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. 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. 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 individuals with disabilities, civil rights, and health and safety conditions. 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. In addition, charter schools are to be held accountable for their financial and educational performance, including the testing requirements under the Elementary and Secondary Education Act of 1965 (ESEA), as amended. In D.C., all charter schools are nonprofit organizations and are required to be governed by a board of trustees. 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. 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 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. 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, 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. 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 IDEA- eligible students with disabilities. 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 a student whose behavior impedes his or her learning or that of others. 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. 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. Examples of covered disabilities under IDEA include intellectual disabilities, hearing or visual impairments, emotional disturbance, autism, and specific learning disabilities. 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 oversight of D.C. charter schools. 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). PCSB, as the sole chartering authority in D.C., has the power to approve, oversee, renew, and revoke charters. (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. PCSB is also required to submit an annual report that includes information on charter renewals, revocations, and other actions related to public charter schools. (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. 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. 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. 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. 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. 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 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. Further, students with disabilities under IDEA have specific rights afforded under that statute. 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. 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. 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. 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). 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). 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. 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. 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 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. 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. 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 comprised 12 percent of D.C. charter school enrollment but represented 20 percent of those suspended and 28 percent of those expelled. 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.) 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. 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. 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 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 that they were using interventions and supports that emphasize positive behaviors to reduce incidences of discipline. (See text box.) An official from the third school said that they have implemented an alternative to in- school suspensions when a student is disruptive, giving the student an opportunity to reflect and continue classwork in a separate environment. 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. 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. 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 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). 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. 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. 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. See figure 10 for an excerpt from one charter school’s 2014-15 Equity Report. 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 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 federally- recognized reasons.” –PCSB 2016 Charter Application Guidelines 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. 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 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. 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. 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 , mandating school disciplinary processes,” thereby limiting the actions that D.C. agencies, including PCSB, may take. 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. 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, 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 non- regulatory 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. Similarly, standards for internal control state that to achieve an entity’s objectives management should establish an organizational structure and assign responsibilities. 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 school- level 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. 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. 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 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. 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. 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 incidences of bullying. 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 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. 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. 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. 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). 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. 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 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) 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. 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 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. 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; Limited English Proficiency; 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 Deputy Mayor for Education; 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, and evaluated D.C. education agencies’ collaboration on this issue against leading practices for interagency collaboration. 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 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. 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. 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. 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. 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. 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. 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. 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.) 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. With some exceptions, applicants must generally adhere to the same guidance and must meet PCSB’s standards for approval. (See table 5.) PCSB provides application instructions and sample documents on the agency’s website. 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.) 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. Applications for a charter school follow a standard format and are required to include specific elements. (See text box.) In addition to the written applications, site visits, interviews, and public hearings, PCSB evaluates charter school applicants against established criteria (see table 8). 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. A list of the dates and places of each meeting of PCSB during the year preceding the report. December 14, 2015 January 27, 2016 February 10, 2016 (Special Meeting) 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. The number of petitions that were approved and the number that were denied. Summary of the reasons for which such petitions were denied. Four public charter school proposals received: 1. Sustainable Futures 2. Interactive Academy 3. Pathways in Education 4. The Adult Career Technical Education One approved—Sustainable Futures One denied—Interactive Academy Two withdrawn—Pathways in Education and The Adult Career Technical Education. 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. Annual Reporting Requirements A description of any new charters issued by PCSB during the year preceding the report. A description of any charters renewed by PCSB during the year preceding the report. Content Shown in 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 competency- based 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). 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. Potomac Preparatory PCS charter revoked for poor academic performance. A description of any charters revoked by PCSB during the year preceding the report. A description of any charters refused renewal by PCSB during the year preceding the report. Any recommendations concerning ways to improve the administration of public charter schools. No recommendations found. Grants includes both federal and private grants. PCSB has not received any federal grant funds since FY 2014. Other revenues include school closure funds and sponsorship income, among other sources. Other expenditures include facilities costs, community events, w ebsite costs, and other overhead expenses. Appendix VII: Public Charter School Board’s Discipline and Demographic Data Suspension rate (percent) 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.

Summary: 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. 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. 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. 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.