications to the following quality rubric standards:
 
  • D.02 currently requires six reports to get a 3- or 4-point rating. The reviewer will only require four reports to get the 3 or 4 rating. The rest of the rubric standard remains as is.
  • D.03 currently requires submission of at least two site visits to get any points. The reviewer will require only one site visit if the sponsor was unable to complete the second one by the date of the ordered school building closure. In addition, if a second site visit was unable to be completed, the sponsor must provide an explanation of why that second site visit was not completed, when it was scheduled to be completed and what information was scheduled to be reviewed/collected during that site visit.
  • D.04 currently requires submission of at least two reports in order to get the 2-point rating. The reviewer will utilize only one site visit report if the sponsor was unable to complete additional reports by the date of the closure. In addition, if a second site visit report was unable to be completed, the sponsor must provide an explanation of why that report was not completed and what information would have been included in that report.
  • E.03 contains date deadlines that occur after the date of the closure. The reviewer will not consider deadlines that occurred after the closure date if the sponsor provides details of how the closure affected its ability to meet the stated deadline.
 
For any other standard for which a sponsor believes it is unable to complete the documentation, it should submit whatever documentation is available and include a brief explanation of how its ability to complete the documentation was affected by the school closure. The evaluation will be based on what is submitted.

As stated on page 12 of the 2019-2020 Sponsor Evaluation Technical Document, the following business rules are used when calculating the sponsor’s score in the Quality Practices component:
 
  1. The score is calculated using the following formula:
B/A where
A = The number of possible points for standards that are applicable to the sponsor being reviewed.
B = The total points scored in the standards included in A.
 
Following those business rules, if there is no submission or if there is only a partial submission, both the numerator and denominator will be adjusted to account for the points that are non-applicable due to the closure. 


Site visits

Vendors will not be conducting site visits this year due to the ordered school building closure and the desire to minimize any risks associated with traveling during the pandemic. The selected items for validation will include only those that do not require on-site validation.
 

Adjustment review period

There are no changes to the adjustment review period. A sponsor still will be able to submit an adjustment request form to the Department if it believes it received an inaccurate assessment of its level of performance on any compliance item or quality standard. 
 

Documentation of approvals

Sections 12(B) and 12(B)(2) of HB 197 state “members of a public body may hold and attend meetings and may conduct and attend hearings by means of teleconference, video conference, or any other similar electronic technology,“ and its members “shall be considered present as if in person at the meeting or hearing, shall be permitted to vote, and shall be counted for purposes of determining whether a quorum is present at the meeting or hearing.” The provision in HB 197 provides boards with flexibility to fulfill their approval obligations. 
 
As indicated in Section 12 of HB 197, school governing boards’ virtual meetings will be treated as in-person meetings. Any actions or resolutions adopted during those meetings must follow the provisions detailed in HB 197 and will have full effect.
 

Communications

The Department will provide information and updates on the 2019-2020 sponsor evaluation as they become available. Questions may be directed to sponsor.evaluation@education.ohio.gov.

Last Modified: 6/23/2020 8:45:45 AM