2019 charter renewal: vanguard classical school · 2019. 6. 19. · • singapore math is very...

2019 Charter Renewal: Vanguard Classical School

Presented by:APS Office of Autonomous Schools

Jeff Park, Interim Executive DirectorMackenzie Khan, Director of Charter Schools

Every Student Shapes a Successful Future 1

Every Student Shapes a Successful Future

Presentation Purpose

▪ Why is this topic on the board agenda?▪ To inform the Board of important changes to the APS Charter Renewal process

▪ To provide explanation and context for a current charter proposal: Vanguard Classical School – East & West (Renewal)

▪ What are we asking the board to do with this information? ▪ Take into consideration the recommendation of the Superintendent, and make a

decision during the March 5 Board Meeting

▪ How is this linked to the Strategic Plan, Vision, Mission, goals & core beliefs? ▪ The District carries out its responsibilities as a quality charter school authorizer by

maintaining high standards for schools, upholding school autonomy and protecting student and public interests

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Presentation Agenda

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▪ School Overview

▪ Annual Performance Reviews – Vanguard East & West

▪ Renewal Process: Timeline & Interview

▪ Evaluation Report by Section

▪ Additional Considerations

▪ Recommendation

▪ Presentation by Vanguard Classical School


Vanguard Classical School

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SPF RatingsVanguard West Vanguard East

2012-13 Performance2013-14 Performance2014-15 Performance2015-16 Improvement2016-17 Performance2017-18 Performance

2012-13 N/A2013-14 N/A2014-15 N/A2015-16 Performance2016-17 Performance2017-18 Performance

ABOUT• 144 Employees• 1130 Students, grades K-12• 1st Graduating Class in 2017• 2 campuses: West Campus - K-8, opened 2007

East Campus – K-12, opened 2014• Supported by Service Agreement with ACCO for HR, Finance, Risk

Management, Nutrition Services, and Health Services



Vanguard Classical School - WEST

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801 Yosemite St.Denver, CO 80230 | 303-691-2384(Neighborhood: NW Aurora/Denver border)

vanguardclassical.org

YEAR OPENED: 2007CONTRACT EXPIRES: 2019

GRADES SERVED: K-8

LEADERSHIP

Terry Glen, Principal West Campus

STUDENT DEMOGRAPHICS

GENDER

Male 46.7%

Female 53.3%

HISTORICALLYUNDERSERVED

FRL 80.8%

ELL 38.8%

SPED 9.0%

http://www.vanguardclassical.org/


Vanguard Classical School - EAST

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17101 East Ohio Dr.Aurora, CO 80017 | 303-338-4129(Neighborhood: NW Aurora)

vanguardclassical.org

YEAR OPENED: 2013CONTRACT EXPIRES: 2019GRADES SERVED: K-12

LEADERSHIP

Angela Schendel Keedy, Secondary PrincipalEmily Van Luit, Primary Principal

STUDENT DEMOGRAPHICS

GENDER

Male 42.2%

Female 57.8%

HISTORICALLYUNDERSERVED

FRL 62.9%

ELL 25.0%

SPED 7.9%

http://www.vanguardclassical.org/


Annual Performance ReviewsVanguard East & West

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Annual Performance Review Summary

ACADEMIC PERFORMANCE

Educational Program MEETS STANDARD

State SPF Rating PERFORMANCE PLAN

FINANCIAL PERFORMANCE

Short-Term Financial Health MEETS STANDARD

Long-Term Financial Health MEETS STANDARD

Audit Review*INTENSIVE APPROACHING STANDARD

ORGANIZATIONAL PERFORMANCE

Governance, Reporting & StaffAPPROACHING STANDARD

School Environment MEETS STANDARD

Enrollment MEETS STANDARD

Meets Standard:All indicators in the section have been met.

Approaching Standard:More than 75% of indicators in the section have been met.

Does Not Meet Standard: 50-75% of indicators in the section have been met.

Falls Far Below Standard:Less than 50% of indicators in the section have been met.

*Each charter school undergoes either a STANDARD or INTENSIVE Internal Audit Review by APS. INTENSIVE reviews are performed for schools in Y1, renewal year, or if the District has reasonable concern to conduct a more thorough review of the school.


Academic Performance

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Academic Performance: VCS WEST

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ELEMENTARYPERFORMANCE

INDICATORS

MEDIAN GROWTH

PERCENTILE

SPF RATING

English Language Arts Growth 50.0% MEETS

Math Growth33.0%

DOES NOT MEET

ELP Growth 68.0% EXCEEDS

MIDDLE PERFORMANCE

INDICATORS

MEDIAN GROWTH

PERCENTILE

SPF RATING

English Language Arts Growth 59.0% MEETS

Math Growth 58.5% MEETS

ELP Growth 61.0% MEETS

All data presented here is taken from the school’s School Performance Framework (SPF) issued by the

Colorado Department of Education.

Academic Achievement Elementary - DOES NOT MEETMiddle - APPROACHING

Academic Growth Elementary - APPROACHINGMiddle - MEETS

Overall SPF points earned 53.8/100 PERFORMANCE PLAN

OVERALL SPF RATING


Academic Performance: VCS EAST

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ELEMENTARYPERFORMANCE

INDICATORS

MEDIAN GROWTH

PERCENTILE

SPF RATING

English Language Arts Growth 46.0% APPROACHING

Math Growth 37.0% APPROACHING

ELP Growth 61.0% MEETS

MIDDLE PERFORMANCE

INDICATORS

MEDIAN GROWTH

PERCENTILE

SPF RATING


Math Growth 45.0% APPROACHING

ELP Growth 43.0% APPROACHING

HIGHPERFORMANCE

INDICATORS

MEDIAN GROWTH

PERCENTILE

SPF RATING


Math Growth 58.0% MEETS

ELP Growth N/A N/A

Academic Achievement Elementary - APPROACHINGMiddle - APPROACHINGHigh - APPROACHING

Academic Growth Elementary - APPROACHINGMiddle - APPROACHINGHigh - MEETS

Overall SPF points earned 54.2/100 PERFORMANCE PLAN

OVERALL SPF RATING


School Response: Academic Review

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East Response:

No response provided

West Response:

Educational Program• Singapore math; Title II funds have been allotted toward staff development through a Singapore

Coach

SPF Rating - Math Growth 33.3% in Elementary; Does Not Meet• Singapore math is very concrete in the beginning years in order to develop full understanding of

math concepts. In middle school years, this program starts to align with state testing.

• School increased Singapore math coaching in the 2018/19 SY through a Singapore coach;

identified Title I elementary students (grades 3-5) are provided with additional math interventions

to increase growth and achievement. In addition, school wide morning work is math focus.


English Language Arts: VCS WEST

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APS evaluates a charter school’s academic performance using several key indicators, including student results on standardized assessment from the previous academic year. In the charts below, this charter school’s academic performance is compared against Aurora Public Schools as a whole. If the school’s performance or growth (either overall or by grade grouping) is less than the district’s, the group is highlighted in red.

Data points in the Achievement table are presented through Mean Scale Scores, and data points in the Growth table are presented through Median Growth Percentiles. More information about the calculation of these data points is available through the Colorado Department of Education.

GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 727.7 725.6

6-8 735.3 726.5

9-12 N/A N/A

GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 50.0% 49.0%

6-8 59.0% 50.0%

9-12 N/A N/A

ACADEMIC ACHIEVEMENT ACADEMIC GROWTH

ENGLISH LANGUAGE

ARTS


English Language Arts: VCS EAST

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APS evaluates a charter school’s academic performance using several key indicators, including student results on standardized assessment from the previous academic year. In the charts below, this charter school’s academic performance is compared against Aurora Public Schools as a whole. If the school’s performance or growth (either overall or by grade grouping) is less than the district’s, the group is highlighted in red.

Data points in the Achievement table are presented through Mean Scale Scores, and data points in the Growth table are presented through Median Growth Percentiles. More information about the calculation of these data points is available through the Colorado Department of Education.

GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 738.3 725.6

6-8 728.9 726.5

9-12 419.3 408.7

ACADEMIC ACHIEVEMENT

GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 46.0% 49.0%

6-8 45.0% 50.0%

9-12 45.0% 35.0%

ACADEMIC GROWTH

ENGLISH LANGUAGE

ARTS


Math & Science: VCS WEST

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GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 710.3 719.7

6-8 716.9 716.4

9-12 N/A N/A

GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 33.0% 48.0%

6-8 58.5% 50.0%

9-12 N/A N/A


MATH

GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 528.7 532.0

6-8 523.6 504.4

9-12 N/A N/A

GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 N/A N/A

6-8 N/A N/A

9-12 N/A N/A

SCIENCE


Math & Science: VCS EAST

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GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 729.0 719.7

6-8 717.7 716.4

9-12 415.4 408.2

GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 37.0% 48.0%

6-8 45.0% 50.0%

9-12 58.0% 46.0%

GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 556.3 532.0

6-8 539.2 504.4

9-12 597.4 538.6

GRADE LEVELS

THIS SCHOOL

AURORA PUBLIC

SCHOOLS

3-5 N/A N/A

6-8 N/A N/A

9-12 N/A N/A

MATH

SCIENCE


Overall Financial Performance

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The Financial Performance section uses key data to assess the financial health and viability of the charter school by analyzing the current state of the school while taking into account the school’s financial trends over a period of three years. The indicators are designed to provide a lens into a school’s overall financial situation and provide insight into historic trends and future viability.

Information for this section is pulled from the school’s 2017-2018 independent audit.

3-YEAR AVG.

FY18 VALUE

What is significantly below standard?

Operating Margin Ratio

0.03 0.04 Less than 0

Asset Sufficiency Ratio

2.01 2.42 Less than 1

Change in Fund Balance Ratio

N/A 0.65Less than 0 for all 3

years

Average Days Cash on Hand

38.67 48.40 Less than 30 days

3-YEAR AVG.

FY18 VALUE

What is significantly below standard?

Net Position(% of Revenue)

6.40% 9.11% Less than 0%

Operating Reserve Ratio

0.07 0.09Less than 0.0192

(1/52, or one week of reserves)

Debt Burden Ratio N/A N/A Less than 1.0

SHORT-TERM METRICS

LONG-TERM METRICS


Financial Health: Short-Term Metrics

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Operating Margin Ratio (OMR) indicates the amount added to reserves for every $1 in total general fund gross revenue.

Asset Sufficiency Ratio (ASR) indicates the coverage of general fund assets to general fund liabilities.

Change in Fund Balance Ratio (CFBR) indicates the change in the fund balance of the general fund from one year to the next in relationship to the prior year fund balance.

Average Days of Cash on Hand is the number of days a school could operate without receiving additional money (calculated as the school’s total cash divided by the average daily cost to run the school).

OPERATING MARGIN RATIO ASSET SUFFICIENCY RATIO


Financial Health: Long-Term Metrics

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Net Position (% of Revenue) measures how much a school is worth as a percentage of their total annual revenue (calculated as net position divided by total revenue).

Operating Reserve Ratio (ORR) indicates the amount the general fund ending fund balance will cover of the current year general fund expenditures, including transfers.

Debt Burden Ratio (DBR) indicates the coverage of revenue of fund(s) paying debt service to the annual principal and interest payments, including leases.

NET POSITION (% OF REVENUE)

OPERATING RESERVE RATIO


Financial Summary

20Every Student Shapes a Successful Future

Did the school receive an unqualified audit opinion? YES

Was the audit free of any significant findings, notes, weaknesses, or other areas of concern?

NO

Have the audit findings from the prior year been addressed or resolved?

N/A

Did the school maintain the TABOR reserve? YES

The annual Colorado Department of Education Letter was free of any comments.

Pending

Is the school demonstrating short-term financial health? YES

Is the school demonstrating long-term financial health? YES

Is the school meeting financial reporting and compliance requirements? YES

STANDARD REVIEW METRICS2017-18

Total Assets $5,442,418 $14,304,356 $11,567,405

Total Liabilities $13,809,770 $28,891,972 $33,529,985

Net Position $(8,367,352) $(14,587,616) $(21,962,580)

Total Revenue $10,074,400 $10,622,196 $11,768,571

Total Expenses $11,785,029 $16,842,460 $18,469,663

Changes in Net Position

$(1,710,629) $(6,220,264) $(6,701,092)

FY16 FY17 FY18

Financial Statement Finding: Significant Deficiency in Internal Control over Financial Reporting. Ability Connection of Colorado, Inc. (ACCO), the School’s Founding Organization, billed the school $465,603 of expenses that were not delineated in the support services nor lease agreements between the two entities. There was no evidence of review and approval of these amounts by the board of directors.

NOTES


APS Internal Auditor’s Comments And Findings 2017-18


Maintained financial transparency NO ISSUES NOTED

Review board meeting minutes NO ISSUES NOTED

Each quarter's spending rate, as listed in the District's Quarterly Financials, is at or under 100.0 percent.

NO ISSUES NOTED

Bank statements agree to GL and financial template. Reconciliations are prepared on a timely basis and proper documentation is maintained.

NO ISSUES NOTED

Finance committee follows appropriate protocols NO ISSUES NOTED

Perform walk-through of financial transactions for understanding of internal controls (Main Office Operation) RECOMMENDATION

Perform walk-through of financial transactions for understanding of internal controls (Deposit) RECOMMENDATION

Maintain and retain all applicable financial records in accordance with all applicable Federal, State, and Local laws, rules, and regulations

NO ISSUES NOTED

APS INTERNAL AUDITOR’S COMMENTS AND FINDINGS 2017-18Aurora Public Schools also performed an

INTENSIVE review of this school in the area of finance for 2017-2018. Information regarding the school’s financial health comparatively to other APS authorized charter schools and the district will be provided through a Mid-Year Report in

December 2018.




INDICATOR: Perform walk-through of financial transactions for understanding of internal controls (Main Office Operation)

OBSERVATION 1

Funds are stored in desks, drawers, or cabinets in multiple areas of both campuses.

RECOMMENDATION 1

All funds should be secured in the safe before and after processing. The school should have their own safe to use if they are unable to use the one provided by Ability Connection Colorado. This will provide a central and secure place for the money before the deposit has been created for Ability Connection Colorado as well as for any of Vanguard Classical School’s change fund and petty cash.

RECOMMENDATION 2

Safe access should be limited to certain key individuals at the school.





OBSERVATION 2

The process for collecting, documenting, and processing funds are different for each campus.

RECOMMENDATION 1

A unified process should be developed for both East and West Campus on collecting, documenting and processing funds.

RECOMMENDATION 2

Records should be secured in a central location on site and organized in a logical manner.

RECOMMENDATION 3

There should be at least two individuals who count money for every deposit. The counters should be restricted to the individuals that are assigned by Vanguard administration, with alternates if needed.

RECOMMENDATION 4

Vanguard procedures should be reviewed annually to verify that there are no contradictions, and matches Vanguard board approved policies.





OBSERVATION 3

Receipts for incoming funds are not given out on a consistent basis.

RECOMMENDATION 1

Incoming money should have a receipt filled out and given to the payor and/or the individual who brings the money to the main office.

RECOMMENDATION 2

Each deposit should have corresponding receipts and any supporting documentation to match the funds associated with the deposit. This documentation should be stored together and secured in a central location.




INDICATOR: Perform walk-through of financial transactions for understanding of internal controls (Deposit)

OBSERVATION 4

Deposits that have been completed by Vanguard Classical School staff to be processed by Ability Connection Colorado do not always match the deposit log that is created by Ability Connection Colorado.

RECOMMENDATION 1

Both campuses should develop a unified process for documenting the outgoing deposits before Ability Connection Colorado receives custody of money.

RECOMMENDATION 2

A reconciliation should be completed at least once a month between Vanguard’s deposit logs, Ability Connection Colorado’s deposit logs, and the bank statements. Discrepancies should be addressed as soon as it is discovered.




INDICATOR: Perform walk-through of financial transactions for understanding of internal controls (Deposit)

OBSERVATION 5

Checks are not restrictively endorsed ‘For Deposit Only’ when received.

RECOMMENDATION 1

Each campus should restrictively endorse each check ‘For Deposit Only’ when it is received.


VCS Implementation of APS Recommendations for 2016-2017

Audit


2016-2017 OBSERVATION 1

There are two sets of policies or regulations between Ability Connection Colorado and Vanguard Classical School. It was later identified that the official policies that should be followed were Ability Connection Colorado.

2016-2017 RECOMMENDATION 1

It is recommended that policies are regularly reviewed and updated by management and the Board. Staff should be trained on official policies and regulations. Any other documents, such as manuals, should reference the official policies.

2018 IMPLEMENTATION 1

PARTIALLY IMPLEMENTED


Vanguard Classical School staff uses a purchase requisition form to make purchases. For purchases under $500.00, policy dictates that Director approval is required. There were instances in which purchases were initiated and approved by the Director.


It is recommended that a process for secondary review and sign-off occurs on all purchases. Implementation of segregation of duties would limit error or fraud.


PARTIALLY IMPLEMENTED


Some purchase requisition forms were incomplete and did not have all required information filled out, did not have a supervisor or director signature on the form, or did not show evidence of review. Some purchase requisition forms over $500.00 were not signed by the president or CEO.


It is recommended that all purchase requisition forms be filled out completely to maintain an audit trail as well as comply with ACCO's procurement policy.


NOT IMPLEMENTED


VCS Implementation of APS Recommendations for 2016-2017

Audit



Some invoices did not have a purchase requisition form filled out.


It is recommended that every purchase have a purchase requisition form filled out to maintain an audit trail as well as comply with ACCO's procurement policy.


IMPLEMENTED


ACCO oversees Health Services for Vanguard. However, funds from Vanguard are used to pay a portion of the health supplies.


It is recommended that the Director of Vanguard Classical Schools review any purchases that receive funding from Vanguard Classical School to ensure that the items purchased are used for Vanguard students.


NOT IMPLEMENTED


School Response: Financial Review


East Response:No response provided

West Response: No response provided


Overall Organizational Performance


GOVERNANCE, REPORTING & STAFF

Is the school complying with governance requirements? NO

Is the school holding management accountable? YES

Is the school complying with reporting requirements? YES

Is the school meeting teacher and other staff credentialing requirements? YES

SCHOOL ENVIRONMENT

Is the school complying with facilities and transportation requirements? YES

Is the school complying with health and safety requirements? YES

Charter schools are required to meet certain regulatory requirements and responsibilities as established by applicable state and federal law and their charter contracts. The Organizational Performance section reports the school’s overall performance in the year reviewed in fulfilling legal requirements and other indicators relevant to organizational health and performance.

Governance Requirements:Governing Board minutes do not reflect details of votes, no evidence provided that school was in compliance with conflict of interest policy due to lack of detail in minutes. Additionally, service agreements made between Vanguard and ACCO are considered conflicting interest transactions and the Board chair stated in an interview she has never recused herself from voting, nor is there any evidence provided that this agreement has been voted on at a Board meeting. Some policies the school is operating under are policies of ACCO and not of the school.

NOTES


Vanguard Enrollment


OCT. COUNT ENROLLMENT TOTAL

744

PROJECTED ENROLLMENT TARGET

749

ACTUAL % OF ENROLLMENT TARGET 99%

MEETS STANDARD

East Campus:

West Campus:

OCT. COUNT ENROLLMENT TOTAL

509

PROJECTED ENROLLMENT TARGET

490

ACTUAL % OF ENROLLMENT TARGET 104%

MEETS STANDARD

>95% - MEET; 85-94% APPROACHING; <85% DOES NOT MEET


School Response: Organizational Review

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East Response:


Governance Reporting & Staffing: ● Board Policies, Bylaws, Conflict of Interest and Board Composition/Membership

requirements have been specific target goals to meet since being informed of the

conditional resolution expectations early 2018. The Board has taken intentional, rigorous

action steps to ensure compliance in the above stated areas. In addition, where potential

conflicts exist, VCS Board Member recuse themselves from voting; all votes are recorded

by name in the Minutes.

West Reponse:No response provided


2019 Renewal Process: Timeline & Interview

33


2019 Renewal Process: Timeline of Events


October 5: Renewal Application Submitted to APS

October: Application reviewed by APS committees

November 7: Applicant Presentation & Formal Interview

November: School provides written responses to follow-up questions; APS committee ratings and feedback compiled

February 19 & March 5: Recommendation is presented to APS Board for review; APS Board rules on renewal application


Interview Summary


Vanguard was given one hour to present to the APS Interview Panel regarding information about their schools.

The presentation provided the interview panel with an overview of the school, historical data and information, and shared photos and successes of the school during its most recent charter term.

Vanguard was given interview topics and some of the interview questions prior to the interview, and were also able to address some of these questions during the presentation.

Vanguard was also given the opportunity to provide written responses to interview questions not asked during the interview.


Renewal ApplicationEvaluation Report by Section

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Section Title Overall Rating Rationale

Educational Program

Adequately Addresses

Criteria

Applicant provided a synopsis of the school's mission and educational program and no academic performance conditions were placed on the school during the most recent charter term.

Organizational Structure


Criteria

This section is rated as adequately meets criteria as the applicant did address all major components. It is important to note that although responses addressed the section, they were lacking in detail and required clarification through the interview process and written response, most notably questions around governing board membership and processes for mitigating conflicts of interest.

Financial Management & Oversight

Partially Addresses

Criteria

This section was overall lacking in reflection/analysis and due diligence on behalf of the applicant. No RFP was conducted or documented processes made available. No plans to evaluate the service provider (ACCO). Additionally, no evaluation of the provider has been done in the past, and there are currently no concrete plans in place to move forward with an RFP per the interview. The applicant included no description or information on how the school will ensure financial solvency and no support or documentation was provided for costs for the service agreement. When asked during the interview, the school responded that the district could gather this information themselves and therefore it was not provided.

SCHOOL OVERVIEW




Academic Performance


Criteria

School adequately addressed all criteria in this section and provided additional data and contextual information through the application and clarification through the interview.

Organizational Performance

Partially Addresses

Criteria

Responses provided in this section were lacking in detail, and clarification was focused around organizational performance during the applicant interview. Actions the school made to improve organizational soundness were mentioned, but a true analysis was not present and limited evidence and supplemental data was provided.

LOOKING BACK: Record of Performance



Section Title Overall Rating

Rationale

Financial Performance

Does NotAddress Criteria

This section was originally rated Does Not Meet Criteria due to the fact that the school did not submit all elements within the section (only 1/4 elements were initially addressed). The school was given another opportunity to submit all required elements. APS still has significant concerns with the content of the submissions. Financial performance expectations were provided by Vanguard but do not include specific plans or action steps to reach them. For example, the school mentions they plan to become financially autonomous from ACCO, but no plan is included on how this would be accomplished nor is this demonstrated in the provided budget. In addition, the school states they will "enhance facilities" as one of their financial performance expectations, but no other details about this are provided. In the school's most recent audit, Vanguard's auditors reported a finding classified as a "Significant Deficiency in Internal Control over Financial Reporting" in which ACCO billed Vanguard Classical Schools $465,603 of expenses "...that were not delineated in the support services nor lease agreements between the two entities" and this did not include any evidence of review or approval by the Vanguard Board. In the renewal application response in this section, Vanguard minimized this finding to be "the result of a reporting error" with no associated costs and no plans on how the school would mitigate this issue in the future. Vanguard discusses a current challenge being declining enrollment, but the budget submitted by the school in the "Looking Ahead" section anticipates increased enrollment year after year over the next 5 years. The school describes how they have addressed and complied with all recommendations from the 2016-2017 APS Internal Audit, but sufficient evidence of this is not provided outside of the information already held by APS which does not show full compliance according to APS Internal Audit. This narrative also does not address how this information contributes to the school's overall financial performance. Vanguard discusses in this section that the school conducted an evaluation of the service contract with ACCO via use of a survey, but no information was provided around the results of the survey or how the school plans to use this information going forward in their evaluation of the relationship with ACCO. In addition, the District later asked a follow up question regarding the survey via email, and Vanguard stated that the survey was only administered to two groups: staff who receive services (Administrators) and those that provide services (ACCO) for both schools. At the time of the survey, Vanguard only employed three administrators and without clarification, it is uncertain who specifically from ACCO participated in the survey. It appears this act was limited to a small group of individuals and potentially those with conflicted interests. Lastly, Vanguard stated in this section that the "VCS Board developed and completed an RFP" with regard to its service provider, yet in the interview, the school stated that the RFP was never fully completed and no specific plans are in place to conduct one going forward.

LOOKING BACK: Record of Performance (cont.)




Educational Plan Adequately Addresses

Criteria

A realistic enrollment projection table was provided and anticipated changes and improvements regarding the schools' educational program were explained in detail and clarified through the interview.

Organizational Plan

Partially Addresses

Criteria

While the applicant did provide a response to this section, it was very limited and lacking in detail. Clarification on some items were brought up during the applicant interview. Most concerning, it does not appear that the school has true intentions of continuing goals set in place in the previous year to evaluate the service provider and conduct an RFP process. Per reviewer feedback, there was no evidence that actions made by the school aligned to goals or expected outcomes set previously.

LOOKING AHEAD: Plans for Next Charter Term



Section Title Overall Rating

Rationale

Financial Plan Does NotAddress Criteria

This section was originally rated Does Not Meet Criteria due to the fact that the school did not submit all elements within the section. The school was given another opportunity to submit all required elements. APS still has significant concerns with the content of the submissions. The school was given a second opportunity to provide a budget narrative since it was not originally provided with the initial renewal application submission. While a budget narrative was later provided, it does not clarify or support assumptions and there is no impact of proposed modifications provided. Vanguard mentions that they have pursued plans to become financially autonomous from ACCO but there is no demonstration of this in the narrative or budget (showing steps towards independence through additional revenue outside of PPR or cuts in expenditures). The school mentions they plan to "enhance" facilities but the only details around this that were provided mention replacing carpet and paint. No additional details were provided. This information is critical considering the school's anticipated growth in student enrollment from 1210 to 1450 over the course of the next 5 years. This increase in enrollment is also not supported by plans for additional teaching staff other than teacher coaches. While the school's narrative does state that teacher coaches will be added, there is no reflection of this in the budget. Initially, Vanguard stated in the application that the school did not anticipate any changes in financial management. Upon re-submission of this narrative section, the school did provide information on steps they have already taken to adjust some financial management practices, but no "looking ahead" plans were provided with regard to any financial management changes. Vanguard states they do plan to incorporate school specific financial policies and procedures to enhance internal control, but in another section the school states that "Policies (of ACCO) have now been renamed and accepted by VCS..."

LOOKING AHEAD: Plans for Next Charter Term (cont.)


2018 Resolution Status

42

Resolution Requirement Status per Aurora Public Schools

1. Recording of Votes Met

2. Contract language agreements - COI Met

3. New Bylaws and COI Policy Met

4. Process for community/parent involvement Met

5. Governance Training- League Met

6. Governance Training - CDE Met

7. VCS Board adopts its own suggestions - Clarity in

service agreement, board membership, etc.

Partially Met - Nutrition Services agreement lacks specificity.

Financial services are not spelled out in detail in ACCO service

agreement. School also still has 5 members.

8. Bylaws amendments Met

9. Meets Standard on the Governance, Reporting, and

Staff measure of the Organizational Performance

section of the Annual Performance Review (APR) Not Met

10. Contract language - ACCO Met

11. Vanguard shall provide notification of these

conditions of approval to parents of students

attending Vanguard within thirty (30) days of a

finalized charter contract.

Not Met - Per email from VCS and Facebook, notification to

families did not include conditions or copy of contract, only

message regarding the renewal decision itself.

*CURED*

Vanguard/ACCO Context

43


Ability Connection Colorado (formerly known as CP of Colorado)

Est. 1994

Vanguard Classical SchoolOpened: 2007/2014

Judith Ham, CEOJudith Ham, Board President

since 2007

Syed Ahmed, CFO Syed Ahmed, CFO since 2011 (on record)

Service Agreement

● HR● Finance● Risk Management● Nutrition Services● Health Services


Additional Considerations

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Governance Practice/Conflict of InterestDocumentation and practice demonstrate unilateral decision making by VCS Board Chair and ACCO

CEO, Judy Ham.

● At any given time at least two ACCO employees served on the Vanguard Board. This includes Judy Ham who also serves as the CEO for ACCO. Approval of ACCO contracts would necessarily require recusal of ACCO employees if Vanguard Board approval would have taken place in order to avoid a conflict of interest.

○ When asked directly how conflict of interests are dealt with, Judy Ham indicated that she would recuse herself from those votes. When asked how often does that occur, Judy Ham indicated that she has never had to recuse herself from a vote despite the ongoing contracts and financial transactions that occur between Vanguard and ACCO.

● At the time that Service Agreement was adopted the Vanguard Board consisted of only two non ACCO Board members who were handpicked by Judy Ham shortly before the vote. See Vanguard Board Meeting minutes from September 13, 2018 as Attachment #17 and a letter from Vanguard’s attorney explaining this vote is attached as Attachment #18.

● In addition to not having Vanguard Board authority to enter in to the agreements, the ACCO agreements appear to be unilaterally approved and executed by Judy Ham as Vanguard Board President.



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Governance Practice/Conflict of Interest(Cont.) Documentation and practice demonstrate unilateral decision making by VCS Board Chair

and ACCO CEO, Judy Ham.

● Until the 2018-2019 school year, the Executive Director had been an ACCO employee and the CFO for Vanguard acts in the capacity of the CFO for ACCO.

○ Upon reviewing the recruitment process for the current Executive Director it appears the candidate was hand chosen by Judy Ham and presented to the Vanguard Board as the sole option for approval.

○ The ED Selection process evidences that the prior conditions put in place by APS through the last renewal cycle to further empower the VCS Board have failed.

● While Vanguard is currently building out its board membership, historically Vanguard has had difficulty maintaining a full board meaning the two ACCO employee seats and direct appointments have consistently had more influence during the existence of the Vanguard charter.

○ Even under the current buildout all current Vanguard Board members have been specifically selected by Judy Ham and ACCO.

● The Vanguard Bylaws do not allow for term limits of Board members. Where in other charter situations, parents and staff would be able to vote to change Board members, this option is not available to Vanguard parents and staff.



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Financial MismanagementDocumentation casts significant doubt that Vanguard has been able to maintain systems and

structures that adequately account for and protect the expenditure of taxpayer funds.

● Service contracts with ACCO were for one uniform price, there is no designation of funds for any specific area of service. Additional service contracts (i.e. nutrition and CFO) appear to duplicate services set forth in the service agreement with ACCO.

● APS Internal Audit found significant transfers of funds from Vanguard to ACCO. These invoices only list “contractor services” as the description on the invoices, no detail for goods or services rendered are detailed. An external auditor presented the OAS with the same findings. When asked for clarification of these invoices, Vanguard, through their ACCO employed CFO, provided general details of goods and services these payments were intended to compensate. That said, there is no documentation to support these transactions other than backdated explanations and assertions.

● The APS Internal Auditor made numerous recommendations to Vanguard that would assist them in shoring up their financial practices. Vanguard did not fully implement all but one of the corrective recommendations even though they made assertions during the last renewal period that they would do so.

● Vanguard has been operating under ACCO financial policies, having not implemented Vanguard policies until the 2018-2019 school year.



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Financial Mismanagement

Prior to 2018-2019, there is no record that any of the service agreements with ACCO had been

presented to or voted on by the Vanguard Board. Many of the agreements are executed by Judy

Ham who serves both as President of the Vanguard Board and CEO of ACCO.

● The 2007 agreement includes signatures from Judy Ham acting as CEO of ACCO and her daughter acting as Board Secretary on behalf of VCS.

● The 2010 agreement includes signatures from Robert Miller (ED of Vanguard, ACCO employee) on behalf of ACCO and Vanguard principal on behalf of VCS who did not have signatory authority.

● The 2013 agreement includes signatures from Judy Ham acting as CEO of ACCO and Vanguard assistant principal on behalf of VCS who did not have signatory authority.

● The 2014 agreement includes signatures from Judy Ham acting as CEO of ACCO and from Vanguard Board member on behalf of VCS who is also an ACCO employee.



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Record of Formal Complaints/Concerns

APS has received significant complaints regarding the retaliatory environment at Vanguard.

● During the last renewal process, former Executive Director, Peggy Downs, worked cooperatively with the District as it began to review these areas of concern. Shortly after the charter was renewed, Ms. Downs alleges that she was unilaterally terminated by Judy Ham “without prior notice to the VCS Board of Directors and without any due process to the employee regarding any cause for concern.”

○ While the District does not assert that it has control over Vanguard employees, the timing and circumstances of the termination raises a concern that the current Vanguard Board is capable of taking retaliatory action against employees who question Vanguard operations.

● The current Executive Director has explicitly requested that the Office of Autonomous Schools does not communicate directly with any Vanguard staff.

● Numerous Vanguard staff have come together to officially address the Vanguard Board in an attempt to remedy the organizational concerns at Vanguard (attachment #31).

● Attachment #32 is a letter received from Amanda Orihuela, a parent of a Vanguard student and a former teacher. This letter is representative of the types of concerns that have been brought to the attention of the Office of Autonomous Schools.


Recommendation Context

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The District would like to be clear that the deficiencies that will be identified in this recommendation are serious enough to warrant closure of Vanguard Classical School, however there exists important context to consider:

● Vanguard is a performance school ● Vanguard operates on two separate campus serving a large student population● The District does not have concern with the school’s educational programming

The District is extremely sensitive to affecting the student population and teaching staff and does not wish to seek closure if significant reorganization will allow the schools to continue to operate.


Final Recommendation

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It is the recommendation of the Superintendent that the charter

contract between APS and Vanguard Classical School be

renewed for a term of two (2) years conditioned on the

adherence to the benchmarks set forth below. Failure to meet

the benchmarks would constitute a default of the charter

agreement and would constitute grounds for revocation of the

charter without adherence to any cure period.


1. By May 20, 2019, Vanguard will amend its Bylaws and restructure its Governing Board (Board) so that no ACCO employee

may serve on the Board and so that ACCO has no ability to appoint members to the Board. The Board will seat seven (7)

members no later than August 19, 2019, and will include a parent representative from both East and West campuses. The

Board will establish reasonable term limits and assign members to classes by August 19, 2019.

2. All Vanguard board members shall have completed governance training in each of the following ways:

A. Complete all 30 modules provided by Colorado Department of Education; and

B. Participate in annual governance training that covers Best Practices in Charter School Governance and Performance

Management for Charter School Boards through the Colorado League of Charter Schools (League).

3. All new members of the Board shall receive governance training through CDE within three months of joining the Board and

submit evidence of completion to the OAS within 4 months of joining the Board.

4. Vanguard shall earn a rating of Meets Standard on the Governance, Reporting and Staff measure of the Organizational

Performance section of the Annual Performance Review (APR) for each year beginning 2018-19.

5. Payments for expenditures of $5,000 or greater will include a contract and/or an invoice supporting payment as well as

signatures from both the Executive Director and a Principal of Vanguard.

6. Vanguard will hold specified and annually updated agreements for all ACCO services including master services, nutrition

services, and CFO. At least every charter term, as a part of the approval and review of the service agreement between

Vanguard and ACCO for master services, an evaluation of the service provider must be conducted and documented and

shall include a review of fair market values and survey responses from the Vanguard community inclusive of all staff and

families.

7. On or before April 1, 2019, Vanguard will provide an updated 5-year balanced budget along with a budget narrative

acceptable to the District that is based on realistic revenue, including grants, and expenditures assumptions, incorporates

the identified facility costs, and enables the school’s mission to be realized while remaining financially solvent.

8. A policy will be developed and adopted by Vanguard no later than April 1, 2019, that covers approval limits for expenditures

and details the involvement of school based leadership and signatures required for contract execution and payments. The

policy shall encompass single expenditures as well as recurring payments.

9. The Executive Director of Vanguard shall be an employee of the school.

10. On or before June 30, 2019 Vanguard will substantially comply with all recommendations provided by APS Internal Audit

during the two most recent intensive audits conducted during school years 2016-2017 and 2017-2018.


Presentation by Vanguard Classical School


Thank You

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2019 charter renewal: vanguard classical school · 2019. 6. 19. · • singapore math is very...

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