I. Background The Louisiana Department of Education (LDOE) was notified that New Beginnings Schools Foundation (NBSF) was completing a review of its 2019 graduating class. In order to assist with the NBSF review, the LDOE conducted a separate review of the NBSF policies that pertain to credit attainment and the business rules used to evaluate graduation completion records at John F. Kennedy High School (JFK). In its review, the LDOE: A. assessed the extent to which NBSF and JFK were completing an accurate assessment of each student’s graduation status; B. assessed the extent to which NBSF and JFK planned to communicate with every student and family about the steps needed to move to their postsecondary plans; and C. advised NBSF on policies related to credit attainment to prevent future findings. This report summarizes the LDOE findings and corrective action steps. II. Findings A. Assessment of the extent to which NBSF and JFK were completing an accurate assessment of each student’s graduation status The LDOE reviewed records for every student in the Class of 2019, using policies--particularly those that pertain to credit attainment and end-of-course (EOC) test requirements--established by the state Board of Elementary and Secondary Education (BESE) to guide their determinations. JFK provided the LDOE with a document that listed 155 students who participated in the graduation ceremony. An additional document was provided to the LDOE including 23 students who were not included on the graduation ceremony list. A total of 178 student records were reviewed as part of the ​2018-2019 senior cohort​ at JFK. Of those 178 students: ● ● 155 students participated in the 2019 graduation ceremony based on the list provided by JFK; 85 students who participated in the graduation ceremony had fulfilled graduation requirements as established by BESE; ● ● ● ● 70 students who participated in the graduation ceremony did not meet at least one graduation requirement and must address at least one deficiency in order to graduate; 14 seniors who participated in the graduation ceremony did not meet EOC requirements; 23 seniors did not participate in the graduation ceremony and did not meet graduation requirements; 81 seniors participated in 154 GradPoint courses. GradPoint is an online learning platform that hosts curriculum focused on intervention and remediation strategies. The needs of the 70 students who participated in the graduation ceremony and did not meet credit attainment and/or EOC requirements are summarized in Table 1. Table 1. Deficiencies Credits needed Passed all tests Need to test or retest Total Students 0 <10 <10 <10 .5 <10 <10 <10 1 19 <10 23 1.5 10 <10 10 2 <10 <10 11 2.5 <10 <10 <10 3 <10 <10 <10 3.5 <10 <10 <10 More than 3.5 <10 <10 <10 Totals 56 14 70 According to information in the GradPoint online learning platform, JFK staff placed 81 seniors in at least one GradPoint course. According to the local transcript system, there were several changes to final grades in face-to-face classes after the school’s deadline for submitting grades. As part of its review, NBSF established a set of business rules to use to determine which students would receive Carnegie credit for the work completed in the online platform and which students would receive credit for the courses in which grades had been changed. B. Assessment of the extent to which NBSF and JFK have communicated with every student and family about the steps needed to move to their postsecondary plans LDOE representatives have communicated with NBSF leaders and the consulting team from TenSquare throughout the review process. The LDOE assessment of how NBSF and JFK have communicated with families is ongoing. To date, NBSF has communicated with families via phone calls, text messages, and home visits to inform students of their graduation statuses and to share plans of action for non-graduates. C. Policies related to credit attainment to prevent future findings During the early stages of its review, LDOE representatives met with NBSF leaders and the consulting team from TenSquare to provide guidance on state policies regarding credit attainment and best practices for credit recovery. Based on those conversations, the LDOE recommended that NBSF and TenSquare clearly articulate business rules for determining how they would be making decisions about credit attainment. The LDOE reviewed the extent to which NBSF and TenSquare applied business rules to the students with records in GradPoint. The LDOE also assisted NBSF staff as they verified student information in their local transcript system. III. Corrective Action Steps and Resources Based on the ​review of the policies and practices pertaining to credit attainment and graduate completion records at JFK, the LDOE is stipulating the following corrective actions for NSBF. A. Pupil Progression Plans​: ​Submit a new pupil progression plan to the LDOE on or before August 31, 2019. Every public school in Louisiana must have a​ ​pupil progression plan​ (PPP) that adheres to​ ​Bulletin 1566: Pupil Progression Policies and Procedures​. These plans must clearly outline the guidelines local education agencies (LEAs) have established for the promotion and retention for each student. Prior to the start of the 2019-2020 academic year, this charter management organization (CMO) should either address the gaps in their current PPP with an addendum, or create an entirely​ ​new PPP​. B. Individual Graduation Plans​:​ Create new and/or revise all individual graduation plans for students enrolled in the 2019-2020 school year by October 1, 2019. School personnel must ensure that students plan for success in high school and beyond. As such, students must develop an​ ​Individual Graduation Plan​ ​(IGP) with the support and guidance of their families and the school counselor(s). When applicable, the student’s Individualized Education Plan​ (IEP) team shall assist in developing the IGP. The plan informs coursework selections for the following academic year and guides secondary and postsecondary decisions. C. Online Learning and Credit Recovery:​ Adopt a clear credit recovery policy that aligns with Section 2324 of Bulletin 741 and provide to the LDOE by August 31, 2019. JFK utilized GradPoint and Rosetta Stone, ​an education technology software company that develops language, literacy and brain-fitness software,​ for instruction in both credit recovery programs and for full courses. In order to provide meaningful computer-based instruction, the NBSF should: ● ● ● ● Research best practices for distance learning and credit recovery; Provide meaningful professional development in asynchronous learning; Use appropriate courses for delivering online instruction, including sequential or virtual course for online instruction and prescriptive coursework for credit recovery; and Hire appropriate, qualified teachers to monitor progress and provide instruction. Credit recovery is an instructional program for courses students have already failed, yet several NBSF students were enrolled in the credit recovery program for classes they had never taken. NBSF should follow state guidelines as they create credit recovery policies. Specific implementation recommendations for credit recovery include: ● ● ● ● Labeling credit recovery courses on the official student transcript; Using a BESE-approved ​Course Choice​ provider for credit recovery courses; Staffing credit recovery courses with teachers who are certified in the appropriate subject area; Awarding credit to students based on assessments that have been approved by the school system and using state assessments when applicable; and ● Limiting the number of high school credits any student may earn in credit recovery throughout his or her high school experience to six credits. D. Graduation Requirements: ​Enroll all ninth and 10th grade students in a common set of foundational courses and adopt procedures to ensure that all 11th and 12th grade students have access to the courses they need to complete their chosen graduation pathway. NBSF must provide the LDOE the following: ● ● ● A copy of the school’s master schedule, course titles, and course codes bu August 2, 2019, refraining from labeling courses in a way that could possibly mislead families or outside entities about the level of rigor; Evidence of training for all administrators and counselors on the requirements for both graduation pathways by August 31,2019, including courses, credentials, and assessments; and A list of all credit recovery/online course providers that will provide courses to students in the 2019-2020 school year by August 31, 2019. Refer to ​Louisiana’s High School Planning Guidebook​ for information on course requirements and graduation pathways. The core course requirements provide students with the foundation they need to be successful in either graduation pathway. Without these courses, students are in danger of not graduating in four years. During the LDOE review, it was evident not all JFK students were enrolled in the appropriate foundational skills courses. For instance, several students did not have an el​igible health education credit that met graduation requirements or access to a biology course in 2017-2018. NBSF staff must build a deep knowledge of the different high school graduation pathways. The state has aligned the diploma pathways to Taylor Opportunity Program for Students (TOPS) scholarship requirements as a way to ensure all students have the same opportunities to earn the merit-based TOPS award. The TOPS University Pathway prepares students who plan to continue their education at a college or university. The TOPS Tech Pathway prepares students for work, as well as for various postsecondary education and training opportunities. With the support of their families and school staff, students select a pathway at the end of 10th grade as part of the IGP process. Schools must ensure that this selection appears on every student’s IGP and provide evidence that the student’s parent or guardian supports the selection. The records at JFK indicated that all students were pursuing a university diploma. However, some student transcripts showed coursework that did not align with the TOPS University Pathway. For example, some students took Algebra I Part 1 and Algebra I Part 2, yet these course(s) do not meet the requirements for a university diploma. E. Services and Supports for Students with Special​ Needs​: For the 2019-2020 school year, JFK will be labeled Tier III - High Risk for Individuals with Disabilities Education Act (IDEA) Monitoring and receive on-site monitoring by LDOE staff. Students with disabilities have diploma options that are specific to their individual needs: ● ● High school students who are eligible under Act 833 can pursue a standard high school diploma by meeting standard graduation requirements through alternate means; and High school students who take LEAP Connect can pursue a diploma pathway by meeting alternate requirements. Based on information in the Special Education Reporting (SER) system, several JFK students had outdated IEPs. Many IEPs were poorly written and/or lacked appropriate goals. To ensure students with special needs receive appropriate services, the LDOE recommends these immediate action steps: ● ● ● Identify all students with exceptionalities; Conduct a thorough review of all IEP goals to ensure they are current and appropriately aligned with student needs; and Ensure any student who is eligible under Act 833 has appropriate course goals that follow policy that have been created within required timelines and meet guidelines on equivalency. F. Uniform Grading, Data Collection, and Submission: The student grading scale should be consistent for awarding Carnegie credit, and uploaded regularly into LDOE data systems. Several student academic records had not been uploaded into LDOE data systems. NBSF must: ● ● ● ● ● Publish a uniform grading scale in the Parent and Student Handbook and provide a copy to the LDOE by August 31, 2019; Install updates to the local student information system and provide evidence of the updates to the LDOE by August 2, 2019; Verify settings in the local transcript system to ensure grades are weighted and calculated correctly and provide the LDOE with a copy of the course code options from the local system by August 2, 2019; Develop a process for appropriately coding traditional courses and credit recovery courses in the data systems and share the process with the LDOE by August 31, 2019; Cease the practice of granting AP credit unless the student has completed the entire AP course; ● ● Conduct a thorough review of all student transcripts for students in grades 9 through 11 before the start of the 2019-2020 academic year to ensure they accurately reflect the credit a student has earned; and Cross reference all records and correct any discrepancies by August 31, 2019, including: ○ Student enrollment ○ Student Transcript System ○ Student Information System ○ Special Education Reporting ○ Cumulative folders ○ Online learning management system G. Summer School​: ​Provide a secondary summer school option for all students who need additional credit and/or remediation to address diploma requirement deficiencies and to stay on track for a timely graduation. NBSF must: ● ● ● Offer summer school so students may schedule courses to enrich their experiences, take new subjects, and/or address deficiencies; Organize and operate summer programming under the administrative and supervisory control of the newly assigned Chief Executive Officer; and Provide summer school remediation and retesting opportunities as outlined in Bulletin 1566 Pupil Progression Policies and Procedures. H. Postsecondary Planning:​ Work with the students who have not yet met their graduation requirements and provide families with options that will allow students to make progress toward their postsecondary plans as they complete high school requirements. NBSF must immediately: ● ● ● Communicate with all 2019 seniors not meeting graduation requirements to identify their postsecondary plans; Provide documentation on student status and communicate with postsecondary institutions on behalf of students who may obtain a diploma this summer to assist with the possibility of conditional enrollment; and Ensure all seniors have access to financial aid planning opportunities.