It’s Time for a CDE Office of Private Schools
During the course of a November 2, 2021 Zoom meeting with private school leaders, SSPI Thurmond committed to the creation of an advisory council on private education. Offering few details about the body’s composition and purposes, Mr. Thurmond hinted that its members would be drawn from both the private and public education sectors, and that the council would tackle the question: “How do we work together to support the needs of low-income students in private schools?” Calling for patience, and pledging to work in earnest on assembling the advisory body “after the start of the new year,” the SSPI proceeded to ask meeting participants how they would hope to see such a council function.
If emphasis is, indeed, to be directed at supporting the needs of low-income private school students, a few ideas come to mind. For one, the new advisory body could shine a spotlight on current levels of participation in school-based meals programs. Whatever one’s perception of private schools, the truth of the matter is that many private schools admit a certain percentage of students from low-income families on a tuition-free, or low-tuition basis. As is true of their public school counterparts, many of these children would benefit academically if they were to receive a nutritious breakfast (and lunch) at their respective private schools. Some do, but other private schools are reluctant to participate in publicly subsidized programs because they can come with burdensome, or untenable strings attached.
As an example, private schools opting to participate in the U.S. Department of Agriculture’s National School Lunch Program are at risk of being deemed “recipients of federal financial assistance,” a status that would make some subject to federal requirements from which they would otherwise be exempt. More specifically, faith-based schools would become bound by the myriad requirements of Title IX, and subject to compliance with special needs accommodations established by the broadly inclusive Section 504 of the Rehabilitation Act of 1973. It has been the policy of the USDA to deem all schools within a private school administrative unit (e.g., a diocese) “recipients,” if so much as a single school within the diocese participates in the program. Some might prefer to see private religious schools made subject to these requirements, but such a public policy contest should be waged without turning hungry children into so many political pawns.
Title I implementation presents another opportunity area (see lead article above). At one time the California Department of Education ran an ESEA Private School Working Group (PSWG) that brought local education agency staff members together with private school officials to anticipate and/or help resolve a variety of implementation issues, including the manner in which LEAs conduct counts of low-income students enrolled in private schools. As a member of that body I can attest that PSWG not only functioned as an effective problem-solving collaborative, but also served to generate trust and good will between our public and private education sectors. Its work need not become a focus of the new CDE advisory council, but the council might suggest the re-establishment of PSWG.
Whatever functions should be assigned to the new advisory council, its work would be facilitated by the establishment an Office of Private Education within the California Department of Education. The idea is by no means novel, as such an office existed as recently as the 1990s. In 2016, CAPSO pitched the idea to then CDE Chief Deputy Superintendent Glen Price, suggesting that a CDE Office of Private Schools could be primarily staffed around a full-time ESEA Ombudsman. CDE took a pass, but the idea continues to makes sense. The Ombudsman could be joined by CDE staff members responsible for overseeing the private school affidavit and coordinating federally funded “state activity” professional development programs for private school educators.
Perhaps Superintendent Thurmond would grant reconsideration to the siggestion. The CDE can be a deeply siloed agency, and staff providing private school support services are spread across the Department’s branches and divisions without a coordinating hub. It would be helpful if those responsible for overseeing the provision of ESEA state level professional development programs to private school educators would make timely mention of the Department’s Green Ribbon Schools program in their communications, or that private schools could receive a heads-up when new Form J-90 (public school teacher salary) data becomes available. When private school administrators seek information about federally funded statewide professional development workshops, perhaps the CDE staff member fielding the call could check to see whether the school has filed its affidavit for the current year. In like manner, the staff person who receives affidavit related phone calls might ask whether the caller would like to be added to the private school professional development listserv. Though private schools aren’t required to follow the state’s curriculum frameworks, it doesn’t follow that the frameworks are of no interest to private school educators. These, and many other CDE resources could be of value to a substantially greater number of private school educators if CDE staff made more of an effort to bring the resources to their attention.
If the current public health crisis hasn’t validated the observation that private schools are partners in the education of the public, nothing will. Of course there are differences, and private school leaders recognize that the CDE’s primary obligation is to our state’s public schools. That said, strengthening the relationship between the CDE and California’s private schools should be in the public interest. With that end in mind, now is the time to re-establish an Office of Private Schools within the California Department of Education.
Note: The commentary and views expressed in this article are those of the author, and do not necessary represent those of the California Association of Private School Organizations, or its members.