DISTRICT OF 

COLUMBIA 

CHARTER SCHOOLS

Multi-Agency Plan 

Needed to Continue 

Progress Addressing

High and 

Disproportionate 

Discipline Rates

Report to Congressional Committees

February 2017

GAO-17-165

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-165, a report to 

congressional committees

February 2017

DISTRICT OF COLUMBIA CHARTER SCHOOLS

Multi-Agency Plan Needed to Continue 

Progress Addressing High and 

Disproportionate Discipline Rates

What GAO Found

Discipline rates (out-of-school suspension and expulsion rates) at District of 

Columbia (D.C.) charter schools dropped from school years 2011-12 through 

2013-14 (the most recent years of national Department of Education data

available). However, these rates remained about double the rates of charter 

schools nationally and slightly higher than D.C. traditional public schools and

were also disproportionately high for some student groups and schools. 

Specifically, during this period, suspension rates in D.C. charter schools dropped

from about 16 percent of all students to about 13 percent, and expulsions, which 

were relatively rare, went down by about a half percent, according to GAO’s 

analysis. However, D.C. Black students and students with disabilities were

disproportionately suspended and expelled. For example, Black students 

represented 80 percent of students in D.C. charter schools, but 93 percent of 

those suspended and 92 percent of those expelled. Further, 16 of D.C.’s 105

charter schools suspended over a fifth of their students over the course of school 

year 2015-16, according to D.C. data.

Suspensions and Expulsions of Black Students and Students with Disabilities in District of 

Columbia Charter Schools Were Disproportionate Relative to Enrollment, School Year 2013-14

Note: Numbers may not add to 100 due to rounding.

The Public Charter School Board (PCSB) regularly uses several mechanisms to 

oversee charter schools’ use of suspensions and expulsions. For example, 

PCSB reviews school-level data and schools’ discipline policies to encourage 

schools to reduce reliance on suspensions and expulsions to manage student 

behavior. Several D.C. agencies have roles in overseeing charter schools and 

reported collaborating on other issues, but we observed a lack of consensus 

around roles and responsibilities regarding charter school discipline. Further, a

plan to issue regulations addressing discipline disparities among D.C. public 

schools was unsuccessful because the D.C. agency that planned to issue the 

regulations was unsure of its authority to do so. Absent a coordinated plan to 

continue progress in reducing discipline rates in charter schools, as well as

clarified roles, responsibilities, and authorities of D.C. agencies with respect to 

oversight of discipline in charter schools, continued progress may be slowed. 

View GAO-17-165. For more information, 

contact Jacqueline M. Now icki at

(617) 788-0580 or now ickij@gao.gov.

Why GAO Did This Study

D.C. charter schools served about 45

percent of D.C.’s public school 

students in the 2015-16 school year. 

The District of Columbia School 

Reform Act of 1995 established PCSB 

to authorize and oversee charter 

schools. PCSB also oversees charter 

schools’ use of suspensions and 

expulsions.

The District of Columbia Appropriations 

Act, 2005, as amended, included a 

provision for GAO to conduct a 

periodic management evaluation of 

PCSB. This report examines (1) what 

is known about suspensions and 

expulsions in D.C. charter schools, and 

(2) to what extent PCSB oversees 

charter schools’ use of suspensions 

and expulsions. GAO analyzed the 

most recent national federal data

(school years 2011-12 and 2013-14) 

and D.C. data (school year 2015-16)

on suspensions and expulsions; 

reviewed relevant laws, regulations, 

and agency policies and 

documentation; and interviewed 

officials at PCSB and other D.C. 

agencies, as well as other 

stakeholders selected to provide a 

range of perspectives. GAO also 

visited three charter schools that had 

high discipline rates.

What GAO Recommends

GAO is making two recommendations, 

including that D.C. education agencies

collaborate on a plan to further reduce 

discipline rates and make explicit

agency roles, responsibilities, and 

authorities regarding charter school 

discipline. The agencies did not 

explicitly agree or disagree with our 

recommendations and indicated they 

could deepen their collaboration.
Page i GAO-17-165 Oversight of D.C. Charter Schools

Letter 1

Background 4

Suspension and Expulsion Rates in D.C. Charter Schools Are 

Down, but Are About Twice the National Charter School Rates 12

PCSB and Other D.C. Agencies Oversee Charter Schools, but 

Have Not Created a Coordinated Plan to Help Schools 

Continue to Bring Down Discipline Rates 24

Conclusions 32

Recommendations for Executive Action 33

Agency Comments and Our Evaluation 33

Appendix I Objectives, Scope, and Methodology 37

Appendix II Regression Analysis 47

Appendix III Public Charter School Board Responsibilities 49

Appendix IV Public Charter School Application Process 51

Appendix V Summary of Public Charter School Board 2016 Annual Report 

Contents 56

Appendix VI Public Charter School Board Revenues and Expenditures 58

Appendix VII Public Charter School Board’s Discipline and Demographic Data 59

Appendix VIII Comments from the Public Charter School Board 65

Contents
Page ii GAO-17-165 Oversight of D.C. Charter Schools

Appendix IX Comments from the Office of the State Superintendent of Education 72

Appendix X GAO Contact and Staff Acknowledgments 74

Tables

Table 1: Race and Ethnicity Variables Used in Analysis of Civil 

Rights Data Collection (CRDC) 39

Table 2: Characteristics of the Three Charter Schools Selected for 

Interviews 45

Table 3: Association of Regression Model Variables with District of 

Columbia Public Schools’ Suspension Rates, School Year 

2013-14 47

Table 4: PCSB Responsibilities As Specified in the District of 

Columbia School Reform Act of 1995 49

Table 5: Types of Charter School Applicants and Charter Schools 

Specified in the PCSB Application Process 51

Table 6: PCSB’s Fall 2016 Charter Application Timeline 52

Table 7: PCSB Application Review Elements 52

Table 8: PCSB’s Application Review Criteria 54

Table 9: PCSB Annual Reporting Requirements and Components 

of 2016 Annual Report 56

Table 10: PCSB Revenues and Expenditures, Fiscal Years (FY) 

2011—2015 58

Table 11: PCSB School-Level Discipline and Demographic Data, 

School Year 2015-16 59

Table 12: PCSB Charter School Discipline Rates, School Years 

2012-13 through 2015-16 64

Figures

Figure 1: Demographic Composition of Students in Charter and 

Traditional Public Schools in the District of Columbia 

(D.C.) and Nationally, School Year 2013-14 7

Figure 2: D.C. Public Education Governance Structure 10

Figure 3: Suspension and Expulsion Rates in Pre-K and K-12 

District of Columbia Charter Schools, School Years 2011-

12 and 2013-14 14
Page iii GAO-17-165 Oversight of D.C. Charter Schools

Figure 4: Suspension Rates in K-12 D.C. Charter Schools Were 

Twice the National Rates and Slightly Higher than D.C. 

Traditional Public Schools in School Years 2011-12 and 

2013-14 16

Figure 5: Black Students and Students with Disabilities Were 

Disproportionately Suspended and Expelled in District of 

Columbia Charter Schools, School Year 2013-14 18

Figure 6: Black Students and Students with Disabilities Had the 

Highest Suspension and Expulsion Rates in District of 

Columbia Charter Schools, School Year 2013-14 19

Figure 7: Suspension Rates for Black Students and Students with 

Disabilities Are Higher Compared to Other Student 

Groups in District of Columbia (D.C.) Charter and 

Traditional Public Schools and Nationally, School Year 

2013-14 20

Figure 8: Suspension and Expulsion Rates Are Distributed 

Unevenly across 105 District of Columbia Charter 

Schools, School Year 2015-16 21

Figure 9: PCSB Discipline Monitoring Mechanisms 25

Figure 10: Excerpt from One Public Charter School’s Equity 

Report for School Year 2014-15 27
Page iv GAO-17-165 Oversight of D.C. Charter Schools

Abbreviations

CRDC Department of Education Civil Rights Data 

 Collection

D.C. District of Columbia

DCPS District of Columbia Public Schools

DME Deputy Mayor for Education

Education U.S. Department of Education

ESEA Elementary and Secondary Education Act of 1965

IDEA Individuals with Disabilities Education Act

IEP individualized education program

Justice U.S. Department of Justice

LEA local educational agency

OSSE Office of the State Superintendent of Education

PCSB Public Charter School Board

Pre-K Pre-Kindergarten 

School Reform Act District of Columbia School Reform Act of 1995

This is a work of the U.S. government and is not subject to copyright protection in the 

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without further permission from GAO. However, because this work may contain 

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Page 1 GAO-17-165 Oversight of D.C. Charter Schools

441 G St. N.W.

Washington, DC 20548

February 9, 2017

The Honorable Shelley Moore Capito

Chairman

The Honorable Christopher Coons

Ranking Member

Subcommittee on Financial Services and General Government

Committee on Appropriations

United States Senate

The Honorable Tom Graves

Chairman

The Honorable Mike Quigley

Ranking Member

Subcommittee on Financial Services and General Government

Committee on Appropriations

House of Representatives

In school year 2013-14, 2.8 million U.S. public school students were 

suspended from school, with disproportionately higher rates of discipline 

for students of color and students with disabilities, according to the most 

recent available data from the U.S. Department of Education (Education). 

The large and disproportionate numbers of suspensions and expulsions 

for some students in our nation’s K-12 schools has received national 

attention. This matter has prompted Education, in conjunction with the 

U.S. Department of Justice (Justice), to issue guidance encouraging 

states, school districts, and public schools, including charter schools, to 

limit the use of suspensions and expulsions, as these practices—known 

as exclusionary discipline—remove students from the classroom and 

reduce their instruction.1

In the District of Columbia (D.C. or the District), which has the fourthlargest proportion of its students enrolled in charter schools of any U.S. 

 1 See, for example, U.S. Department of Education, Guiding Principles: A Resource Guide 

for Improving School Climate and Discipline, (Washington, D.C.: January 2014);U.S. 

Department of Justice, Civil Rights Division and U.S. Department of Education, Office for 

Civil Rights, Dear Colleague Letter on the Nondiscriminatory Administration of School 

Discipline, January 2014; and U.S. Department of Education, Office for Civil Rights, Dear 

Colleague Letter – Charter Schools, May 2014. See 

http://www2.ed.gov/policy/gen/guid/school-discipline/index.html for Education’s web page 

on school discipline.

Letter
Page 2 GAO-17-165 Oversight of D.C. Charter Schools

city, the U.S. Secretary of Education has raised questions about the rates 

of suspensions and expulsions at some charter schools—public schools 

established under charters that are granted autonomy from certain state 

and local laws and regulations in exchange for increased accountability. 

The entity with primary oversight of charter schools in the District, the 

Public Charter School Board (PCSB), was established by the District of 

Columbia School Reform Act of 1995.2 The District of Columbia 

Appropriations Act, 2005, as amended, includes a provision for GAO to 

conduct a management review of PCSB every 5 years, including its 

oversight of charter schools.3 In this report, we examine 1) what is known 

about suspensions and expulsions in D.C. charter schools, and 2) to what 

extent PCSB oversees the use of suspensions and expulsions at charter 

schools.

To determine what is known about suspensions and expulsions in D.C. 

charter schools and compare them to national rates, we analyzed 

Education’s biennial Civil Rights Data Collection (CRDC) for school years 

2011-12 and 2013-14, the most recent years for which national data are 

available. The CRDC is a comprehensive source of data on suspensions 

and expulsions that collects comparable data across the nation’s public 

school districts, schools, and students. As such, we used the CRDC to 

make comparisons between D.C. charter schools, D.C. traditional public 

schools, and traditional and charter schools nationally. PCSB also 

collects information on suspensions and expulsions in D.C. charter 

schools, but these data are not comparable to CRDC data on schools and 

students in other states. At the time we did our work PCSB had data that 

were more recent than data available through the CRDC (school year 

2014-15 for PCSB versus 2013-14 for CRDC). We therefore chose to 

present PCSB’s data in selected analyses in the report, while also being 

careful not to make comparisons between the PCSB and CRDC data. In 

its written comments on a draft of this report, PCSB noted the recent 

availability of data for the 2015-16 school year. We updated our analyses 

accordingly to provide the most current picture of D.C. charter school 

discipline rates. Doing so did not materially change the findings in this 

report. PCSB provided us with these data on each charter school, which 

are part of data that the District collects annually on both charter schools 

 2 Pub. L. No. 104-134, Title II, § 2214, 110 Stat. 1321, 1321-132 (codified at D.C. Code § 

38-1802.14) (1996).

3 Pub. L. No. 108-335, § 346, 118 Stat. 1322, 1352 (2004), as amended by Pub. L. No. 

112-74, Div. C, Title VIII, § 816, 125 Stat. 786, 943 (2011).
Page 3 GAO-17-165 Oversight of D.C. Charter Schools

and traditional public schools.4 We determined that the data from both 

datasets were sufficiently reliable for the purposes of this report by 

reviewing documentation about the systems used to produce the data, 

conducting electronic testing, and interviewing Education and D.C. 

officials. As part of our data analysis, we also examined whether certain 

school characteristics—such as school type (charter versus traditional) 

and the racial composition of the student body—were associated with a 

higher incidence of suspensions in D.C. schools using a regression model 

based on the 2013-14 CRDC. In order to obtain charter school 

perspectives on reasons for high discipline rates in some schools, we 

conducted interviews with officials at three charter schools, selected 

because two had high discipline rates and one had reduced its formerly 

high discipline rates, according to D.C. data. These schools also 

represented variation on other school factors such as grades served and 

academic performance.

To determine the extent to which PCSB oversees suspensions and 

expulsions at D.C. charter schools, we reviewed documentation and 

guidance from PCSB as well as federal and District laws and regulations. 

We also reviewed documentation from other D.C. education agencies and 

Education. We interviewed PCSB officials, as well as officials at other 

D.C. agencies that have oversight responsibility for charter schools, 

including the Office of the State Superintendent of Education (OSSE), the 

District’s state educational agency; the Deputy Mayor for Education; and 

the State Board of Education, including the Ombudsman for Public 

Education and the Chief Student Advocate. Further, to obtain additional 

context and insights, we selected and interviewed researchers and 

officials from advocacy groups and associations with different 

perspectives on charter schools and discipline. Finally, we reviewed 

selected research studies that provided further context and insight into 

school discipline in charter schools. For more detailed information on our 

scope and methodology see appendix I. See appendix II for the results of 

the regression model.

We conducted this performance audit from November 2015 to February 

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

 4 Throughout this report, we use “traditional” to refer to publicly funded schools other than 

public charter schools, consistent with the definition used by Education’s National Center 

for Education Statistics.
Page 4 GAO-17-165 Oversight of D.C. Charter Schools

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

Education and Justice have an initiative underway to support local and 

statewide school discipline initiatives that build positive school climates 

while keeping students in school. Education has made school discipline 

reform a priority and recently launched its #RethinkDiscipline campaign to 

increase awareness about the detrimental impacts of exclusionary 

discipline. As part of this awareness campaign, Education has developed 

a webpage where administrators, educators, students, parents and 

community members can find data and resources to increase their 

awareness of the prevalence, impact, and legal implications of 

suspension and expulsion. This webpage contains, among other things, 

guidance for addressing the behavior needs of students with disabilities 

and a directory of federal school climate and discipline resources 

available to schools and districts.5

Of the approximately 87,000 public school students in D.C. in school year 

2015-16, about 45 percent attended charter schools, while about 55

percent attended traditional public schools.6 Charter schools in D.C. serve 

students ranging from pre-kindergarten (pre-K) through grade 12. D.C. 

charter schools offer a range of focuses and specialized curricula, such 

as foreign language immersion or a focus on serving students who have 

not been successful in traditional public school settings. For the vast 

majority of public charter schools, students enroll through D.C.’s common 

lottery system, My School DC.

D.C. charter schools, like all public schools, must comply with various 

laws governing the education of children, including those pertaining to 

 5 Education’s guidance on discipline and school climate related to this initiative can be 

found at: http://www2.ed.gov/policy/gen/guid/school-discipline/index.html.

6 Preliminary D.C. data for the 2016-17 school year show about 46 percent of public 

school students in D.C. enrolled in charter schools.

Background

Characteristics of D.C. 

Charter Schools
Page 5 GAO-17-165 Oversight of D.C. Charter Schools

individuals with disabilities, civil rights, and health and safety conditions.7

Further, in January 2014 guidance, Education and Justice stated that 

school districts that receive federal funds must not intentionally 

discriminate on the basis of race, color, or national origin, and must not 

implement any policies that have the effect of discriminating against 

students on the basis of race, color, or national origin.8 In addition, charter 

schools are to be held accountable for their financial and educational 

performance,9 including the testing requirements under the Elementary 

and Secondary Education Act of 1965 (ESEA), as amended.10 In D.C., all 

charter schools are nonprofit organizations and are required to be 

governed by a board of trustees.11 Members of the board of trustees are

selected according to terms laid out in the school’s charter, and the board 

assumes a fiduciary role and sets the overall policy for the school.12

Some D.C. charter schools are part of larger charter school networks that 

have schools in other states, such as KIPP or BASIS Schools. While 

some charter schools are managed by charter management 

 7 D.C. Code § 38-1802.04.Entities, such as traditional local educational agencies (LEA) 

and charter school LEAs, that receive federal financial assistance are prohibited from 

discriminating on the basis of race, color, or national origin, by Title VI of the Civil Rights 

Act of 1964, 42 U.S.C. § 2000d et seq., 34 C.F.R. Part 100, on the basis of sex by Title IX 

of the Education Amendments of 1972, 20 U.S.C. § 1681 et seq., 34 C.F.R. Part 106, and 

on the basis of disability, by Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 

794, 34 C.F.R. Part 104, in all of their operations. In addition, public entities, such as 

traditional LEAs and charter school LEAs, are prohibited from discriminating on the basis 

of disability in all of their operations, regardless of whether they receive federal financial 

assistance, by Title II of the Americans with Disabilities Act, 42 U.S.C. § 12131 et seq., 28 

C.F.R. Part 35. See also U.S. Department of Education, Office for Civil Rights, Dear 

Colleague Letter – Charter Schools, May 2014.

8 U.S. Department of Justice, Civil Rights Division and U.S. Department of Education, 

Office for Civil Rights, Dear Colleague Letter on Nondiscriminatory Administration of 

School Discipline, January 2014.

9 D.C. charter schools must submit an annual report to PCSB which includes, among 

other things, audited financial statements. D.C. Code § 38-1802.04(c)(11)(B)(ix). In 

determining whether a school’s charter will be renewed, PCSB will review all audited 

financial statements for the school, among other things. D.C. Code § 38-1802.12(b)(2).

10 D.C. charter schools receiving funds under Title I, Part A of ESEA are required to 

comply with most provisions of ESEA. D.C. Code § 38-1802.10(a)(5), (6).

11 D.C. Code §§ 38-1802.02(9), 38-1802.04(c)(16). 

12 The Board of Trustees must have an odd number of members that does not exceed 15, 

of which a majority must be D.C. residents,and at least 2 must be parents of a student 

attending the school. D.C. Code § 38-1802.05.
Page 6 GAO-17-165 Oversight of D.C. Charter Schools

organizations—which may handle, for example, curriculum development, 

teacher recruitment and training, and operational support services for the 

charter school—other charter schools are single-school networks and 

operate without such an entity. In the 2015-16 school year, there were 

114 charter schools in D.C., run by 65 different organizations.13 In the 

District, each charter school or group of charter schools functions as its 

own local educational agency (LEA), both for purposes of Title I of 

ESEA,14 and other purposes. As such, each charter school or group of 

charter schools is responsible for a wide range of functions associated 

with being an LEA, such as applying for certain federal grants and 

acquiring and maintaining facilities. PCSB officials told us that each 

charter LEA also has the autonomy to establish its own discipline policies 

and suspend and expel students. Officials from the State Board of 

Education also told us that, unlike D.C. traditional public schools, charter 

LEAs are not subject to the discipline policies and procedures in D.C. 

municipal regulations.

As shown in figure 1, charter schools and traditional public schools in 

D.C. both serve a largely Black population. In the 2013-14 school year, 80 

percent of the students in charter schools were Black, compared to 67 

percent in traditional public schools in the District. Both charter and 

traditional public schools in D.C. serve much higher percentages of Black 

students compared to schools nationally, reflecting D.C.’s large Black 

population. 

 13 PCSB’s annual report for 2016 stated that there were 115 charter schools in that year, 

but their discipline data included only 114 schools and PCSB officials later confirmed that 

114 was the correct count. In the 2016-17 school year there are 118 schools run by 65 

organizations.

14 D.C. Code § 38-1802.10(a)(1)(A).
Page 7 GAO-17-165 Oversight of D.C. Charter Schools

Figure 1: Demographic Composition of Students in Charter and Traditional Public 

Schools in the District of Columbia (D.C.) and Nationally, School Year 2013-14

With respect to students with disabilities, D.C. charter schools serve 

slightly lower percentages of these students than D.C. traditional public 

schools, but D.C. charter schools and D.C. traditional public schools both 

serve slightly higher percentages of these students than their national 

counterparts (see fig. 1). The Individuals with Disabilities Education Act 

(IDEA) contains specific procedures that govern the discipline of IDEAeligible students with disabilities.15 In 2016, Education issued two pieces 

of “significant guidance” relevant to these students. The first emphasizes 

the importance of using IDEA’s individualized education program (IEP) 

and placement provisions to provide needed positive behavioral 

interventions and supports and other strategies to address the behavior of 

 15 20 U.S.C. § 1415(k) and 34 C.F.R. §§300.530-300.536.
Page 8 GAO-17-165 Oversight of D.C. Charter Schools

a student whose behavior impedes his or her learning or that of others.16

The guidance explains that these supports are especially important in 

light of research showing the detrimental effects of disciplinary 

suspensions, both short- and long-term, on students with disabilities.17

The second guidance document emphasizes that charter schools have 

the same obligation as other public schools to provide IDEA-eligible 

students with these supports, as well as all other protections under the 

law. In addition, Education noted in this guidance that it expects that a 

charter school authorizer will be able to ensure that any charter school 

that it authorizes complies with the terms of its charter, as well as 

applicable federal and state laws, including IDEA and other civil rights 

laws.18 Examples of covered disabilities under IDEA include intellectual 

disabilities, hearing or visual impairments, emotional disturbance, autism, 

and specific learning disabilities.19

In the District, traditional public schools and charter schools have different 

oversight structures. The Chancellor of D.C. Public Schools oversees the 

traditional public schools, which operate as a single LEA. In contrast, 

each charter school or group of charter schools operates as its own LEA. 

The District of Columbia School Reform Act of 1995 (School Reform Act) 

established PCSB, an independent agency which provides the primary 

 16 Each child with a disability under IDEA receives an individualized education program, 

which is a written statement for each child that includes academic and functional goals for 

the child and that is approved by an individualized education program team consisting of 

the child’s parents, teachers, representatives of the LEA, and other experts. See 20 

U.S.C. § 1414(d).

17 U.S. Department of Education, Office of Special Education and Rehabilitative Services, 

Dear Colleague Letter on Ensuring Equity and Providing Behavioral Supports to Students 

with Disabilities, August 2016. This guidance is available at 

https://www2.ed.gov/policy/gen/guid/school-discipline/files/dcl-on-pbis-in-ieps--08-01-

2016.pdf. Significant guidance is defined in the Office of Management and Budget’s Final 

Bulletin for Agency Good Guidance Practices, 72 Fed. Reg. 3432 (Jan. 25, 2007).

18 U.S. Department of Education, Office of Special Education and Rehabilitative Services, 

Frequently Asked Questions about the Rights of Students with Disabilities in Public 

Charter Schools under the Individuals with Disabilities Education Act (December 28, 

2016). This guidance is available at 

https://www2.ed.gov/policy/speced/guid/idea/memosdcltrs/faq-idea-charter-school.pdf.

19 20 U.S.C. § 1401(3)(A).

Charter School 

Governance Structure
Page 9 GAO-17-165 Oversight of D.C. Charter Schools

oversight of D.C. charter schools.

20 However, as in the states, general 

oversight of federal education program funding requirements—including 

requirements for serving students with disabilities and those related to 

federal civil rights—is the responsibility of the state educational agency, 

which in D.C. is OSSE. In addition, other D.C. education agencies are to 

coordinate with PCSB and interact with charter schools in various ways 

(see fig. 2).

 20 Pub. L. No. 104-134, Title II, § 2214, 110 Stat. 1321, 1321-132 (codified at D.C. Code § 

38-1802.14) (1996).The School Reform Act also designated the D.C. Board of Education

as a chartering authority. However, in 2007, the D.C. Council passed the Public Education 

Reform Amendment Act of 2007 (D.C. Law 17-9). This law transferred oversight 

responsibility for charter schools previously authorized by the Board of Education to 

PCSB, making PCSB the sole charter school authorizer in the District. The 2007 Act also 

placed D.C. public schools under the governance of the Mayor, moved the state education 

functions into a new state superintendent’s office (Office of the State Superintendent of 

Education), established a separate public education facilities office, and created the D.C. 

Department of Education headed by the Deputy Mayor for Education. Moreover, the 2007 

Act eliminated the Board of Education and created a new State Board of Education with 

responsibility for advising the State Superintendent of Education on educational matters, 

including state academic standards, polices, and regulations for traditional public schools, 

as well as charter schools. 
Page 10 GAO-17-165 Oversight of D.C. Charter Schools

Figure 2: D.C. Public Education Governance Structure

Note: The D.C. Mayor appoints PCSB’s members w ith the advice and consent of the D.C. Council.

PCSB, as the sole chartering authority in D.C., has the power to approve, 

oversee, renew, and revoke charters.21 (See app. III for a list of PCSB’s 

responsibilities.) PCSB reviews applications for new charters, as 

described in appendix IV, and then is responsible for monitoring charter 

schools’ academic achievement, operations, and compliance with 

applicable laws.22 PCSB is also required to submit an annual report that 

includes information on charter renewals, revocations, and other actions 

 21 See generally, D.C. Code §§ 38-1802.11 - 38-1802.14.

22 D.C. Code § 38-1802.11(a)(1).
Page 11 GAO-17-165 Oversight of D.C. Charter Schools

related to public charter schools.23 (See app. V for more information on 

PCSB’s annual reporting.) The School Reform Act allows PCSB to grant 

up to 10 charters per year.24 Each charter remains in force for 15 years. 

After 15 years in operation, if a school desires to renew its charter, it is 

required to submit a renewal application requesting to renew its charter 

for another 15-year term.25 Charters may be renewed an unlimited 

number of times. PCSB is also required to review each charter at least 

once every 5 years to determine whether the charter should be revoked.26

PCSB itself is comprised of seven unpaid board members who are 

appointed by the Mayor, with the advice and consent of the D.C. Council, 

and who are to be selected so that knowledge of specific areas related to 

charter schools is represented on the board.27 In addition, there are 37 

employees who implement the board’s policies and oversee charter 

schools. PCSB’s main source of revenue is administrative fees from 

charter schools, and its main expenditures are for its personnel and for 

other costs related to its monitoring activities (see app. VI for more 

information on PCSB’s revenues and expenditures).

Students who are suspended or expelled from any public school have 

certain rights. These rights are derived from a number of sources, 

including state and federal constitutional and statutory law and court 

decisions interpreting them.28 For instance, the U.S. Supreme Court has 

held that all students facing temporary suspension have interests 

qualifying for protection under the Due Process Clause of the U.S. 

Constitution and that due process requires, in connection with a 

 23 D.C. Code § 38-1802.11(d). The report must be submitted to the Mayor, the District of 

Columbia Council, the Board of Education, the Secretary of Education, and the 

appropriate Congressional committees.

24 D.C. Code § 38-1802.03(h)(2)(i)(2)(A).

25 D.C. Code § 38-1802.12(a).

26 D.C. Code § 38-1802.12(a)(3). PCSB may revoke a charter for fiscal mismanagement, 

if the school has committed a violation of applicable laws or the terms of its charter, or if 

the school has failed to meet the student academic achievement goals in its charter. D.C. 

Code § 38-1802.13(a) and (b)

27 D.C. Code §§ 38-1802.14(a)(2), 38-1802.14(c).

28 GAO did not conduct an exhaustive examination of the rights afforded D.C. public 

school students as this was outside the scope of this report.

Rights of Students 

Suspended or Expelled 

from Charter Schools
Page 12 GAO-17-165 Oversight of D.C. Charter Schools

suspension of 10 days or less, that a student be given oral or written 

notice of the charges against them and an explanation of the evidence 

the authorities have and an opportunity to present the student’s side of 

the story.29 Further, students with disabilities under IDEA have specific 

rights afforded under that statute.30 In particular, if a school proposes 

suspending a student served under IDEA for more than 10 days, the LEA, 

the student’s parents, and relevant members of a child’s IEP team must 

conduct a review to determine whether the behavior in question is a 

manifestation of the student’s disability. If so, the suspension cannot 

proceed. Students with disabilities also have rights to educational 

services while suspended.31

District of Columbia Charter School Discipline at a Glance

• Discipline rates for charter schools overall dropped from school

year 2011-12 through school year 2013-14 according to federal

data, and continued to drop through school year 2015-16,

according to D.C. data.

• According to federal data, in school year 2013-14:

o Both charter and traditional public schools in D.C. had

suspension rates that were about double the rates for

schools nationally.

o D.C. charter school suspension rates were slightly higher

than D.C. traditional public school suspension rates

overall.

o Discipline rates remain disproportionately high for Black

students and students with disabilities.

• Rates for individual charter schools varied widely in 2015-16,

according to D.C. data.

Source: GAO analysis of U.S. Department of Education’s Civil Rights Data Collection and Public Charter School Board data. | 

GAO-17-165 

Note: Federal and D.C. data are not comparable.

29 Goss v. Lopez, 419 U.S. 565, 581 (1975). 

30 In addition, the U.S. Supreme Court also held that IDEA’s predecessor prohibits school 

authorities from unilaterally removing students with disabilities from the classroom for 

more than ten school days for dangerous or disruptive conduct stemming from their 

disability. Honig v. Doe, 484 U.S. 305 (1988).

31 20 U.S.C. § 1415(k)(1)(D). 34 C.F.R. § 300.530(d).

Suspension and 

Expulsion Rates in 

D.C. Charter Schools 

Are Down, but Are 

About Twice the 

National Charter 

School Rates
Page 13 GAO-17-165 Oversight of D.C. Charter Schools

Discipline rates—that is, out-of-school suspensions and expulsions—at 

D.C. charter schools dropped from school year 2011-12 through school 

year 2013-14, but remained disproportionately high for Black students 

and students with disabilities, as well as at some schools.32 The overall 

suspension rate for K-12 students dropped from 16.4 percent of all 

students to 13.4 percent, a 3 percentage point drop from school years 

2011-12 to 2013-14, the most recent years for which national data are 

available (see fig. 3).33 The number of students suspended similarly 

dropped from 4,465 to 3,980 students over that same period. D.C.’s own 

data, which is collected annually and is more recent, also indicated that 

suspension rates for D.C. charters schools dropped from school year 

2012-13 through school year 2015-16. (See app. VII for PCSB’s data on 

D.C. charter school discipline rates for school years 2012-13 through 

2015-16).34

 32 To compare D.C. public charter school data with D.C. traditional public school data, as 

well as national data for both charter and traditional public schools, we primarily analyzed 

data from school year 2013-14, the most recent for which national data are available. In 

addition, PCSB’s data are not comparable to Education’s data.

33 While rates went down, absent more data points we cannot say definitively whether this 

is part of larger trend. 

34 PCSB’s data are not comparable to Education’s data in part because they do not 

distinguish between pre-K and K-12 rates, and also included three adult-serving schools 

not included in the CRDC. In addition, we found 12 K-12 charter schools that were in 

operation in 2013-14 that were not captured in Education’s data. All except 1 of the 12 

schools closed by the end of the 2014-15 school year, which likely prevented them from 

submitting data. 

Discipline Rates of 

Students in D.C. Charter 

Schools Have Dropped
Page 14 GAO-17-165 Oversight of D.C. Charter Schools

Figure 3: Suspension and Expulsion Rates in Pre-K and K-12 District of Columbia 

Charter Schools, School Years 2011-12 and 2013-14

Note: Pre-K = Pre-Kindergarten. The 2013-14 pre-K expulsion data presented here differ from the 

Civil Rights Data Collection publicly available at the time GAO did its w ork. One group of charter 

schools did report pre-K expulsions in that year, but later said they did so in error and w ere working 

w ith the Department of Education to correct the data. The Public Charter School Board reported zero 

pre-K expulsions in 2013-14, w hich is what we present here.

Expulsions for K-12 students were also down, with 188 students expelled 

in 2011-12 (a rate of 0.7 percent) compared to 133 students expelled in 

D.C. charter schools in 2013-14 (a rate of 0.4 percent), according to 

Education’s data (see fig.3). D.C.’s data similarly show expulsion rates for 

D.C. charter schools dropping over the 4-year period from 2012-13 

through 2015-16 (see app. VII). Expulsions for pre-K students remained 

very low—there were zero pre-K expulsions in 2013-14 compared to two 

expulsions in 2011-12—an expulsion rate of less than .01 percent.35

 35 In 2015, the D.C. Council passed a law restricting suspensions and disallowing 

expulsions for pre-K students, which took effect during the 2015-16 school year. (Pre-K 

Student Discipline Amendment Act of 2015,D.C. Act 21-50)
Page 15 GAO-17-165 Oversight of D.C. Charter Schools

In both 2011-12 and 2013-14 both D.C. charter schools and traditional 

public schools had suspension rates that were about double the rates for 

schools nationally, according to Education’s data (see fig. 4). For 

example, in 2013-14, D.C charter schools had about a 13 percent 

suspension rate, while the national rate for all charter schools was about 

6 percent. This was also true for expulsions, with charter schools in D.C. 

reporting double the rate of charter schools nationally. Within D.C., 

charter schools’ suspension rates were slightly higher than D.C. 

traditional public schools. In the same year, D.C. charter schools expelled 

133 K-12 students (a rate of 0.4 percent). D.C. charter school students 

who are expelled are not permitted to return to their charter school. They 

typically return to their traditional public school for the remainder of the 

school year but may re-enter the D.C. school lottery for a different charter 

school the next year. In contrast, D.C. traditional public schools generally 

do not expel students. Instead, D.C. traditional public schools generally 

use long-term suspensions (greater than 11 days) and temporarily 

transfer these students to an alternative middle and high school.36

 

36 D.C. traditional public schools only expel students for extreme circumstances, such as 

violence, and such students are expected to attend the alternative school for 180 days 

and then return to their original school. In 2014-15, 266 students in D.C. traditional public 

schools were transferred to the alternative school, and 3 of these students had been 

issued 1-year expulsions.

Suspension Rates in D.C. 

Schools Are About Twice 

the National Rates
Page 16 GAO-17-165 Oversight of D.C. Charter Schools

Figure 4: Suspension Rates in K-12 D.C. Charter Schools Were Twice the National Rates and Slightly Higher than D.C.

Traditional Public Schools in School Years 2011-12 and 2013-14

Note: Expulsion rates for District of Columbia (D.C.) charter and traditional public schools reflect 

differences in policy. D.C. traditional public schools generally use long-term suspensions instead of 

expulsions and temporarily transfer these students to an alternative middle and high school. D.C. 

traditional public schools only expel students for extreme circumstances, such as violence, and such 

students are expected to attend the alternative school for 180 days and then return to their original 

school.

Further, for both charter and traditional public schools in D.C., some 

stakeholders we spoke with had concerns about schools removing 

students from school without issuing them formal suspensions—a 

practice they said occurs in some schools. Both the Ombudsman for 

Public Education and officials from a legal advocacy group for children 

told us they had worked on cases in which students were sent home for 

part or all of a school day for behavior-related reasons without being 

formally suspended. The three D.C. charter schools we visited all 

engaged in these practices to some extent. For example, at one of the 

three schools, officials said a student may be asked to stay home, but not 
Page 17 GAO-17-165 Oversight of D.C. Charter Schools

formally suspended, while the school investigates a behavior incident. 

Such full-day removals from school should be reported as suspensions 

under D.C. law, which defines out-of-school suspension as removing a 

student from school for disciplinary reasons for 1 school day or longer.37

At this school and the two others we visited, officials also said that when a 

behavioral incident occurs, they may send a student home for the 

remainder of the school day without issuing a formal suspension. Based 

on D.C.’s legal definition of suspension and PCSB reporting 

requirements, these partial day removals would only be tracked in the 

D.C. data if the student had a disability and was sent home for at least 

half of the school day. PCSB officials told us they require charter schools 

to follow the law in reporting suspensions and have discouraged schools 

from using partial day removals as a way to avoid formal suspensions. 

Frequent partial or full day removals from school can contribute to a 

significant amount of missed instruction time that is currently not fully 

captured, tracked, or monitored by PCSB or other D.C. education 

agencies, despite their stated goals of using data to reduce exclusionary 

discipline practices.

Although suspension and expulsion rates at D.C. charter schools have 

dropped overall and across most student groups, rates varied widely 

among groups of students and among individual D.C. charter schools. 

Specifically, Black students and students with disabilities were 

disproportionately suspended and expelled from D.C. charter schools, 

according to Education’s 2013-14 data.38 As shown in figure 5, although 

Black students represented 80 percent of charter school enrollment, they 

represented 93 percent of those suspended and 92 percent of those 

expelled. Black boys, who represented 39 percent of enrolled students, 

were 56 percent of those suspended and 55 percent of those expelled 

over this period (not shown). Similarly, students with disabilities 

 37 D.C. Code § 38-271.01(5A). In contrast, in 2013-14, the federal Civil Rights Data 

Collection required schools to report removals of at least half a day as suspensions. 

38 Our analysis of students with disabilities included only those students receiving services 

under the Individuals with Disabilities Education Act, and not those receiving services 

under Section 504 of the Rehabilitation Act of 1973, as amended, because Section 504 

students were not reported by race and ethnicity. Section 504 is a civil rights statute which 

prohibits discrimination on the basis of disability in any program or activity receiving

federal financial assistance. 29 U.S.C. § 794. Students only receiving services under 

Section 504 represented 8 percent of the population of all students with disabilities in D.C. 

public school students in 2013-14. 

Discipline Rates Varied 

Widely Among Student 

Groups and Schools in 

D.C.
Page 18 GAO-17-165 Oversight of D.C. Charter Schools

comprised 12 percent of D.C. charter school enrollment but represented 

20 percent of those suspended and 28 percent of those expelled.

Figure 5: Black Students and Students with Disabilities Were Disproportionately 

Suspended and Expelled in District of Columbia Charter Schools, School Year 

2013-14

Note: Numbers may not add to 100 due to rounding.

Our analysis also found that the rates of suspension for Black students in 

D.C. charter schools were about six times higher than the rates for White 

students and the rates for students with disabilities were almost double 

the rates for students without disabilities, as shown in figure 6. In addition, 

male students in D.C. charter schools had suspension rates that were 

approximately 65 percent higher and expulsion rates that were two times 

higher than female students (not shown). The pattern of higher rates of 

discipline for Black students, students with disabilities (as shown in fig. 7), 

and male students (not shown) also occurred in D.C. traditional public 

schools, as well as charter and traditional public schools nationally. 

Further, our regression model found an association between some 

student characteristics and a higher incidence of suspensions.

Specifically, schools that served upper grades (grade 6 and up), or 

served higher percentages of Black students or English Learners were 

associated with higher rates of suspensions. This effect existed for both 

types of public schools in D.C. but was larger for traditional public schools 

than charter schools. (See app. I for a full discussion of the regression 

analysis and app. II for the results.)
Page 19 GAO-17-165 Oversight of D.C. Charter Schools

Figure 6: Black Students and Students with Disabilities Had the Highest 

Suspension and Expulsion Rates in District of Columbia Charter Schools, School 

Year 2013-14
Page 20 GAO-17-165 Oversight of D.C. Charter Schools

Figure 7: Suspension Rates for Black Students and Students with Disabilities Are Higher Compared to Other Student Groups 

in District of Columbia (D.C.) Charter and Traditional Public Schools and Nationally, School Year 2013-14

When we looked at suspensions and expulsions for individual D.C. 

charter schools for school year 2015-16, we found wide variation in rates. 

In particular, 16 of the 105 D.C. charter schools suspended 20 percent or 

more of their students, with 5 schools suspending 30 percent or more of 

their students over the course of that school year.39 With respect to 

expulsions, 6 charter schools expelled more than 1 percent of their 

students, and these 6 schools accounted for over half of all charter school 

expulsions. (See fig. 8; see app. VII for a full list of D.C. charter schools 

and their school year 2015-16 discipline rates.) The schools with the 

highest suspension rates tended to serve middle school students (grades 

5-8), while the schools with the highest expulsion rates varied in the 

grades they served.

 39 This analysis, based on PCSB’s data, excludes the 9 charter schools that served adults 

or that were exclusively online in 2015-16.
Page 21 GAO-17-165 Oversight of D.C. Charter Schools

Figure 8: Suspension and Expulsion Rates Are Distributed Unevenly across 105 District of Columbia Charter Schools, School 

Year 2015-16

Note: This analysis excludes the 9 charter schools that served adults or that w ere exclusively online 

in 2015-16.

PCSB officials said that the D.C. charter schools with the highest rates 

either served high percentages of at-risk students or had strict discipline 

policies. According to these officials, some of these charter schools serve 

a high percentage of students with risk factors associated with behavioral 

problems—such as being formerly incarcerated or expelled—and these 

schools may struggle to manage their behavior while maintaining a safe 

school environment. One charter school we visited fell into this category 

and officials told us that their rates were high because they served many 

students who had been encouraged to leave their previous schools 

because of bad behavior. In addition, charter school officials in all three 

schools we visited said that managing the behavioral issues of some 

students with disabilities was one of the key discipline challenges they 
Page 22 GAO-17-165 Oversight of D.C. Charter Schools

faced. Officials at these schools also said that many of their students 

have experienced trauma, which can manifest as behavior issues in the 

classroom. All of these schools had hired or planned to hire more mental 

health experts to better address these issues. However, officials at two 

schools said they have had challenges obtaining additional mental health 

resources and added that their staff could benefit from further training on 

working with traumatized students.

With respect to school discipline policies, PCSB officials also said that 

many of the schools with high discipline rates are part of networks with 

reputations for strict policies. For example, they said that one network 

started with a “no excuses” discipline philosophy that encouraged 

punishment for minor offenses, although their approach to discipline is 

now changing. PCSB officials described another network that runs D.C. 

charter schools with high suspension rates as having an “elaborate”

behavior management system, which uses 1-day suspensions as an 

anchor of their discipline system. The network does not see their high 

suspension rate as a problem because their policy does not keep 

students out of school for a long time, and, according to school officials, 

helps correct student behavior. PCSB officials said they conducted an 

analysis which found no correlation between 1-day suspensions and 

withdrawal rates. However, several other stakeholders we interviewed 

told us that some parents have withdrawn their children from so-called 

“no excuses” charter schools out of frustration because of the multiple 

suspensions their child received. Further, the Ombudsman for Public 

Education said that her office had heard from some charter school 

parents who were frustrated with such discipline practices, but felt they 

had no option but to keep their child at the school for the remainder of the 

school year because the school lottery had closed.

According to officials we interviewed, charter schools have made a 

concerted effort to reduce discipline incidents but continue to face 

challenges. According to PCSB and other stakeholders, most D.C. 

charter schools have been motivated to address discipline issues in their 

schools. At the three charter schools we visited, all of the officials said 

they took steps to reduce their suspension rates and create a more 

positive environment to reduce behavior problems. For example, one 

charter school official described an approach that incorporates empathy 

and problem solving skills to address discipline, while keeping the student 

in school. This school is part of an OSSE pilot program in which five D.C. 

traditional public and charter schools receive on-site technical assistance 

to implement such practices. An official at a second charter school said 

Efforts to Reduce 

Discipline Rates Have Met 

with Some Success, but 

Charter Schools We 

Visited Continue to Face 

Challenges
Page 23 GAO-17-165 Oversight of D.C. Charter Schools

that they were using interventions and supports that emphasize positive 

behaviors to reduce incidences of discipline.40 (See text box.) An official 

from the third school said that they have implemented an alternative to inschool suspensions when a student is disruptive, giving the student an 

opportunity to reflect and continue classwork in a separate environment.41

D.C. data for school year 2015-16 showed that discipline rates in these 

three schools had declined from 2014-15, although suspension rates at 

all three remained above the public charter school average, with one 

school’s suspension rate remaining above 30 percent.42

Alternatives to Exclusionary Discipline

Restorative Justice Practices: An alternative disciplinary approach which uses non-punitive disciplinary 

responses that focus on repairing harm done to relationships and people. The aim is to teach students 

empathy and problem solving skills that can help prevent the occurrence of inappropriate behavior in the 

future. For example, officials at one school we interviewed described asking a student who stole a laptop to 

“restore” his community by writing a reflection paper, as well as attend Saturday school, instead of being 

suspended.

Positive Behavior Intervention and Supports: A schoolwide framework, which focuses on positive behavioral 

expectations. By teaching students what to do instead of what not to do, the school can focus on the preferred 

behaviors. At one school implementing this practice, officials told us they instruct teachers to note three 

positive behaviors for every negative behavior, for each student.

Source: U.S. Department of Education guidance. | GAO-17-165

Note: Education’s Guiding Principles: A Resource Guide for Improving School Climate and Discipline 

and Positive Behavior Intervention and Supports w ebsite hosted by Education’s Office of Special 

Education Programs at http://www.pbis.org. 

School officials told us that implementing changes to their discipline 

practices and creating a more positive environment is time and resource 

intensive and that full implementation would take several years. In 

implementing these changes, schools officials told us they faced 

resistance from both staff and parents. Some teachers may not fully 

adhere to these new practices, finding it easier to remove students from 

 

40 These strategies for reducing harsh discipline practices in schools are identified as 

leading practices by Education, Justice, and the Department of Health and Human 

Services. 

41 The in-school suspension rate for D.C. charter schools as a group went up between 

2011-12 and 2013-14, from 4.0 percent to 5.3 percent, according to Education’s data.

42 The decrease in these schools’ suspension rates from school year 2014-15 to 2015-16 

ranged from 6 to 14 percentage points, and the decrease in their expulsion rates ranged 

from less than 1 to nearly 2 percentage points.
Page 24 GAO-17-165 Oversight of D.C. Charter Schools

class when they are misbehaving, according to charter school officials. 

Officials at two schools said they had recently hired new principals to 

more effectively implement their new discipline philosophies, and all three 

of the schools had hired more staff to focus on school climate issues. In 

addition, school officials told us that some parents protested the changes, 

preferring a strict discipline culture that they perceive as keeping their 

children safe.

PCSB has increased its focus on school discipline in recent years and 

uses several mechanisms to oversee charter schools’ use of suspensions 

and expulsions (see fig. 9).

PCSB and Other D.C. 

Agencies Oversee 

Charter Schools, but 

Have Not Created a 

Coordinated Plan to 

Help Schools 

Continue to Bring 

Down Discipline 

Rates

PCSB Collects and 

Publishes Discipline Data 

by School and Alerts 

Schools of Concerns
Page 25 GAO-17-165 Oversight of D.C. Charter Schools

Figure 9: PCSB Discipline Monitoring Mechanisms

Specifically, PCSB officials said that in 2012, PCSB began reviewing 

discipline data it collected from each charter school on a monthly basis. 

They told us they use the data to focus schools’ attention on suspension 

and expulsion rates and encourage schools to address high rates. In 

these monthly reviews, PCSB officials said they examine year-to-date 

suspension and expulsion rate averages, including averages by grade 

band (pre-K, elementary, etc.), and also identify outlier schools that have 

the highest suspension and expulsion rates, highest number of days 

students were suspended, and highest suspension rates for students with 

disabilities.43 PCSB officials said they communicate with schools regularly 

about the patterns they see in their discipline data and that they request 

meetings with charter school officials of outlier charter schools to discuss 

their schools’ rates and how they compare to other charter schools. 

 43 PCSB also reported examining data on mid-year withdrawals, attendance, and truancy 

as part of these reviews.
Page 26 GAO-17-165 Oversight of D.C. Charter Schools

PCSB officials told us they use this approach because charter school 

officials will usually choose to make changes when they are provided with 

this information. Officials from the three schools we interviewed said that 

PCSB has generally been active in sharing information and data, 

highlighting issues, and encouraging schools to reduce suspension and 

expulsion rates. Further, PCSB has offered training and professional 

development opportunities to charter school officials on topics related to 

school discipline, including conferences on classroom management and 

multiple quarterly meetings for school officials devoted to the topic.

PCSB and OSSE work together to annually publish discipline data by 

school in Equity Reports, which are reports that PCSB officials said drive 

schools to lower their suspension and expulsion rates. The Equity 

Reports are also meant to provide school leadership, school boards, 

families, and the community with information that will allow them to 

compare data on both charter schools and traditional public schools in 

D.C.44 See figure 10 for an excerpt from one charter school’s 2014-15 

Equity Report.

 44 Equity Reports can be found at http://osse.dc.gov/equity-reports.
Page 27 GAO-17-165 Oversight of D.C. Charter Schools

Figure 10: Excerpt from One Public Charter School’s Equity Report for School Year 2014-15

PCSB officials told us that they also review schools’ discipline policies 

during the charter application and renewal processes. These officials said 

that they use the application process to shape new charter schools’

discipline policies. According to PCSB officials and application guidance, 

PCSB is unlikely to approve an application whose discipline policy will 

result in frequent removal of students from the school (see text box). 

PCSB officials said that this process is their opportunity to ensure that 
Page 28 GAO-17-165 Oversight of D.C. Charter Schools

charter school policies limit the use of suspensions and expulsions. For 

example, in a May 2015 letter explaining the reasons for denying a new 

charter school application, PCSB noted that the “demanding behavioral 

program may result in high percentages of students being suspended or 

expelled and the founding team has not developed realistic supports to 

meet the needs of all learners. When asked about how the school will 

support students who struggle with strict behavior expectations, the 

founding group...did not provide a cohesive and deliberate approach.”

Excerpts from PCSB Policy Documents

“Discipline plans that provide for expulsion for minor offenses such as 

possession of tobacco or insubordination will not be approved.” –PCSB 

Discipline Plan Policy

“PCSB is unlikely to approve applications for schools with discipline 

policies that rely on school exclusion to manage student behavior and/or 

that are likely to result in high rates of suspensions and expulsions.” 

–PCSB 2016 Charter Application Guidelines

“PCSB expects that schools will only expel students for federallyrecognized reasons.”a –PCSB 2016 Charter Application Guidelines

Source: Public Charter School Board (PCSB) policy and guidance. | GAO-17-165

a

According to PCSB officials, federally-recognized reasons include drug and alcohol incidents, 

w eapons possession, and violent acts.

With respect to charter renewals, which occur every 15 years, PCSB 

officials said that recently they have begun to use this process to, among 

other things, renegotiate parts of schools’ discipline policies. Officials said 

that if PCSB and the charter school board fail to reach agreement, the 

school’s funding will cease, which according to PCSB officials provides a 

strong incentive for charter schools to comply.45

In addition, PCSB conducts higher-level reviews of schools’ discipline 

policies on an annual basis. Officials told us that these reviews are meant 

to confirm that schools’ discipline policies include three key elements: due 

process and appeals procedures, clearly outlined reasons for 

suspensions and expulsions, and adherence to federal protections for 

 45 PCSB officials told us that Board members typically vote on charter renewals during the 

school year. After the Board has approved a charter renewal typically in the spring, they 

will begin to work with the school on a new charter agreement. PCSB generally begins 

making payments to schools on July 15 each year. According to PCSB officials, schools 

without a signed charter agreement in place are not eligible to receive payments.
Page 29 GAO-17-165 Oversight of D.C. Charter Schools

students with disabilities in the discipline process. (See text box below for 

the full list of discipline policy elements PCSB requires of charter 

schools.) If a school’s policy does not include one or more of these 

elements, PCSB officials said they will give the school 2 weeks to revise 

the policy and, if the school fails to fix the issue, PCSB will send a “notice 

of concern”— a formal, written notification alerting a school of issues that 

need to be addressed. If the school still fails to fix the issue, PCSB will 

send a charter warning letter indicating that the charter could be subject 

to revocation. PCSB officials told us they have never had to send a 

warning letter for issues related to discipline policies.

Required Elements of Charter School Discipline Policies

• Parent, student, and staff rights and responsibilities;

• Clear explanation of infractions, what specific acts are not tolerated in 

the school, tiered consequences and interventions, and a clearly 

outlined basis for suspensions and expulsions;

• Due process and appeals procedures;

• Provisions to ensure that all rules are enforceable and applied 

consistently by all staff; and

• All Individuals with Disabilities Education Act (IDEA) guidelines and 

requirements, which concern services for students with disabilities.

Source: Public Charter School Board Discipline Plans Policy. | GAO-17-165

Finally, PCSB also monitors parent and stakeholder complaints. PCSB 

officials told us that if they notice a trend or pattern in these complaints 

they will follow up with schools. They said that they have never had a 

pattern of complaints against a school related to suspensions or 

expulsions.46

 46 PCSB’s Community Complaint Policy is available for download at 

http://www.dcpcsb.org/policy/community-parent-engagement/community-complaint-policy. 

The website includes the following description of PCSB’s role with regard to complaints: 

“When a parent or community member reaches out to the D.C. Public Charter School 

Board (“PCSB”) with a complaint against a school, the primary goal is to ensure that the 

school has (a) followed its complaint process in order to address the parent’s concern 

(See D.C. Code § 38- 1802.04(c)(13)); (b) is in compliance with its charter and charter 

agreement; and (c) has not violated any applicable laws.”
Page 30 GAO-17-165 Oversight of D.C. Charter Schools

While other D.C. education agencies also have oversight responsibility 

with respect to charter schools (see fig. 2), plans to further bring down 

discipline rates have been hampered by agencies’ lack of consensus 

regarding roles and responsibilities, and by one agency’s stated lack of 

clarity around its own authority. In interviews, the Deputy Mayor for 

Education (DME), OSSE, and PCSB officials described different views

regarding agency roles in overseeing charter schools and providing 

guidance and training. In particular, officials described differing views on 

the appropriate scope of PCSB’s role with respect to charter schools. For 

example, the DME—whose role is to oversee District-wide education 

strategy—said that PCSB could issue further guidance on certain 

discipline-related topics and place additional requirements on schools. In 

contrast, officials from PCSB—the entity charged with overseeing charter 

schools—told us that providing additional or more specific guidance 

would be inconsistent with their role as authorizer. PCSB officials said 

that they interpret certain provisions of the School Reform Act as 

providing “a strong legal bulwark against the District government, 

including [PCSB itself], mandating school disciplinary processes,” thereby 

limiting the actions that D.C. agencies, including PCSB, may take.47 In 

addition, officials from these three agencies differed in their views 

regarding charter schools’ needs with respect to discipline, including 

whether charter schools needed additional guidance on due process 

procedures, training, or other resources.

Further, OSSE officials said that the agency’s current view of its authority 

to regulate charter schools on discipline differs from previous 

administrations’ interests in that area, and that they still lacked clarity on 

their authority in some areas. Specifically, in a 2014 report, OSSE—the 

agency with general oversight of federal education funding 

requirements—stated its intent to issue regulations applying to both D.C. 

traditional public and charter schools that would address high discipline 

rates.48 In the report, OSSE said that this effort would address potential 

discipline disparities across D.C. charter and traditional public schools 

and help ensure that all public school students in the District are treated 

fairly. However, OSSE never issued the regulations, and OSSE officials 

told us in 2016 that, in contrast with previous administrations’ interests, 

 

47 In particular, PCSB officials cited D.C. Code §§ 38-1802.02(10), 38-1802.04(c)(3)(A), 

and 38-1802.04(c)(3)(B). 

48 District of Columbia, Office of the State Superintendent of Education, Reducing Out-ofSchool Suspensions and Expulsions in District of Columbia Public and Public Charter 

Schools, 2014.

Several D.C. Agencies 

Oversee Charter Schools 

but We Observed a Lack 

of Consensus around

Roles, Responsibilities, 

and a Key Agency’s 

Authority
Page 31 GAO-17-165 Oversight of D.C. Charter Schools

the current administration does not interpret the School Reform Act as 

providing them with clear authority to issue such regulations. OSSE 

officials also stated that the complexity of the D.C. regulatory framework, 

combined with the fact that some regulations were promulgated prior to 

the creation of D.C. charter schools, resulted in a lack of clarity around 

their oversight authority over charter schools in some areas. OSSE did, 

however, issue non-regulatory guidance in June 2016, which provides 

high-level descriptions of federal and D.C. laws relating to school 

discipline and cites some leading practices. It is unclear whether this 

guidance will lead to any changes in charter schools’ discipline rates. 

Subsequent to releasing this guidance, OSSE released a new report in 

2016, concluding that further progress is still needed on discipline policy, 

implementation, and disproportionality across all D.C. public schools.

Despite these challenges, officials from these three agencies and D.C. 

traditional public schools have collaborated together on a key effort to 

address discipline rates by publishing the Equity Reports for each charter 

and traditional public school in the District. In addition, officials told us that 

the other key D.C. education agencies reviewed OSSE’s draft nonregulatory guidance on discipline, and that officials from these agencies 

also work together along with officials from other D.C. agencies that 

support families and young people through regular meetings convened by 

the DME. OSSE and PCSB officials said that they also promote and 

support each other’s training programs on classroom management and 

discipline. Further, they work together on education-related issues as 

participants on a number of city-wide task forces and other collaborative 

efforts. However, while some of those task forces focus on issues related 

to discipline, such as bullying or truancy, none specifically address 

discipline rates or disparities in a comprehensive manner.

Leading practices on interagency collaboration state that to achieve a 

common outcome, agencies should agree on roles and responsibilities 

and create mutually reinforcing or joint strategies that align the agencies’

activities, processes, and resources.49 Similarly, standards for internal 

control state that to achieve an entity’s objectives management should 

 49 GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms,GAO-12-1022 (Washington, D.C.: Sept. 27, 2012); and 

Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
Page 32 GAO-17-165 Oversight of D.C. Charter Schools

establish an organizational structure and assign responsibilities.50 The 

agencies differing views on roles and responsibilities, and OSSE’s stated 

lack of clarity on its authority around the issue of discipline in charter

schools makes it difficult for them to leverage resources and the collective 

expertise of other agencies in the District to develop plans and strategies 

to address D.C.’s high discipline rates. Absent such a plan, as well as 

explicitly stated roles and responsibilities, charter schools may face 

challenges in continuing to bringing down rates.

PCSB and the District’s charter schools have made notable progress in 

bringing down discipline rates in recent years. However, rates remain 

troublingly high, at twice the national rate for school year 2013-14—the 

most recent year for which nationally comparable data are available—and 

particularly for certain schools and for Black students and students with 

disabilities. PCSB has taken steps to address this issue by using schoollevel discipline data to focus schools’ attention on reducing reliance on 

those practices that remove students from school. However, some 

schools are removing students from school for partial or even full school 

days without fully reflecting these actions in the discipline data or 

consistently documenting them. As a result, PCSB does not have a clear 

sense of how widely these practices are used or what strategies might 

help it best address the problem.

PCSB, the DME, and OSSE all play key roles in charter school oversight. 

While these agencies communicate regularly and have worked together 

in a number of areas, including making data on school discipline across 

all District schools more available through the Equity Reports, we 

observed a lack of consensus around their roles and responsibilities, and 

OSSE’s view of its authority to regulate charter schools on discipline 

differs from previous administrations’ interests in that area. This has 

contributed to inertia around creating and implementing a coordinated 

plan that could help further address high discipline rates. Absent such a 

plan, continued progress in bringing down discipline rates may be slowed.

 

50 GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sept. 2014).

Conclusions
Page 33 GAO-17-165 Oversight of D.C. Charter Schools

1. PCSB should further explore ways to more accurately measure 

behavior-related time out of school—both partial and full day 

removals—not captured under current reporting procedures.

2. The D.C. Mayor should direct the DME and OSSE to deepen 

collaboration with PCSB and other relevant stakeholders, such as 

charter school LEAs, to develop a coordinated plan to continue 

progress in reducing discipline rates and, as part of this process, 

make explicit their respective roles, responsibilities, and authorities 

with regard to discipline in D.C. charter schools. This plan could 

include developing additional guidance, training, or resources, 

consistent with the unique autonomy of charter schools.

We provided a draft of this report to PCSB, the D.C. Mayor’s Office, and 

Education for review and comment. PCSB’s written comments, which 

also include technical comments, are reproduced in appendix VIII. OSSE 

provided written comments on behalf of the D.C. Mayor’s Office, which 

are reproduced in appendix IX. Education and the D.C. State Board of 

Education provided technical comments on the report. In each case, we 

incorporated their comments into the report, as appropriate.

In its written comments, PCSB said that by not focusing our analysis on 

D.C. data, we reached inaccurate conclusions. Specifically, it stated that 

by focusing on CRDC data, which are most recently available for school 

years 2011-12 and 2013-14, the report failed to acknowledge the more 

recent reductions in D.C. charter schools’ suspension and expulsion rates 

shown in D.C.’s own data for school years 2014-15 and 2015-16. PCSB 

also commented on our analysis that used CRDC data to make 

comparisons between D.C. charter school rates to those of charter 

schools nationally. These data showed that suspension rates at D.C 

charter schools were double the national rates for school years 2011-12 

and 2013-14. In its comments PCSB presented a table with its own data 

for all 4 of these school years and stated that its data show that D.C. 

charter schools’ discipline rates have moved closer to national rates. 

PCSB asked that our report prominently incorporate D.C.’s 2014-15 and 

2015-16 data throughout.

As stated in our draft report, the most recent available PCSB data at the 

time we did our work was for school year 2014-15, which we presented in 

selected analyses where appropriate throughout the draft report. We have 

updated these analyses with PCSB’s recently available 2015-16 data. 

PCSB’s 2015-16 data continue to show modest declines in D.C. charter 

school discipline rates, compared to previous years of PCSB data. 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 34 GAO-17-165 Oversight of D.C. Charter Schools

However, as stated in our draft report, PCSB’s data are not comparable 

to other states’ data collected by CRDC. Further, because school year 

2013-14 is the most recent year for which national comparable CRDC 

data are available, it is not possible to know whether D.C. charter school 

rates have moved closer to national rates, which may have also changed 

since 2013-14. 

PCSB agreed that D.C. charter schools’ discipline rates remain higher 

than PCSB would like, and that they remain disproportionate with respect 

to race and disability status. PCSB also stated that steady progress seen 

in D.C. charter schools is the right way to reduce discipline. We applaud 

PCSB’s efforts in steadily bringing down rates, as noted in the draft 

report, and continue to believe that a coordinated multi-agency plan is 

needed to continue this progress. 

In addition, PCSB said in its comments that our draft report failed to 

acknowledge the autonomy granted to D.C. charter schools under the 

School Reform Act, which it interprets as preventing any D.C. agency 

from mandating charter school disciplinary processes. We believe that the 

report clearly states that each charter LEA has the autonomy to establish 

its own discipline policies and suspend and expel students, and that 

unlike D.C. traditional public schools, charter LEAs are not subject to the 

discipline policies and procedures in D.C. municipal regulations. 

However, as also stated in the draft report, PCSB exercised its authority 

by putting some requirements and oversight mechanisms in place for 

charter schools, including regularly reviewing charter schools’ discipline 

data and policies. Moreover, Education’s recent guidance highlights its 

expectation that charter school authorizers ensure that the schools they 

authorize comply with federal and state laws, including those pertaining to 

the discipline of students with disabilities.

PCSB did not comment on our first recommendation (that PCSB further 

explore ways to more accurately measure behavior-related time out of 

school—both partial and full day removals—not captured under current 

reporting procedures). However, PCSB said that a related statement in 

the report—that it has no official policy on partial day removals of 

students for disciplinary reasons—was erroneous. We have removed this 

statement in the final report. 

PCSB and OSSE both disagreed with our characterization of their 

collaboration around charter school discipline, but both indicated that they 

look forward to deepening their collaboration to continue progress made 

in reducing discipline rates. We have added additional information to our 
Page 35 GAO-17-165 Oversight of D.C. Charter Schools

report to more fully reflect new information both entities provided in their 

comments regarding the level of collaboration between these two entities. 

Finally, OSSE, in commenting on the report, agreed that there is some 

ambiguity around its authority with respect to D.C. charter schools. 

Specifically, OSSE stated that the complex D.C. regulatory framework is 

unclear regarding oversight authority in some instances. As such, the 

agency’s current view of its authority to regulate charter schools on 

discipline differs from previous administrations’ interests in that area. 

Specifically, OSSE stated that its current conclusion is that the D.C. code 

does not provide OSSE clear authority to regulate charter schools with 

respect to discipline. Such views about D.C.’s regulatory framework are 

an example of the importance of clarifying agency roles and 

responsibilities with respect to D.C. charter school discipline. 

In light of PCSB’s and OSSE’s comments around collaboration and their 

respective authorities around discipline, we modified our second 

recommendation slightly. We now specify that these agencies should 

deepen their collaboration in order to continue progress in reducing

discipline rates, and that in doing so they should make explicit their 

respective oversight authorities, in addition to roles and responsibilities. 

We also specify that the multi-agency plan to continue progress reducing 

discipline rates should be consistent with the unique autonomy of charter 

schools.

We are sending copies of this report to the D.C. Mayor, the Chairman and 

Executive Director of the Public Charter School Board, and the U.S. 

Secretary of Education. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov.
Page 36 GAO-17-165 Oversight of D.C. Charter Schools

If you or your staff should have any questions about this report, please 

contact me at 617-788-0580 or nowickij@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix X.

Jacqueline M. Nowicki

Director, Education, Workforce,

 and Income Security Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-17-165 Oversight of D.C. Charter Schools

The objectives of this study were to examine: (1) what is known about 

suspensions and expulsions in District of Columbia (D.C. or District) 

charter schools, and (2) to what extent the Public Charter School Board 

(PCSB) oversees the use of suspensions and expulsions at charter 

schools. To address these objectives, we used a variety of methods, 

including analyzing federal and D.C. data; reviewing published reports 

and monitoring documentation from PCSB and other D.C. agencies; and 

interviewing officials from these agencies, representatives from 

associations and advocacy groups, and officials from three charter 

schools.

To determine the out-of-school suspension and expulsion rates at charter 

and traditional public schools, both in D.C. and nationally, we analyzed 

federal data from the U.S. Department of Education’s (Education) Civil 

Rights Data Collection (CDRC) for school years 2011-12 and 2013-14, 

the 2 most recent years available. The CRDC is a comprehensive source 

of data on suspensions and expulsions that collects comparable data 

across the nation’s public school districts, schools, and students. As such, 

we used the CRDC to make comparisons between D.C. charter schools, 

D.C. traditional public schools, and traditional and charter schools 

nationally. PCSB also collects information on suspensions and expulsions 

in D.C. charter schools, but these data are not comparable to CRDC data 

on schools and students in other states. At the time we did our work 

PCSB had data that were more recent than data available through the 

CRDC (school year 2014-15 for PCSB versus 2013-14 for CRDC). We 

therefore chose to present PCSB’s data in selected analyses in the 

report, while also being careful not to make comparisons between the 

PCSB and CRDC data. In its written comments on a draft of this report, 

PCSB noted the recent availability of data for the 2015-16 school year. 

We updated our analyses accordingly to provide the most current picture 

of D.C. charter school discipline rates. Doing so did not materially change 

the findings in this report.

The Civil Rights Data Collection is a biennial survey that is mandatory for 

every school and district in the United States. Conducted by Education’s 

Office for Civil Rights, the survey collects data on the nation’s public 

schools, including student characteristics and enrollment; educational and 

course offerings; disciplinary actions; and school environment, such as 

Appendix I: Objectives, Scope, and 

Methodology

Data Analysis

Analysis of Federal Civil Rights 

Data Collection
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-17-165 Oversight of D.C. Charter Schools

incidences of bullying.1 From school years 2000 through 2010, the CRDC 

collected data from a representative sample of schools, but in school 

years 2011-12 and 2013-14, the CRDC collected data from every public 

school in the nation (approximately 17,000 school districts, 96,000 

schools, and 50 million students in school year 2013-14). The dataset 

includes traditional public schools (pre-K through 12th grade), alternative 

schools, magnet schools, and charter schools.

For school years 2011-12 and 2013-14, the most recent years of data 

available, we calculated aggregate discipline rates. To determine the 

extent to which discipline rates varied by student demographic groups 

and school type, we calculated aggregate discipline rates by student 

demographics and for all charter and traditional public schools in D.C. 

Further, we calculated discipline rates for each school in D.C.—both 

charter and traditional—to determine the extent of variation in rates by 

school and school type. We also compared the aggregate rates in D.C. 

charter and traditional public schools to rates for charter and traditional 

public schools nationally.

We analyzed the following discipline and demographic variables:

• Total out-of-school suspensions, calculated by combining the CRDC 

variables:2

• Students receiving only one out-of-school suspension

• Students receiving more than one out-of-school suspension

• Total expulsions, calculated by combining the CRDC variables:

• Expulsions with educational services

• Expulsions without educational services

The CRDC has seven race and ethnicity variables, which we combined 

into five categories, as shown in table 1.

 1 Section 203(c)(1) of the Department of Education Organization Act (Pub. L. No. 96-88 

(1979)) authorizes the Assistant Secretary for Civil Rights in the Department of Education 

“to collect or coordinate the collection of data necessary to ensure compliance with civil 

rights laws within the jurisdiction of the Office for Civil Rights [OCR].” OCR has been 

collecting this data since 1968.

2 We also examined students receiving one or more in-school suspensions, separately. 
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-17-165 Oversight of D.C. Charter Schools

Table 1: Race and Ethnicity Variables Used in Analysis of Civil Rights Data 

Collection (CRDC)

GAO category CRDC category

Black Black

Hispanic Hispanic

White White

Asian Asian

Native Hawaiian / Other Pacific Islander

Other American Indian/Alaska Native

Two or more races

Source: GAO analysis. | GAO-17-165

We also analyzed rates for students identified as English Learners and 

students with a disability. Our analysis of students with disabilities 

included only those students served under the Individuals with Disabilities 

Education Act. We excluded Section 504 students because the CRDC 

does not collect discipline data for Section 504 broken out by race and 

ethnicity.3 In school year 2013-14, students only receiving services under 

Section 504 represented 8 percent of public school students with 

disabilities in D.C.

To analyze the poverty levels of schools with different suspension and 

expulsion rates, we matched schools in both years of the CRDC with data 

on free or reduced-price lunch (FRPL) eligibility from the Common Core 

of Data, which is administered by Education’s National Center for 

Education Statistics, and which annually collects non-fiscal data about all 

public schools in the nation. These data are supplied by state education 

agency officials for their schools and school districts. However, we 

determined that the school year 2013-14 FRPL data for D.C. were not 

sufficiently reliable for our purposes. These FRPL data differed 

dramatically from the school year 2011-12 data and when we asked 

officials from the Office of the State Superintendent of Education (OSSE), 

the state educational agency responsible for reporting these data, to 

corroborate these data, they reported having no confidence in the data 

they had reported. Therefore, we did not use this FRPL data in any of our 

analyses.

 3 Section 504 of the Rehabilitation Act of 1973, as amended, is a civil rights statute which 

prohibits discrimination on the basis of disability in any program or activity receiving 

federal financial assistance. 29 U.S.C. § 794.
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-17-165 Oversight of D.C. Charter Schools

To assess the reliability of the federal data used in this report, we 

reviewed technical documentation about the survey and dataset and 

interviewed officials from Education’s Office for Civil Rights about their 

procedures for checking the data. We also conducted electronic testing 

and logic checks of our analysis. Based on these efforts, we determined 

that the CRDC data were sufficiently reliable for our purposes. We used 

the version of the 2013-14 CRDC data that was publicly available as of 

September 30, 2016 because it corrected errors in the original data 

previously submitted by Florida.

We also analyzed the data using a generalized linear regression model to 

determine (1) whether and the extent to which certain school level 

characteristics are associated with a higher incidence of suspensions and 

(2) whether and the extent to which an association exists between high 

incidences of suspension and school type in the District (charter schools 

versus traditional public schools).4 For our regression model, we used the 

CRDC for school year 2013-14, limiting our analysis to suspensions 

because expulsions are a rare event and therefore difficult to model.5 We 

included demographic variables in our model that Education’s Office for

Civil Rights has identified as key drivers of suspension. We used these 

variables in our model as follows:

• Outcome: number of students with one or more out-of-school 

suspensions

• Independent variable: Charter school status (Yes/No)

• Adjustment variables: Percent of student population that is male, 

Black, students with disabilities, and English Learners; whether school 

offers upper grades (grades 6 and above) (Yes/No)

 4 A negative binomial regression was used instead of a Poisson regression, since 

negative binomial models are appropriate for count analyses with observed overdispersion – that is, when the variance of the count variable is much larger than the mean 

of that variable (see Generalized Linear Models, 2nd Edition, by McCullagh and Nelder, pp. 

198-199, for example).

5 Although the data are available for the full population and not based on a statistical 

sample, they can be thought of as realizations generated from an underlying process of 

interest: out of school suspensions for different school types (charter versus traditional), 

within the District. Such an approach is sensible if the phenomenon has more than a onetime interest, beyond what happened in the one specific year in these specific schools, 

with these specific students. By assuming these data are one realization from an 

underlying super-population of schools, generated by a process, we use statistical tests to 

determine whether any observed association is beyond what would be expected by 

chance alone.

Regression Analysis
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-17-165 Oversight of D.C. Charter Schools

Some variables that were thought to be important were not included in 

our model due to estimation or reliability issues. Specifically, we 

excluded:

• FRPL in school year 2013-14, due to reliability issues as indicated by 

OSSE, the agency responsible for reporting the data;

• percent of students within a school who are Hispanic, due to 

collinearity with English Learners; and

• alternative school designation, due to lack of variability and 

sparseness in data.

We used the number of students enrolled as an exposure variable to 

account for different school sizes. Our analysis included K-12 schools. 

We excluded pre-Kindergarten (pre-K) schools because pre-K 

suspensions are rare and reported differently in the data. This resulted in 

dropping 8 schools that offered only pre-K. Additionally, for schools that 

offered both pre-K and later grades we excluded out-of-school 

suspension and student counts for pre-K students. We also excluded 5 

magnet schools because they are too dissimilar to the other schools in 

our model, since students are admitted to such schools based on the 

merits of their application. With these schools excluded, the 2013-14 

CRDC data resulted in 191 D.C. Public Schools in our analysis file, where 

105 were traditional and 86 were charter.6

All models are subject to limitations. For this model, the limitations 

included:

• The data we analyzed are at the school level, rather than student 

level. Ideally, data would be analyzed at the student level in order to 

describe the association between a charter versus traditional public 

school student’s suspension rate, controlling for characteristics of the 

individual students suspended, such as gender, race/ethnicity, and 

grade level. Instead, the school-level nature of the CRDC data limited 

what we could ascribe to the association between these schools’

suspension incidence, controlling for the characteristics of the entire 

 6 The number of D.C. charter schools included in our regression analysis differs from the 

102 D.C. charter schools shown in figure 8 for several reasons. First, figure 8 shows 

PCSB data, while our regression used the CRDC data. Second, figure 8 shows data from 

school year 2014-15, while the regression data are from school year 2013-14. Finally, 

figure 8 includes some schools that serve only pre-K students, while we excluded such 

schools from our regression analysis.
Appendix I:Objectives, Scope, and 

Methodology

Page 42 GAO-17-165 Oversight of D.C. Charter Schools

school’s population, such as percent of students who are male, Black, 

etc.

• Some variables that may be related to out-of-school suspensions are 

not available in the data. For example, in this context, it could be that 

parent education or household type (single- versus multiple-headed 

household) could be related to student behavior, such as those that 

lead to out-of-school suspensions.

• These data were not gathered through a randomized control trial in 

which students would be randomized to attend either a traditional or a 

charter school. Although there is some randomness inherent in the 

lottery for oversubscribed charter schools, this is not systematic and, 

for students who were offered the option to attend charter schools, the 

students’ families decide whether to accept or not.

Typically, a generalized linear regression model provides an estimated 

incidence rate ratio, where a value greater than 1 indicates a higher or 

positive association, in this case, between suspensions and the variable 

of interest, such as being a charter school or having a higher percentage 

of Black students.7 An estimated incidence rate ratio less than 1 indicates 

a lower incidence of suspensions when a factor is present. Given the 

limitations of our model as described above, in appendix II we present a 

general summary of association by providing the direction, rather than an 

estimated rate (incidence) of suspensions of charter versus traditional 

public schools in the District.

To analyze more recent data on D.C. charter schools, we obtained 

aggregate data from PCSB for school years 2012-13 through 2015-16. In 

addition, we obtained more detailed school-level data on charter school 

suspensions and expulsions from PCSB for school years 2013-14, 2014-

15, and 2015-16 which are part of data that the District collects annually 

on both charter schools and traditional public schools. The data included 

published reports on discipline from PCSB, and Equity Reports for each 

school. Equity Reports contain data on:

• total enrollment;

 7 We use statistical tests that account for the possibility of observing an incidence rate 

ratio different than 1, when in fact the null hypothesis of no association (incidence rate 

equal to 1) is really true. The level of significance is a measure of type I error and is the 

probability of rejecting the null hypothesis when the null hypothesis is true. Unless 

otherwise noted, we use the 95 percent level of confidence to test whether estimates from 

our model differ from 1 at a statistically significant level (i.e., there is an association).

Analysis of D.C. Data
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-17-165 Oversight of D.C. Charter Schools

• grade level;

• demographics;

• economic disadvantage;8

• Limited English Proficiency;9

• special education;

• suspension rate by student subgroup; and

• overall expulsion rate.

In addition, we obtained published reports on discipline, as well as data 

from OSSE on the numbers of students transferred to an alternate school 

for students who received long-term suspensions and expulsions in 

school year 2014-15.

To assess the reliability of the D.C. data, we reviewed documentation, 

interviewed relevant officials from PCSB and OSSE, and conducted logic 

checks. Based on these efforts, we determined that these data were 

sufficiently reliable for our purposes. D.C.’s data however, are not 

comparable to Education’s data because they do not distinguish between 

pre-K and K-12 rates and because not all schools were captured in 

Education’s data.

To determine the extent to which PCSB oversees suspensions and 

expulsions at charter schools, we reviewed documentation and guidance 

from PCSB, as well as federal and District laws and regulations. We also 

reviewed documentation from other D.C. education agencies that also 

have a role in overseeing D.C. charter schools and reviewed discipline 

guidance from the U.S. Departments of Education and Justice. In 

addition, we interviewed PCSB officials and officials at other D.C. 

agencies that have oversight of charter schools. These other D.C. 

agencies were

• OSSE;

• Deputy Mayor for Education;

 8 Economic disadvantage is PCSB’s proxy for poverty level and is based on FRPL data. 

9 Limited English Proficiency is the term D.C. uses for English Learners.

Review of Laws, 

Regulations, and 

Guidance and Interviews 

with D.C. Officials
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-17-165 Oversight of D.C. Charter Schools

• State Board of Education, including the Ombudsman for Public 

Education and the Chief Student Advocate; and

• D.C. Office of the Inspector General.

We evaluated PCSB’s oversight of charter school discipline against 

federal standards for internal control for communicating quality 

information to external parties and establishing structure, responsibility, 

and authority, 10 and evaluated D.C. education agencies’ collaboration on 

this issue against leading practices for interagency collaboration.11

We also reviewed selected research studies that provided further context 

and insight into school discipline in charter schools.

To obtain additional context and insights, we selected and interviewed 

researchers and officials from advocacy groups and associations with 

different perspectives on charter schools and discipline. The researchers 

and officials we interviewed were located at

• The Center for Civil Rights Remedies at the Civil Rights Project,

• The Center on Reinventing Public Education,

• The Children’s Law Center,

• The Council for Court Excellence,

• The D.C. Association of Chartered Public Schools,

• D.C. Lawyers for Youth,

• The Dignity in Schools Campaign, and

• The National Association of Charter School Authorizers.

In order to obtain the views of charter school officials with diverse 

perspectives on discipline policies and practices, reasons for high 

discipline rates, and experiences with PCSB oversight, we interviewed 

school and local educational agency (LEA) officials at three D.C. charter 

schools. We selected two schools that had high suspension and/or 

expulsion rates in school year 2014-15, as well as one school with 

 10 GAO-14-704G

11 GAO-12-1022

Interviews with Advocacy 

Groups and Associations

Charter School Interviews
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-17-165 Oversight of D.C. Charter Schools

formerly high discipline rates, according to D.C. data. In making our 

selections, we also took into consideration:

• the number of LEA campuses in D.C., to get perspectives from large 

and small charter school networks;

• grade levels served, because both research and stakeholders 

indicated that discipline rates are higher for middle and high school 

students than elementary school students;

• school location and demographics, to ensure that we spoke to schools 

serving similar populations of students; and

• rank in the 2014 Performance Management Framework (PMF), when 

available, to get perspectives from higher and lower performing 

schools. The PMF is PCSB’s rating system to measure school quality 

and includes three tiers. The highest performing schools are ranked 

as Tier 1, while the lowest are ranked Tier 3.

Table 2: Characteristics of the Three Charter Schools Selected for Interviews

School 1 2 3

Selection criteria High suspension rate; high longterm suspension rate; small 

D.C. network

High suspension rate, high 

expulsion rate, high long-term 

suspension rate; large national 

network

Most improved expulsion rate; 

reduced suspension rate; small 

D.C. network

Grade level 9-12 5-8 6-8

Ward 7 8 7

PMF tier in 2014a Untiered 1 2

Source: GAO analysis of Public Charter School Board (PCSB) data. | GAO-17-165

a

PMF is PCSB’s Performance Management Framew ork. The highest performing schools are ranked 

as Tier 1, w hile the low est are ranked Tier 3. Schools could be un-tiered in 2014 for a number of 

reasons. They could be: in their first year of operation; classified as an early childhood school; 

classified as an adult-education school; or classified as an alternative accountability school.

We conducted two interviews each for the three schools: we interviewed 

LEA staff from the school’s central office and school-based staff including 

the principal and other administrators with responsibility for implementing 

discipline policy. We asked officials to describe their school’s discipline 

policies and practices, how and why they have changed over the years, 

and discipline challenges they are facing. We also reviewed their 

discipline policies in their most recent student handbook, as well as other 

relevant documentation, such as annual reports, renewal reports, and 

Equity Reports which capture schools’ discipline data. Because we 

selected the schools judgmentally, we cannot generalize our findings 

about their policies, practices, and challenges.
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-17-165 Oversight of D.C. Charter Schools

We conducted this performance audit from November 2015 to February 

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Regression Analysis

Page 47 GAO-17-165 Oversight of D.C. Charter Schools

Using the school year 2013-14 CRDC data, we conducted a generalized 

linear regression model examining the association between District of 

Columbia (D.C.) schools’ out-of-school suspensions and various school–

level characteristics. For further discussion of our methodology for this 

analysis, see appendix I.

Our regression model found an association between certain school 

demographic characteristics and suspension, regardless of type of school 

(charter versus traditional public schools). Specifically, serving the upper 

grades (grades 6 and up) or having higher percentages of Black students 

or English Learners were associated with a higher incidence of 

suspensions. Further, our model showed that D.C. charter schools overall 

were associated with a higher incidence of suspensions than D.C 

traditional public schools. However, our model also examined the 

interactions between school type and school demographic variables and 

found that the association between school type and suspension rate 

varied across several demographic variables. Specifically, while serving 

upper grades, higher percentages of Black students, or higher 

percentages of English Learners is generally associated with a higher 

incidence of suspensions, this effect was smaller for charter schools than 

for traditional public schools.

These relationships are shown in table 3, which presents coefficients from 

our model, where positive means that a particular variable was 

significantly associated with an increase in the suspension rate at the 

0.05 level and negative indicates a decrease in the suspension rate. 

Insignificant indicates the variable is not significantly associated with 

suspensions at the 0.05 level.

Table 3: Association of Regression Model Variables with District of Columbia Public 

Schools’ Suspension Rates, School Year 2013-14

School-level variable

Association with 

suspension rates

Percent Male Insignificant

Percent Black Positive

Percent Students with Disabilities Insignificant

Percent English Learners Positive

Grade Levels Served (6 and up) Positive

School Type – Charter Positive

Interaction: Percent Male and School Type – Charter Insignificant

Interaction: Percent Black and School Type – Charter Negative

Appendix II: Regression Analysis
Appendix II: Regression Analysis

Page 48 GAO-17-165 Oversight of D.C. Charter Schools

School-level variable

Association with 

suspension rates

Interaction: Percent with Disabilities and School Type –

Charter

Insignificant

Interaction: Grade Levels Served (6 and up) and School Type 

– Charter

Negative

Interaction: English Learners and School Type – Charter Negative

Source: GAO analysis of Civil Rights Data Collection. | GAO-17-165

Note: Significance is indicated by a p value of less than .05, except for Grade Levels Served 

interaction, w hich has a p value less than 0.10.

Our model did not find an association between gender or the percentage 

of students with disabilities in a school and increased suspension rates. 

The absence of an association here may be due to the way that federal 

data is collected and reported at the school, rather than student, level.
Appendix III: Public Charter School Board 

Responsibilities

Page 49 GAO-17-165 Oversight of D.C. Charter Schools

The District of Columbia School Reform Act of 1995 (School Reform Act) 

established the Public Charter School Board (PCSB) as an eligible 

chartering authority with specific powers and duties.1 Under the School 

Reform Act, PCSB has specific responsibilities with regard to reviewing 

petitions (applications) for new charters, monitoring charter school 

operations, reviewing charter renewal applications, and revoking 

charters.2 Table 4 provides the detailed requirements for these activities 

as specified in the School Reform Act. As required by the School Reform 

Act, PCSB must issue annual reports and financial statement audits. (See 

app. V for information on PCSB’s 2016 annual report.)

Table 4: PCSB Responsibilities As Specified in the District of Columbia School Reform Act of 1995

Review public charter school 

applications

1. Establish a schedule for receiving applications and publish it in the District of Columbia 

Register and newspapers

2. Hold public hearings on applications no more than 45 days after receiving an application

a. Publish a notice of the hearing in the District of Columbia Register and newspapers 

of general circulation

b. Send a written notification of the hearing date to the applicant

3. Approve or deny applications not later than 45 days after the conclusion of the public 

hearing

4. Specify in writing the reasons for denying an application and how the applicant may 

satisfy requirements for approval

5. Provide written notice of an application approval not later than 10 days after approval to 

the applicant and the Chief Financial Officer of the District of Columbia and publish a 

notice of the approval in the District of Columbia Register and newspapers of general 

circulation

6. Not approve more than 10 applications in any academic year 

Monitor the operations of public 

charter schools

1. Ensure schools comply with applicable laws and the provisions of their charters

2. Monitor the progress of schools in meeting student academic achievement expectations 

specified in the charter

Review charter renewal applicationsa

(Charters are in force for 15 years and 

may be renewed for an unlimited 

number of times.)

1. Provide school’s Board of Trustees written notice of right to an informal hearing, not later 

than 15 days after receiving the application

2. Upon receiving a written request for a hearing, set a date and time for the hearing and 

provide reasonable notice of the date and time and procedures to be followed to the 

Board of Trustees

3. Hold the hearing no more than 30 days after receiving the request

4. Provide a written decision no more than 30 days after the hearing was concluded and no 

more than 30 days after the notice of right to a hearing was provided

5. Provide reasons for denial of a renewal application in the written decision

 1 Pub. L. No. 104-134, Title II, 110 Stat. 1321 (1996). 

2 Charters granted to public charter schools are in force for 15 years after which they may 

be renewed for an unlimited number of 15-year periods.

Appendix III: Public Charter School Board 

Responsibilities
Appendix III: Public Charter School Board 

Responsibilities

Page 50 GAO-17-165 Oversight of D.C. Charter Schools

Revoke chartersb 1. Provide the charter school Board of Trustees written notice stating the reasons for 

proposed revocation and inform them of the right to an informal hearing

2. Schedule the hearing upon receiving a written request and provide reasonable notice of 

the date and time, as well as the procedures to be followed at the hearing

3. Hold the hearing not later than 30 days after receiving the request

4. Render a decision in writing, not later than 30 days after providing written notice of right 

to a hearing and not later than 30 days after the hearing is held

5. State in its decision the reason for the revocation

Source: GAO analysis of the District of Columbia School Reform Act of 1995. | GAO-17-165

a

The School Reform Act specifies that the Public Charter School Board (PCSB) shall not approve a 

charter renewal if (1) the school committed a material violation of applicable law s or a material 

violation of the conditions, terms, standards, or procedures set forth in its charter, including violations 

relating to the education of children w ith disabilities, or (2) the school failed to meet the goals and 

achievement expectations in its charter.

b

The School Reform Act specifies that PCSB may revoke a charter if the Board determines that the 

school (1) committed a violation of applicable law s or a material violation of the conditions, terms, 

standards, or procedures set forth in its charter, including violations relating to the education of 

children w ith disabilities, or had failed to meet the goals and student academic achievement 

expectations set forth in the charter; (2) engaged in a pattern of nonadherence to generally accepted 

accounting principles; (3) engaged in a pattern of fiscal mismanagement; or (4) is no longer 

economically viable.
Appendix IV: Public Charter School 

Application Process

Page 51 GAO-17-165 Oversight of D.C. Charter Schools

The Public Charter School Board (PCSB) reviews all applications for new 

charter schools in the District of Columbia (D.C.), which can be submitted 

by parents, educators, nonprofit organizations, or other groups.1 With 

some exceptions, applicants must generally adhere to the same guidance 

and must meet PCSB’s standards for approval.2 (See table 5.)

Table 5: Types of Charter School Applicants and Charter Schools Specified in the 

PCSB Application Process

Type of applicant

Experienced operators (existing non-profit management organizations or charter school 

networks with at least 3 years of performance data)

Management organizations (new schools or experienced operators that plan to contract 

with an existing non-profit or for-profit management organization)

New schools 

Type of Charter School Proposed by Applicants

Conversion of an existing District of Columbia public school into a charter school

Conversion of an existing private or independent school into a public charter school

Establishment of a new public charter school

Source: Public Charter School Board (PCSB), 2016 Charter Application Guidelines: Application to Establish a Public Charter School in 

the District of Columbia. | GAO-17-165

PCSB provides application instructions and sample documents on the 

agency’s website.3 Once PCSB receives an application, the review 

process generally takes 3 months. (For example, see table 6 for PCSB’s 

fall 2016 charter application timeline.)

 1 General requirements for applicants to petition PCSB to establish a D.C. charter school 

are found in D.C. Code §§ 38-1802.01, 38-1802.02.

2 Some questions in the application differ slightly for applicants categorized as 

experienced operators and management organizations.

3 Public Charter School Board, 2016 Charter Application Guidelines: Application to 

Establish a Public Charter School in the District of Columbia.

Appendix IV: Public Charter School 

Application Process
Appendix IV: Public Charter School 

Application Process

Page 52 GAO-17-165 Oversight of D.C. Charter Schools

Table 6: PCSB’s Fall 2016 Charter Application Timeline

Date Action item

August 31, 2016 Deadline to submit electronic application for confirmation 

of completeness before printing

September 2, 2016 Deadline to submit paper copies of application

September 22-23, 2016 Interviews

September 26-28, 2016 Site visits (if applicable)

October 17, 2016 Public hearing

November 21, 2016 Board decision announced

Source: Public Charter School Board (PCSB) website (http://www.dcpcsb.org/report/start-charter-school), accessed September 15, 

2016. | GAO-17-165

PCSB’s charter school application review is a four-part process including 

written applications, site visits (if applicable), interviews, and public 

hearings (see table 7). Following the application review, PCSB votes on 

each charter application at a public meeting.

Table 7: PCSB Application Review Elements

Written applications Applicants must provide a detailed academic and business plan, including the school’s academic focus, plans 

for community and parental involvement, a 2-year operating budget, and articles of incorporation and bylaws. 

Applications must demonstrate a need for the school; provide information on education, management, and 

finance plans; include curriculum samples; and provide information on the founding group. 

Site visits Site visits to an operator’s existing schools are scheduled following submission of the written application. 

Applicants eligible for site visits include all experienced operators, as well as some new schools, particularly 

those contracting with a management organization or conversion schools.

Interviews Interviews with PCSB staff and the applicants (also referred to as the founding group) of the proposed school. 

Applicants may bring as many members of their group as they deem appropriate and are encouraged to include 

their special education expert. Interviews are transcribed and publicly available.

Public hearings Public hearings to provide the PCSB Board and the public the opportunity to hear from charter school 

applicants. Applicants provide a brief introduction about the proposed school, such as its mission and target 

population, and may address the PCSB Board and public with prepared comments that are to be no longer than 

5 minutes. The PCSB Board will ask questions of the applicant and members of the public may give testimony 

about the application. 

Source: Public Charter School Board (PCSB), 2016 Charter Application Guidelines: Application to Establish a Public Charter School in the District of Columbia and Public Charter School Board website 

(http://www.dcpcsb.org/report/start-charter-school), accessed September 15, 2016. | GAO-17-165

Applications for a charter school follow a standard format and are 

required to include specific elements. (See text box.)
Appendix IV: Public Charter School 

Application Process

Page 53 GAO-17-165 Oversight of D.C. Charter Schools

PCSB’s Charter School Written Application Required Table of Contents

Table of Contents

Applicant Information Sheet

Executive Summary4

A. Establishing a Need

1. Demonstrating a Need

2. Recruiting and Marketing

B. Education Plan

1. Mission and Philosophy

2. Charter Goals and Student Academic Achievement Expectations

3. Curriculum

4. Support for Learning

C. Management Plan

1. Founding and Leadership

2. Staffing Plan

3. Management and Internal Oversight

4. Management Organization (if applicable)

5. Student Policies and Procedures

D. Finance Plan

1. Facilities

2. Finance

3. Budget Workbook

E. Founding Group Supporting Documents

• Résumé

• Personal Statement

If the founding group member plans to join the founding board, also include:

• Board Member Agreement (in a separate file)

• Conflict of Interest Form

F. Additional Required Documents

1. Articles of Incorporation

2. Bylaws

3. Code of Ethics

4. Conversion Endorsement Certification (if applicable)

5. Letter of Intent for Facility (if applicable)

6. Research on Comparable Facilities (if applicable)

7. Draft Memorandum of Understanding, Letter of Intent, or Contract for MissionCritical Partnerships

8. Assurances Form

If applicant is an experienced operator or management organization, also include:

9. Management Agreement and Related Documents

10. Financial Audits for the last three years

11. Annual Reports for the last two years

12. IRS filings for the last three years

G. Curriculum Samples

Source: Public Charter School Board (PCSB), 2016 Charter Application Guidelines: Application to Establish a Public Charter School in the District of Columbia. | GAO-17-165
Appendix IV: Public Charter School 

Application Process

Page 54 GAO-17-165 Oversight of D.C. Charter Schools

In addition to the written applications, site visits, interviews, and public 

hearings, PCSB evaluates charter school applicants against established 

criteria (see table 8).

Table 8: PCSB’s Application Review Criteria

Criteria Description

Demonstrated need for the 

school

Has the applicant made a compelling case for why the school fills an unmet need in the District of 

Columbia (D.C.)?

Sufficient progress in developing 

the plan

Has the applicant made significant progress in designing a high quality school or in planning the 

replication of their existing school(s), and assessed the challenges they will face in opening and 

operating the school, and clearly described how they expect to address those challenges? Do the 

essential elements of the school’s academic and non-academic programming demonstrate how the 

school will fulfill its goals and mission? In cases where elements of the application are not yet fully 

developed, has the applicant presented an achievable timeline and framework? Has the applicant 

group planned for conservative growth (i.e., adding no more than two grades and 150 students per 

year)? Have applicants expecting more aggressive growth demonstrated existing local interest in 

the school, including recruitment/outreach staff on the ground by the time of the application 

submission, and a contingency budget that includes growth of no more than 150 students per 

year?

Consistency of the mission and 

philosophy

Are the essential elements of the mission, philosophy, and school program infused in each element 

of the application?

Inclusiveness Is each element of the school program deliberately designed to be inclusive of all students, 

including students with disabilities, English language learners, students who are academically 

struggling or advanced, homeless students, and any other population(s) targeted in the mission? 

Further, can the school accommodate and serve students who do not fit into the school’s target 

population but who may be admitted through the enrollment lottery?

Founding group ability Has the applicant demonstrated its ability to ensure that the proposed school can meet the 

educational objectives outlined in the application, including the following:

• For new schools: having the experience, knowledge, and skill to implement innovative and/or 

research-proven strategies to effect strong academic and non-academic results with student 

populations similar to those found in D.C. public schools;

• For experienced operators or schools planning to contract with a management organization:

having a history of strong academic and non-academic results with student populations similar 

to those found in DC public schools;

• understanding the D.C. educational landscape and how to attract students and families;

• holding a strong commitment to the education of all students, including having a member of 

the founding group with deep special education expertise;

• having effective controls in place to ensure financial stability and legal compliance; and

• having members who have the combined skillset needed to build and implement its program, 

or an operational team with this skillset?

Source: Public Charter School Board (PCSB). 2016 Charter Application Guidelines: Application to Establish a Public Charter School in the District of Columbia and Public Charter School Board website 

(http://www.dcpcsb.org/report/start-charter-school), accessed September 15, 2016. | GAO-17-165

Criteria for Review of 

Applications
Appendix IV: Public Charter School 

Application Process

Page 55 GAO-17-165 Oversight of D.C. Charter Schools

PCSB may approve any application if it determines that the application (1) 

meets the legal requirements; (2) agrees to any condition or requirement 

set forth by the authorizer; and (3) has the ability to meet the educational 

objectives outlined in the application. If PCSB does not approve an 

application, it must provide written notice to the applicant explaining why 

the application was not approved. Based on all components of the 

application process, the PCSB Board votes on each charter school 

application at a public meeting. There are three possible outcomes for an 

application:

1. Full approval: Applicant has met all of the requirements.

2. Conditional approval/approval with conditions: Applicant is approved 

pending satisfaction of all requirements, wherein they are determined 

to have Full Approval.

3. Denial: Applicant does not meet all of the requirements and no further 

consideration is given to the application. Such applicants may address 

the shortcomings and reapply in a future cycle, though not in the 

same 12-month period.

Determination of 

Applicants’ Ability to 

Operate a Charter School
Appendix V: Summary of Public Charter 

School Board 2016 Annual Report Contents

Page 56 GAO-17-165 Oversight of D.C. Charter Schools

Table 9: PCSB Annual Reporting Requirements and Components of 2016 Annual Report

Annual Reporting Requirementsa Content Shown in Reportb

A list of the PCSB members.c The seven members of the Board and their wards of residence:

• Darren Woodruff (Chair), Ward 4

• Don Soifer, Ward 2

• Steve Bumbaugh, Ward 3

• Sara Mead, Ward 6

• Rick Cruz, Ward 3

• Ricarda Ganjam, Ward 6

• Saba Bireda, Ward 8

A list of the dates and places of each meeting 

of PCSB during the year preceding the report.

Dates and locations of public meetings held between August 2015 and July 2016

August 17, 2015 PCSB Office

September 21, 2015 PCSB Office

October 26, 2015 DC International School

November 16, 2015 Carlos Rosario International PCS

December 14, 2015 César Chávez Prep PCS – Kenyon Campus

January 27, 2016 Washington Latin PCS

February 10, 2016 (Special Meeting) Gala Hispanic Theatre

February 22, 2016 PCSB Office

March 22, 2016 PCSB Office

April 18, 2016 Carlos Rosario International PCS

May 16, 2016 IDEA PCS

June 20, 2016 PCSB Office

July 18, 2016 PCSB Office

The number of petitions received for the 

conversion of an existing school to a public 

charter school and for the creation of a new 

charter school.

Four public charter school proposals received:

1. Sustainable Futures

2. Interactive Academy

3. Pathways in Education

4. The Adult Career Technical Education

The number of petitions that were approved 

and the number that were denied. 

One approved—Sustainable Futures

One denied—Interactive Academy

Two withdrawn—Pathways in Education and The Adult Career Technical Education.

Summary of the reasons for which such 

petitions were denied.

The Board denied the application of Interactive Academy for three reasons: (1) 

capacity of the founding group; (2) insufficient development of the plan for supporting 

students with disabilities; and (3) insufficient evidence of the success of the founding 

group in driving academic achievement.

Appendix V: Summary of Public Charter 

School Board 2016 Annual Report Contents
Appendix V: Summary of Public Charter 

School Board 2016 Annual Report Contents

Page 57 GAO-17-165 Oversight of D.C. Charter Schools

Annual Reporting Requirementsa Content Shown in Reportb

A description of any new charters issued by 

PCSB during the year preceding the report. 

Sustainable Futures will serve 131 students in its first year, growing to no more than 

288 students by its third year of operation. The school seeks to serve disconnected 

youth in the District and will offer project-based learning, along with a competencybased approach to allow students to move through the curriculum at their own pace. 

The school will also offer social-emotional supports (e.g., mental health services) and 

wraparound services (e.g., on-site health clinic, transportation assistance, and three 

meals per day).

A description of any charters renewed by 

PCSB during the year preceding the report. 

Two charters renewed:

1. KIPP DC PCS

2. Thurgood Marshall Academy PCS

Four charters reviewed:

1. Inspired Teaching Demonstration PCS

2. Imagine Hope Community PCS

3. Washington Latin PCS

4. The Next Step PCS.

A description of any charters revoked by PCSB 

during the year preceding the report. 

Potomac Preparatory PCS charter revoked for poor academic performance.

A description of any charters refused renewal 

by PCSB during the year preceding the report.

None listed

Any recommendations concerning ways to 

improve the administration of public charter 

schools.

No recommendations found.

Source: GAO analysis of the District of Columbia School Reform Act of 1995 and Public Charter School Board (PCSB), 2016 Annual Report. | GAO-17-165

a

Annual reporting requirements as specified in D.C. Code § 38-1802.11(d). Although the law refers to 

“eligible chartering authority,” PCSB is currently the only chartering authority in the District of 

Columbia (D.C. or the District), and therefore we have only referred to PCSB in the table for 

simplicity. The annual reports must be issued by July 30; PCSB’s 2016 Annual Report w as published 

on July 27, 2016.

The reports must also be submitted to the District of Columbia Mayor, District of Columbia Council, 

District of Columbia Board of Education, Secretary of Education, Consensus Commission, House and 

Senate Committees on Appropriations, House Committee on Education and the Workforce, Senate 

Committee on Health, Education, Labor, and Pensions, House Committee on Oversight and 

Government Reform, and Senate Committee on Homeland Security and Governmental Affairs.

b

The 2016 report can be found online at http://www.dcpcsb.org/sites/default/files/2016.07.27-dcpcsbannual-report-single-page.pdf. View previous years’reports at http://www.dcpcsb.org/report/pcsbannual-reports.

c

The law also requires the reports to include members’ addresses. D.C. Code § 38-1802.11(d)(1).
Appendix VI: Public Charter School Board 

Revenues and Expenditures

Page 58 GAO-17-165 Oversight of D.C. Charter Schools

Table 10: PCSB Revenues and Expenditures, Fiscal Years (FY) 2011—2015

FY 2011 FY 2012 FY 2013 FY 2014 FY 2015

Revenues

Total $4,931,630 $4,782,429 $5,534,067 $7,047,554 $7,987,091 

Administrative Fees $2,065,105 $2,509,209 $3,130,224 $3,509,078 $7,343,934 

Local Funds $1,201,000 $951,656 $947,806 $1,016,650 $0

Grantsa $1,557,183 $1,213,327 $1,356,226 $2,420,008 $638,139 

Otherb $108,341 $108,238 $99,812 $101,818 $5,018 

Expenditures

Total $5,964,693 $4,695,487 $5,277,574 $6,345,054 $6,141,566 

Personnel (Salary and 

Benefits) $2,697,745 $2,478,255 $2,983,415 $3,715,796 $4,114,329

Program (Non-Personnel) $2,507,320 $1,368,839 $1,077,779 $1,237,428 $644,719

Otherc $759,628 $848,393 $1,216,380 $1,391,830 $1,382,518 

Source: GAO Analysis of Public Charter School Board (PCSB) data. | GAO-17-165

a

Grants includes both federal and private grants. PCSB has not received any federal grant funds 

since FY 2014.

b

Other revenues include school closure funds and sponsorship income, among other sources.

c

Other expenditures include facilities costs, community events, w ebsite costs, and other overhead 

expenses.

Appendix VI: Public Charter School Board 

Revenues and Expenditures
Appendix VII: Public Charter School Board’s 

Discipline and Demographic Data

Page 59 GAO-17-165 Oversight of D.C. Charter Schools

Table 11: PCSB School-Level Discipline and Demographic Data, School Year 2015-16

School name

Number of

students

Suspension 

rate 

(percent) 

Expulsion 

rate 

(percent)

Grade 

levels 

serveda

Percent 

Black 

students

Percent 

Hispanic 

students

Percent 

economically 

disadvantagedb

Percent 

students with 

disabilities

2015-16 D.C. charter 

averagec

341.3 9.1 0.2 NA 76.3 15.5 83.6 14.1 

Achievement Preparatory 

PCS – Elementary

273 9.2 0.0 K-3 98.9 1.1 99.6 11.0 

Achievement Preparatory 

PCS – Middle 

383 12 0.0 4-8 99.2 0.8 85.1 16.2 

AppleTree Early Learning 

PCS – Columbia Heights

158 0 0.0 PK3-PK4 55.1 19.0 68.4 8.2 

AppleTree Early Learning 

PCS – Lincoln Park

60 0 0.0 PK3-PK4 33.3 8.3 26.7 1.7 

AppleTree Early Learning 

PCS – Oklahoma

156 0 0.0 PK3-PK5 98.1 1.3 100.0 5.1 

AppleTree Early Learning 

PCS – Southeast

177 0 0.0 PK3-PK4 94.9 3.4 99.4 6.8 

AppleTree Early Learning 

PCS – Southwest

102 0 0.0 PK3-PK4 81.4 7.8 78.4 6.9 

BASIS DC PCS 599 7.3 0.0 5-11 38.9 6.7 20.0 4.8 

Bridges PCS 333 0.9 0.0 PK3-2 43.8 27.6 64.9 32.1 

Capital City PCS – Middle 324 6.8 0.6 5-8 43.5 43.5 75.0 15.4 

Capital City PCS – High 333 15.3 0.9 9-12 37.8 54.4 82.9 19.8 

Capital City PCS – Lower 324 0.6 0.0 PK3-3 36.1 41.0 67.0 8.0 

Cedar Tree Academy PCS 366 0 0.0 PK3-K 99.5 0.3 100.0 4.4 

Center City PCS –

Brightwood 

252 0.8 0.0 PK4-8 42.9 50.0 76.6 11.9 

Center City PCS – Capitol 

Hill 

244 16.4 0.8 PK4-8 97.1 1.6 68.4 11.5 

Center City PCS –

Congress Heights

243 8.6 0.4 PK4-8 99.6 0.4 100.0 7.0 

Center City PCS – Petworth 251 7.6 0.0 PK4-8 41.0 54.6 83.7 9.6 

Center City PCS – Shaw 237 7.6 0.0 PK4-8 67.9 27.8 86.1 10.5 

Center City PCS – Trinidad 211 8.5 3.3 PK4-8 97.2 2.8 99.1 12.8 

César Chávez PCS for 

Public Policy – Capitol Hill 

387 16.5 0.0 6-9 87.6 12.1 98.2 22.2 

César Chávez PCS for 

Public Policy – Chavez 

Prep

357 10.6 0.0 9-12 42.6 55.7 98.0 12.6 

César Chávez PCS for 

Public Policy – Parkside 

High 

374 12.6 0.0 9-12 92.8 7.2 99.7 12.6 

Appendix VII: Public Charter School Board’s 

Discipline and Demographic Data
Appendix VII: Public Charter School Board’s 

Discipline and Demographic Data

Page 60 GAO-17-165 Oversight of D.C. Charter Schools

School name

Number of

students

Suspension 

rate 

(percent) 

Expulsion 

rate 

(percent)

Grade 

levels 

serveda

Percent 

Black 

students

Percent 

Hispanic 

students

Percent 

economically 

disadvantagedb

Percent 

students with 

disabilities

César Chávez PCS for 

Public Policy – Parkside 

Middle 

302 10.6 0.0 6-8 96.4 3.3 99.3 16.9 

Creative Minds 

International PCS

237 0.4 0.0 PK3-5 32.1 13.9 22.8 29.5 

DC Bilingual PCS 403 2.7 0.0 PK3-5 18.1 56.3 82.9 16.9 

DC Preparatory Academy 

PCS – Anacostia 

Elementary

141 0 0.0 PK3-PK4 89.4 3.5 82.3 6.4 

DC Preparatory Academy 

PCS – Benning Elementary

444 14.6 0.0 PK3-3 94.6 3.4 100.0 7.9 

DC Preparatory Academy 

PCS – Benning Middle 

223 28.3 0.0 4-6 94.2 2.7 74.0 20.2 

DC Preparatory Academy 

PCS – Edgewood 

Elementary

441 8.8 0.0 PK3-3 84.1 8.8 76.9 9.8 

DC Preparatory Academy 

PCS – Edgewood Middle

310 23.9 0.3 4-8 90.0 3.2 74.8 16.5 

DC Scholars PCS 446 10.1 0.0 PK3-6 100.0 0.0 100.0 13.0 

Democracy Prep Congress 

Heights PCS

627 21.7 0.0 PK3-6 96.5 3.5 99.7 13.6 

District of Columbia 

International School

404 4.2 0.3 6-8 37.1 40.3 56.2 16.6 

E.L. Haynes PCS –

Elementary 

333 3.9 0.0 PK3-5 41.7 38.4 66.7 15.6 

E.L. Haynes PCS – High 435 21.6 0.2 5-8 50.3 45.3 65.5 23.9 

E.L. Haynes PCS – Middle 373 20.9 0.3 9-12 47.5 46.6 77.2 25.5 

Eagle Academy PCS –

Capitol Riverfront

141 0 0.0 PK3-3 93.6 2.8 99.3 11.3 

Eagle Academy PCS –

Congress Heights

785 2 0.0 PK3-3 99.1 0.1 100.0 16.2 

Early Childhood Academy 

PCS

262 0.8 0.0 PK3-3 98.9 1.1 100.0 10.4 

Elsie Whitlow Stokes 

Community Freedom PCS

350 0 0.0 PK3-5 41.4 27.7 52.9 9.4 

Excel Academy PCS 731 12.3 0.1 PK3-7 98.6 0.5 99.9 6.4 

Friendship PCS –

Armstrong

432 4.9 0.0 PK-5 94.2 5.1 100.0 10.9 

Friendship PCS – BlowPierce Elementary408 9.3 0.0 PK3-3 98.5 1.2 100.0 6.4 

Friendship PCS – BlowPierce Middle187 16 0.0 4-8 98.9 0.5 100.0 19.8 
Appendix VII: Public Charter School Board’s 

Discipline and Demographic Data

Page 61 GAO-17-165 Oversight of D.C. Charter Schools

School name

Number of

students

Suspension 

rate 

(percent) 

Expulsion 

rate 

(percent)

Grade 

levels 

serveda

Percent 

Black 

students

Percent 

Hispanic 

students

Percent 

economically 

disadvantagedb

Percent 

students with 

disabilities

Friendship PCS –

Chamberlain Elementary

376 1.6 0.0 PK3-3 99.2 0.3 100.0 8.0 

Friendship PCS –

Chamberlain Middle

334 5.1 0.0 4-8 99.7 0.3 100.0 17.1 

Friendship PCS –

Collegiate Academy

810 12.7 0.4 9-12 99.9 0.1 100.0 21.5 

Friendship PCS –

Southeast Academy

546 11.4 0.0 PK3-5 100.0 0.0 100.0 9.3 

Friendship PCS –

Technology Preparatory 

Middle

543 16.8 0.6 6-8 99.3 0.4 100.0 22.1 

Friendship PCS –

Woodridge Elementary

281 3.6 0.0 PK3-3 96.1 3.2 100.0 7.8 

Friendship PCS –

Woodridge Middle

179 14.5 0.6 4-8 96.6 2.8 100.0 20.1 

Harmony DC PCS – School 

of Excellence

105 17.1 0.0 K-5 96.2 2.9 100.0 23.8 

Hope Community PCS –

Lamond

316 2.5 0.0 PK3-5 88.9 10.4 77.2 8.5 

Hope Community PCS –

Tolson 

520 1.5 0.0 PK3-8 94.0 5.8 80.6 10.4 

Howard University Middle 

School of Mathematics and 

Science PCS

266 12.8 0.0 6-8 94.7 4.9 77.1 9.4 

IDEA PCS 281 30.6 2.9 9-12 97.5 2.1 100.0 23.5 

Ideal Academy PCS 296 8.1 0.0 PK3-8 97.0 3.0 100.0 9.4 

Ingenuity Prep PCS 288 17.4 0.0 PK3-2 98.3 1.4 100.0 19.1 

Inspired Teaching 

Demonstration PCS

368 2.2 0.0 PK3-7 42.7 4.1 20.4 13.9 

Kingsman Academy PCS 254 12.6 0.4 6-12 99.2 0.0 100.0 57.9 

KIPP DC PCS – AIM 

Academy 

350 32.6 0.6 5-8 99.7 0.3 100.0 27.4 

KIPP DC PCS – Arts & 

Technology Academy 

229 1.3 0.0 PK3-K 99.6 0.4 100.0 9.6 

KIPP DC PCS – College 

Preparatory Academy

505 27.1 0.8 9-12 99.8 0.2 100.0 19.0 

KIPP DC PCS – Connect 

Academy

315 0.3 0.0 PK3-K 98.4 0.3 100.0 8.9 

KIPP DC PCS – Discover 

Academy

346 0.3 0.0 PK3-K 99.4 0.0 100.0 7.8 

KIPP DC PCS – Grow 

Academy 

327 0.9 0.0 PK3-K 97.2 0.6 100.0 9.8 
Appendix VII: Public Charter School Board’s 

Discipline and Demographic Data

Page 62 GAO-17-165 Oversight of D.C. Charter Schools

School name

Number of

students

Suspension 

rate 

(percent) 

Expulsion 

rate 

(percent)

Grade 

levels 

serveda

Percent 

Black 

students

Percent 

Hispanic 

students

Percent 

economically 

disadvantagedb

Percent 

students with 

disabilities

KIPP DC PCS – Heights 

Academy 

434 10.1 0.0 1-4 100.0 0.0 100.0 12.9 

KIPP DC PCS – KEY 

Academy

341 27.3 0.0 5-8 98.8 0.3 100.0 15.0 

KIPP DC PCS – Lead 

Academy

421 7.4 0.0 1-4 96.4 1.9 100.0 12.8 

KIPP DC PCS – LEAP 

Academy

213 0 0.0 PK3-PK4 99.1 0.5 100.0 8.0 

KIPP DC PCS – Northeast 

Academy

238 10.1 0.0 5-7 98.3 1.3 100.0 21.0 

KIPP DC PCS – Promise 

Academy

515 6.8 0.0 K-4 99.0 0.6 100.0 14.6 

KIPP DC PCS – Quest 

Academy

324 15.1 0.0 1-4 98.1 0.9 100.0 14.2 

KIPP DC PCS – Spring 

Academy

216 2.8 0.0 1-2 96.3 2.8 100.0 10.6 

KIPP DC PCS – Valor 

Academy

120 28.3 0.0 5-7 99.2 0.8 100.0 25.0 

KIPP DC PCS – WILL 

Academy 

303 30 0.7 5-8 98.7 0.7 100.0 23.4 

Latin American Montessori 

Bilingual PCS

374 0 0.0 PK3-5 14.2 51.9 27.8 12.0 

Lee Montessori PCS 104 1 0.0 PK3-2 44.2 2.9 36.5 18.3 

Mary McLeod Bethune Day 

Academy PCS

420 7.6 0.0 PK3-8 90.0 7.1 99.5 7.5 

Maya Angelou PCS – High 

School

225 16.9 0.9 9-12 99.6 0.0 100.0 40.0 

Meridian PCS 724 9.4 0.0 PK3-8 61.7 35.1 98.9 10.4 

Monument Academy PCS 40 37.5 0.0 5 100.0 0.0 100.0 55.0 

Mundo Verde Bilingual PCS 538 1.1 0.0 PK3-4 22.7 39.0 35.3 8.4 

National Collegiate 

Preparatory PCHS

280 22.5 2.5 9-12 100.0 0.0 100.0 22.1 

Paul PCS – International 

High School

444 19.8 1.6 9-12 75.0 23.9 57.2 14.2 

Paul PCS – Middle School 232 27.6 0.9 6-8 81.0 19.0 60.8 13.8 

Perry Street Preparatory 

PCS

323 10.2 0.0 PK3-8 96.9 0.6 73.1 13.3 

Potomac Preparatory PCS 427 1.9 0.0 PK3-8 96.7 0.9 100.0 15.7 

Richard Wright PCS for 

Journalism and Media Arts

284 15.1 0.0 8-12 98.9 1.1 100.0 19.0 

Roots PCS 106 0 0.0 PK3-5 100.0 0.0 95.3 3.0 
Appendix VII: Public Charter School Board’s 

Discipline and Demographic Data

Page 63 GAO-17-165 Oversight of D.C. Charter Schools

School name

Number of

students

Suspension 

rate 

(percent) 

Expulsion 

rate 

(percent)

Grade 

levels 

serveda

Percent 

Black 

students

Percent 

Hispanic 

students

Percent 

economically 

disadvantagedb

Percent 

students with 

disabilities

SEED PCS of Washington, 

DC

352 32.4 1.7 6-12 99.7 0.3 98.9 17.6 

Sela PCS 134 0.7 0.0 PK3-2 64.2 9.0 64.2 9.7 

Shining Stars Montessori 

Academy PCS

160 0 0.0 PK3-4 52.5 12.5 50.0 11.3 

Somerset Preparatory 

Academy PCS

279 15.1 1.8 6-10 99.3 0.0 100.0 25.8 

St. Coletta Special 

Education PCS

251 1.2 0.0 ages 3-22 77.7 12.0 79.3 100.0 

The Children's Guild DC 

PCS

326 23.3 0.0 K-8 98.8 0.3 96.3 38.7 

Thurgood Marshall 

Academy PCS

387 14.2 0.0 9-12 99.7 0.3 74.4 12.1 

Two Rivers PCS – 4th 

Street

526 7.6 0.0 PK3-8 59.9 10.1 50.8 22.4 

Two Rivers PCS – Young 169 0.6 0.0 PK3-1 60.9 5.9 49.7 15.4 

Washington Global PCS 101 11.9 0.0 6-7 98.0 2.0 100.0 25.7 

Washington Latin PCS –

Middle School

362 6.6 0.0 5-8 36.5 8.6 16.0 8.3 

Washington Latin PCS –

Upper School

321 7.2 0.6 9-12 55.5 12.5 24.9 14.0 

Washington Mathematics 

Science Technology PCHS

310 12.3 0.0 9-12 99.4 0.6 98.7 23.2

Washington Yu Ying PCS 551 0.4 0.0 PK3-5 36.8 5.4 11.4 8.3

William E. Doar, Jr. PCS for 

the Performing Arts

467 11.3 0.0 PK3-8 96.8 2.6 98.5 10.1

Source: GAO analysis of Public Charter School Board (PCSB) data. | GAO-17-165

Note: Demographic percentages refer to percent of students in the school.

a

PK3 and PK4 refer to Pre-Kindergarten for 3- and 4-year-olds, respectively. K refers to Kindergarten.

b

Economic disadvantage is PCSB’s proxy for poverty and is based on free or reduced-price lunch 

eligibility data.

c

These are PCSB’s published averages for all charter schools in 2015-16. Our analysis excludes the 

9 charter schools that served adults or that w ere exclusively online in 2015-16. Therefore, the 

averages for the schools shown in this table may be slightly different than the averages we present 

here.
Appendix VII: Public Charter School Board’s 

Discipline and Demographic Data

Page 64 GAO-17-165 Oversight of D.C. Charter Schools

Table 12: PCSB Charter School Discipline Rates, School Years 2012-13 through 

2015-16

Rates 2012-13 2013-14 2014-15 2015-16

Suspension rate 14.7 11.9 10.9 9.1

Expulsion rate .5 .4 .4 .2

Source: GAO analysis of Public Charter School Board (PCSB) data. | GAO-17-165
Appendix VIII: Comments from the Public 

Charter School Board

Page 65 GAO-17-165 Oversight of D.C. Charter Schools

Appendix VIII: Comments from the Public 

Charter School Board
Appendix VIII: Comments from the Public 

Charter School Board

Page 66 GAO-17-165 Oversight of D.C. Charter Schools
Appendix VIII: Comments from the Public 

Charter School Board

Page 67 GAO-17-165 Oversight of D.C. Charter Schools
Appendix VIII: Comments from the Public 

Charter School Board

Page 68 GAO-17-165 Oversight of D.C. Charter Schools
Appendix VIII: Comments from the Public 

Charter School Board

Page 69 GAO-17-165 Oversight of D.C. Charter Schools
Appendix VIII: Comments from the Public 

Charter School Board

Page 70 GAO-17-165 Oversight of D.C. Charter Schools
Appendix VIII: Comments from the Public 

Charter School Board

Page 71 GAO-17-165 Oversight of D.C. Charter Schools
Appendix IX: Comments from the Office of the 

State Superintendent of Education

Page 72 GAO-17-165 Oversight of D.C. Charter Schools

Appendix IX: Comments from the Office of 

the State Superintendent of Education
Appendix IX: Comments from the Office of the 

State Superintendent of Education

Page 73 GAO-17-165 Oversight of D.C. Charter Schools
Appendix X: GAO Contact and Staff 

Acknowledgments

Page 74 GAO-17-165 Oversight of D.C. Charter Schools

Jacqueline M. Nowicki, (617) 788-0580, nowickij@gao.gov

In addition to the contact named above, Sherri Doughty (Assistant 

Director), Lauren Gilbertson (Analyst-in-Charge), Melinda Bowman, Jean 

McSween, John Mingus, James Rebbe, Alexandra Squitieri, and Sonya 

Vartivarian made key contributions to this report. Also contributing to this 

report were Deborah Bland, Grace Cho, Sara Daleski, Holly Dye, Lauren 

Kirkpatrick, Sheila R. McCoy, Mimi Nguyen, Sara Pelton, and Ronni 

Schwartz.

Appendix X: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100474)
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