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Iowa State Board of Education Executive Summary February 20, 2020 Agenda Item: High School Program at Hamburg Community School District State Board Priorities: Implementing Iowa’s Academic Standards Creating a Safe and Rich Learning Environment State Board Role/Authority: Iowa Code chapter 256.11 gives the State Board the authority to grant high school accreditation. Presenter(s): Hamburg Community School District (20 minutes) Presenter selected by Hamburg Sidney Community School District (10 minutes) Presenter selected by Sidney Iowa Department of Education (30 minutes) Janet Boyd, Consultant Bureau of School Improvement Eric Heitz, Administrative Consultant Bureau of School Improvement Amy Williamson, Chief Bureau of School Improvement Tom Cooley, Chief Bureau of School Business Operations Attachment(s): One (submitted by the Department) Recommendation: The Department recommends that the State Board hear and discuss this request, then take any action the board deems appropriate. Background: The Hamburg Community School District (CSD) operated as an independent PK-12 district until 2011. In 2011, Hamburg entered into a whole grade sharing with Farragut CSD. Hamburg high school students attended Farragut. Farragut sent middle school students to Hamburg. In 2016, Hamburg began to tuition out all 9-12 grades students to Sidney CSD due to the dissolution of Farragut. Hamburg wishes to reopen a high school program.

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Page 1: Iowa State Board of Education Hamburg High School...Hamburg CSD Feasibility Study Report to the State Board 5 Introduction In January 2020, the Iowa State Board of Education (State

Iowa State Board of Education Executive Summary

February 20, 2020 Agenda Item: High School Program at Hamburg Community School District State Board Priorities: Implementing Iowa’s Academic Standards

Creating a Safe and Rich Learning Environment

State Board Role/Authority: Iowa Code chapter 256.11 gives the State Board the authority to grant high

school accreditation. Presenter(s): Hamburg Community School District (20 minutes)

Presenter selected by Hamburg Sidney Community School District (10 minutes) Presenter selected by Sidney Iowa Department of Education (30 minutes) Janet Boyd, Consultant Bureau of School Improvement Eric Heitz, Administrative Consultant Bureau of School Improvement

Amy Williamson, Chief Bureau of School Improvement

Tom Cooley, Chief Bureau of School Business Operations Attachment(s): One (submitted by the Department) Recommendation: The Department recommends that the State Board hear and discuss this

request, then take any action the board deems appropriate. Background: The Hamburg Community School District (CSD) operated as an independent

PK-12 district until 2011. In 2011, Hamburg entered into a whole grade sharing with Farragut CSD. Hamburg high school students attended Farragut. Farragut sent middle school students to Hamburg. In 2016, Hamburg began to tuition out all 9-12 grades students to Sidney CSD due to the dissolution of Farragut. Hamburg wishes to reopen a high school program.

Page 2: Iowa State Board of Education Hamburg High School...Hamburg CSD Feasibility Study Report to the State Board 5 Introduction In January 2020, the Iowa State Board of Education (State

Hamburg CSD Feasibility Study Report to the State Board 1

February 13, 2020

Hamburg Community School District High School Feasibility Study Report to the Iowa State Board of Education

Page 3: Iowa State Board of Education Hamburg High School...Hamburg CSD Feasibility Study Report to the State Board 5 Introduction In January 2020, the Iowa State Board of Education (State

Hamburg CSD Feasibility Study Report to the State Board 2

State of Iowa Department of Education

Grimes State Office Building 400 E. 14th Street

Des Moines, IA 50319-0146

State Board of Education Brooke Axiotis, President, Des Moines Michael Bearden, Vice President, Gladbrook Bettie Bolar, Marshalltown Joshua Byrnes, Osage Angela English, Dyersville Michael L. Knedler, Council Bluffs Mike May, Spirit Lake Mary Ellen Miller, Wayne County Kimberly Wayne, Des Moines Fez Zafar, Student Member, Clive

Administration Ryan M. Wise, Director and Executive Officer of the

State Board of Education

Division W. David Tilly, Deputy Director Division of Learning and Results

Bureau Tom Cooley, Chief Bureau of School Business Operations Jay Pennington, Chief Bureau of Information and Analysis Services Amy Williamson, Chief Bureau of School Improvement

It is the policy of the Iowa Department of Education not to discriminate on the basis of race, creed, color, sexual orientation, gender identity, national origin, sex, disability, religion, age, political party affiliation, or actual or potential parental, family or marital status in its programs, activities, or employment practices as required by the Iowa Code sections 216.9 and 256.10(2), Titles VI and VII of the Civil Rights Act of 1964 (42 U.S.C. § 2000d and 2000e), the Equal Pay Act of 1973 (29 U.S.C. § 206, et seq.), Title IX (Educational Amendments, 20 U.S.C.§§ 1681 – 1688), Section 504 (Rehabilitation Act of 1973, 29 U.S.C. § 794), and the Americans with Disabilities Act (42 U.S.C. § 12101, et seq.). If you have questions or complaints related to compliance with this policy by the Iowa Department of Education, please contact the legal counsel for the Iowa Department of Education, Grimes State Office Building, 400 E. 14th Street, Des Moines, IA 50319-0146, telephone number: 515-281-5295, or the Director of the Office for Civil Rights, U.S. Department of Education, Citigroup Center, 500 W. Madison Street, Suite 1475, Chicago, IL 60661-4544, telephone number: 312-730-1560, FAX number: 312-730-1576, TDD number: 877-521-2172, email: [email protected].

Page 4: Iowa State Board of Education Hamburg High School...Hamburg CSD Feasibility Study Report to the State Board 5 Introduction In January 2020, the Iowa State Board of Education (State

Hamburg CSD Feasibility Study Report to the State Board 3

Contents Introduction ........................................................................................................................................................ 5

Purpose ......................................................................................................................................................... 5

Feasibility Study Team Members ................................................................................................................... 5

Report Structure ............................................................................................................................................. 5

I. Background .................................................................................................................................................... 6

Previous Feasibility Studies ........................................................................................................................... 6

History of Restructuring and Noncompliance: April 2010 to February 2020 .................................................... 7

Table 1. Timeline of Hamburg: April 2010 to February 2020 .......................................................................... 7

School Size .................................................................................................................................................... 9

II. Department Report ...................................................................................................................................... 10

Conclusions ................................................................................................................................................. 10

Enrollments and Population ......................................................................................................................... 11

Table 2. Certified and BEDS Enrollment for Hamburg: Fall 2015 to Fall 2023 .............................................. 11

Table 3. Hamburg’s Open Enrollment and Tuition Summary: 2000-2001 to 2019-2020 ............................... 12

Table 4. Annual Estimates of the Resident Population: July 1, 2010 to July 1, 2018 .................................... 12

Table 5. Fremont County Workforce: 2016 to 2019 ...................................................................................... 13

Table 6. K-12 Students Eligible for Free and Reduced-Price Lunch by District: 2018-2019 .......................... 13

Educational Programs and Personnel .......................................................................................................... 14

Table 7. Hamburg High School Courses Offered and Taught Prior to Sharing: 2006-2007 to 2010-2011 .... 14

Table 8. Comparison of Proposed Hamburg High School Courses to Courses Offered and Taught at Neighboring Districts .................................................................................................................................... 15

Table 9. CTE Areas and Number of Units Offered by District ....................................................................... 17

Table 10. Iowa School Performance Profile Indicators: 2018 and 2019 ........................................................ 18

Table 11. Percent of Hamburg Students K-3 at Literacy Benchmark: Spring 2015-16 to Fall 2019-20 ......... 19

Transportation .............................................................................................................................................. 20

Table 12. Distance between Hamburg and Neighboring Districts ................................................................. 21

Long-Term Viability ...................................................................................................................................... 21

Finances ...................................................................................................................................................... 23

Table 13. Unspent Authorized Budget .......................................................................................................... 23

Table 14. Hamburg’s Taxable Valuation and Total Tax Rate: Fiscal Year 2015 to Fiscal Year 2020 ............ 24

Table 15. Hamburg’s Total Expenditures: Fiscal Year 2010 to Fiscal Year 2019 .......................................... 24

Table 16. Comparison of Hamburg with the 10 Smallest Districts with High Schools: Fiscal Year 2019 ....... 24

Table 17. Hamburg’s Unspent Balance History, Projected Amounts, and Addition Spending Authority: Fiscal Year 2004 to Fiscal Year 2022 ..................................................................................................................... 25

Figure 1. Comparison of Hamburg to the 10 Smallest District High Schools: Middle and High School Expenditures, Total District Expenditures, and Fall 2019 Certified Enrollment. ............................................ 26

III. Specific Data .............................................................................................................................................. 27

Enrollment Comparisons .............................................................................................................................. 28

Table 18. Hamburg Comparison to Neighboring District’s Certified Enrollment: Fall 2015 to Fall 2019 ........ 28

Table 19. Hamburg Comparison to Neighboring District’s BEDS Enrollment: Fall 2015 to Fall 2019 ............ 28

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Table 20. Projected Enrollment by District: Fall 2020 to Fall 2023 ................................................................ 28

Table 21. Certified and BEDS Enrollment: Fall 2015 to Fall 2023................................................................. 29

Table 22. Student Sharing for Districts with 300 or Fewer Students: 2019-2020 .......................................... 31

Table 23. Students Open Enrolling Out of Hamburg by District: Fall 2015 to Fall 2019 ................................ 32

Table 24. Students Open Enrolling to Hamburg by District: Fall 2015 to Fall 2019 ....................................... 33

Map .............................................................................................................................................................. 34

Appendix ......................................................................................................................................................... 35

Iowa Code .................................................................................................................................................... 35

Iowa Administrative Code ............................................................................................................................ 35

Page 6: Iowa State Board of Education Hamburg High School...Hamburg CSD Feasibility Study Report to the State Board 5 Introduction In January 2020, the Iowa State Board of Education (State

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Introduction In January 2020, the Iowa State Board of Education (State Board) asked the Iowa Department of Education (Department) to conduct a study to investigate the feasibility of Hamburg Community School District’s (Hamburg) request to reopen their 9-12 high school. The report that follows is the result of the State Board’s request.

Purpose The purposes of this feasibility study are to:

1. Present the State Board with relevant background information, including citing pertinent research and legal frameworks and authorities;

2. Provide the State Board with appropriate data, pursuant to Iowa Code section 275.2, and information to inform their discussion and deliberations; and

3. Present the feasibility study team’s conclusions for the consideration of the State Board.

Feasibility Study Team Members Department of Education personnel participating in the study were:

• Janet Boyd, Consultant, Bureau of School Improvement; • Tom Cooley, Bureau Chief, Bureau of School Business Operations; • Eric Heitz, Administrative Consultant, Bureau of School Improvement; • Thomas Mayes, Attorney, Division of Learning and Results; • Rob Olsen, Consultant, Bureau of School Business Operations; • Jay Pennington, Bureau Chief, Bureau of Information and Analysis Services; • Bill Roederer, Consultant, Bureau of School Business Operations; • Carla Schimelfenig, Consultant, Bureau of School Business Operations; • Hannah M. Walsh, Consultant, Bureau of School Improvement; and • Amy Williamson, Bureau Chief, Bureau of School Improvement

Report Structure Part I of this document provides relevant background information to contextualize Hamburg’s request to reopen a high school in the district. Part II of the report explains the findings in general terms and summarizes the team’s conclusions. The data tables and explanations included in Part III go into much more detail, but they are essential to supporting the conclusions.

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I. Background Previous Feasibility Studies Prior to this feasibility study, five studies have been conducted for Hamburg. The studies are summarized below.

Restructuring Feasibility Studies (1989)

In 1989, three restructuring studies were conducted in conjunction due to their proximity: Hamburg and Sidney, Malvern and Nishna Valley, and Fremont-Mills. The feasibility studies were done at the request of the respective districts’ school boards. The general recommendation of the team was to consolidate to form two districts, with Farragut involved in the planning. Specifically, the team recommended that:

• Hamburg and Sidney enter into a whole grade sharing contract with one high school at Sidney, one middle school (5-8) in Hamburg, and one elementary school in each respective district;

• Malvern and Nishna Valley enter into a whole grade sharing contract with the middle school at Nishna Valley and the high school at Malvern; and

• Fremont-Mills remain aware of its neighbors’ actions and participate with them in their feasibility studies.

Reorganization Financial Study (1993)

A study committee, appointed by the board of directors of Sidney, requested a reorganization finance study. The request was for finance combination information for Sidney, with all possible mergers that include Farragut, Fremont-Mills, and Hamburg. The concluding recommendation of the study was that “Sidney should aggressively begin to work with its neighboring districts in order to develop a plan that encompasses reorganization, the uses of current buildings, and the construction of new facilities. All of the neighbors need to be involved. They have as much at stake as does Sidney” (p. 6).

Feasibility Study of a Regional High School for Southwest Iowa (2004)

In 2004, a feasibility study was conducted to evaluate the feasibility of a regional high school for the following districts: Farragut, Fremont-Mills, Hamburg, Malvern, Nishna Valley, and Sidney. The team concluded that:

• Action must be taken given declining projected enrollment and resources available; • Long-term solutions need to be explored; • A regional high school for Southwest Iowa was feasible; and • “Anything less than whole grade sharing will not resolve concerns” (p. 23).

Reorganization Study (2009)

In 2009, a reorganization study was conducted to examine the possibility of whole grade sharing between Farragut, Hamburg, and Sidney. The team recommended that elementary and middle school students from Farragut, Hamburg, and Sidney remain in their respective schools but that all high school students attend a single high school located in Sidney.

Green Hills Area Education Agency Reorganization Plan (2013)

In September 2013, Green Hills Area Education Agency (AEA) released its reorganization plan pursuant to Iowa Code chapter 275. In the Green Hills AEA Reorganization Plan, the AEA suggested Hamburg and all other districts with certified enrollments fewer than 300 “examine the potential of whole grade sharing and/or appropriate mergers” (p. 55).

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History of Restructuring and Noncompliance: April 2010 to February 2020 The following section is a brief overview of the district’s restructuring and noncompliance. For a more extensive summary of restructuring and other relevant events, see the abbreviated timeline below (Table 1). In April 2010, the Department conducted an accreditation visit of Hamburg. The visit resulted in findings of 35 noncompliance citations. In August 2011, Hamburg entered into a whole grade sharing agreement with Farragut. Hamburg high school students attended Farragut, and Farragut sent middle school students to Hamburg. In September 2013, Hamburg and Farragut expanded their previous agreement to share a secondary school in Farragut and an elementary school in Hamburg. In December 2014, a reorganization vote was scheduled between Farragut and Hamburg. The plan was approved by Farragut; however, Hamburg voted down the proposal. In November 2015, Farragut was deaccredited by the State Board. As a result, in August 2016, Hamburg began to tuition out all high school students to Sidney. In Hamburg’s 2017 Certificate of Need application submitted to the Department, the district indicated that they “hope to work toward a consolidation” with Sidney (p. 4). In January 2019, Hamburg submitted a request to reopen their high school program and presented its proposal to the State Board in March 2019. In March 2019, there was extensive discussion regarding staffing, local concerns, the next closest career academy, letters the State Board received in support of a high school, concern for students that want a traditional education route, and the negative financial impact on Sidney. While a motion was made by a State Board member to reopen the high school with intensive Department monitoring—due to the district’s history of noncompliance and repeated citations—the motion was not approved. In January 2020, Hamburg again submitted a request to reopen their high school and provided materials related to the proposed high school coursework for the 2020-2021 school year, financial information, and information regarding the proposed career academies with Iowa Western Community College (IWCC) for the consideration of the State Board. Again, the State Board had a no decision vote, tie. On February 4, 2020, the superintendent forwarded the Department a letter of support from IWCC, dated November 4, 2019. The letter indicated that IWCC “will potentially enter into dual enrollment agreements and partnership arrangements, including a career academy, if the high school is granted permission to re-open.” To date, no contractual agreements have been entered into. On February 5, 2020, Sidney sent a letter to Hamburg requesting the two local school boards formally discuss whole grade sharing, consolidation, transportation, and a revised tuition agreement. In addition, Sidney proposed to pay for the transportation to and from Hamburg each day. To date, no formal discussion has occurred on these topics.

Table 1. Timeline of Hamburg: April 2010 to February 2020

Date Event

April 2010 The Department conducted an accreditation visit, finding 35 non-compliances.

April 2010 The Department conducted an equity visit, finding 14 areas of non-compliance. This does not include Americans with Disabilities Act (ADA) noncompliance items.

June 2011 Hamburg experienced a flood.

August 2011 Hamburg entered into a whole grade sharing agreement with Farragut.

July 24, 2012 The Department conducted a follow-up visit after several noncompliance items remained uncorrected.

September 2013 Farragut and Hamburg began sharing a secondary school in Farragut and an elementary school in Hamburg.

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Date Event

December 17, 2013 The School Budget Review Committee (SBRC) recommended the Department conduct a Fiscal Phase I review of Farragut (that included Hamburg because they were a sharing partner). In conjunction with the fiscal review and in response to longstanding noncompliance issues in both districts, the SBRC determined that the Department would conduct a Phase II accreditation visit immediately following the fiscal review.

February 7, 2014 Seven remaining noncompliance items still not complete, including accessibility.

May 27, 2014 The Department conducted a desk audit and site visit of Hamburg, as part of a full review of the district’s finances.

June 25-26, 2014 The Department visited Hamburg based on the district’s failure to correct numerous and significant instances of noncompliance originally cited in 2010.

December 2014 Reorganization vote fails after Hamburg votes it down.

February 17-18, 2015 The Department conducted a site visit.

March 26, 2015 Hamburg became conditionally accredited.

August 19-20, 2015 The Department visited Hamburg and Farragut for the first quarterly visit as part of a one-year conditional accreditation for each district.

November 18, 2015 The State Board voted to deaccredit the Farragut, effective June 30, 2016.

November 2015 The Department made the second of four quarterly visits as part of Hamburg’s one-year conditional accreditation agreement.

August 2016 Hamburg began to tuition out all 9-12 grade students to Sidney due to the dissolution of Farragut.

February 2016 The Department made the third of four quarterly visits as part of Hamburg’s one-year conditional accreditation agreement.

April 2016 The Department made the fourth of four quarterly visits as part of Hamburg’s one-year conditional accreditation agreement.

September 2017 The district submitted its Certificate of Need application to the Department, stating they “hope to work toward a consolidation” with Sidney.

February 2018 The Department conducted a Differentiated Accountability visit.

March 2018 The Department conducted a Differentiated Accountability follow-up visit.

May 2018 The Department conducted a Differentiated Accountability follow-up visit.

January 25, 2019 Hamburg’s school board petitioned the State Board to start a high school.

January 27, 2019 Superintendent Wells and Board President David Mincer requested Department assistance in investigating the establishment of a 9-12 accredited high school.

March 2019 Hamburg experienced another flood.

March 28, 2019 Hamburg presented its request to the State Board to reopen a district high school. The request was not approved.

December 5, 2019 The Department conducted a targeted site visit.

January 23, 2020 Hamburg presented its request to the State Board to reopen a district high school. The request was not approved.

February 4, 2020 Hamburg forwarded the Department a letter of support from IWCC, dated November 4, 2019. The letter indicates that IWCC “will potentially enter into dual enrollment agreements and partnership arrangements, including a career

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Date Event

academy, if the high school is granted permission to re-open.” To date, no contractual agreements have been entered into.

February 5, 2020 Sidney sent a letter to Hamburg requesting the two local school boards discuss whole grade sharing, consolidation, transportation, and a revised tuition agreement. Sidney proposed to pay for student transportation each day. To date, no formal discussion has occurred on these topics.

School Size Minimum Size Requirement for School District Reorganization and Enlargement

Iowa Code section 275.3 prohibits the approval of any proposal to enlarge a school district unless the district’s previous year enrollment is at least 300 students. However, the director of the Department may grant approval for school enlargement if sufficient evidence of why meeting the school enrollment requirement is in impractical. While Iowa Code section 275.3 is not directly applicable, this is not a school reorganization, it serves as a legal basis upon which school feasibility may be measured.

Enrollments for Districts with Fewer than 300 Students

To provide additional context in understanding the nature of Hamburg’s request, the team pulled certified enrollments and student sharing information for all districts below 300 students (i.e., the minimum size requirement to enlarge a district).1 Based on the 2019-2020 certified enrollment, 39 districts have fewer than 300 students. Of the 39 districts, 12 districts have fewer than 200 students. For the districts with enrollments fewer than 300 students:

• Eleven districts operate their own high school, • Eight districts send 9-12 students to another district, • Eleven districts send 7-12 grade students to another district, • Two districts send 6-12 grade students to another district, • Six districts send 9-12 grade students to another district for partial day sharing, and • One district has a charter high school.

For the districts with enrollments fewer than 200 students, three districts (Essex, Stanton, Whiting) operate a high school and do not student share. In the past year, all three districts have been cited for noncompliance with accreditation requirements (i.e., “Offer and Teach”).

1 For more information on the specifics on student sharing by district, see Table 22.

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II. Department Report Conclusions The Department study team recommends that the State Board considers the following in making a decision about Hamburg’s request to reopen a 9-12 high school:

• Hamburg’s student enrollment and total population are declining. While Iowa’s total population has increased over the last several years, the total populations of Fremont County—the county in which Hamburg resides—and Hamburg have not increased (see Table 4). Similarly, Hamburg’s enrollment continues to fall. In general, loss of enrollment is the major factor that gives rise to the need for school district reorganization. However, despite a continued trend of enrollment decline, the district of Hamburg believes that reopening a district high school meets the needs of the community.

• The proposal put forth by the district focuses on high school “Offer and Teach” and misses key elements required to reopen an accredited high school. While Offer and Teach is a part of reopening a high school, it is only one component of several required for accreditation (see the following Accreditation section). The purpose of school district reorganization or, in this case, expansion is to provide improved learning opportunities for students. The study team does not believe that the reopening of Hamburg’s high school will provide students with an improved educational program over what is currently offered through agreements with neighboring districts nor does the proposed coursework provided support an improved educational program.

• Long-term viability of a high school in Hamburg is questionable, both programmatically and financially. In addition to declining enrollment and population, the district has a long history of noncompliance and frequent need to restructure (see Previous Feasibility Studies). Neighboring districts also expressed concerns about their current working relationship with the superintendent and the district and spoke to the negative impact the proposed re-opening of Hamburg’s high school would have on their respective districts. Additionally, a preliminary review of financial data indicates that the proposed high school might only have funds to be operational for two years.

• If Hamburg is granted permission to start a high school and does not meet minimum accreditation requirements the only options for action of the State Board are Phase II and potential deaccreditation. Hamburg must receive permission from the State Board to reopen their high school, but once it is open the entire district succeeds or does not succeed as one. The State Board does not have the authority to remove the high school only, putting the current situation back in place. The State Board may only act on the entire district’s accreditation. The district may always choose to voluntarily enter into a whole grade sharing agreement, tuition agreement, or reorganize, but the State Board cannot force these choices.

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Enrollments and Population School enrollment and district population are the key considerations in a feasibility study. In general, the feasibility study committee must analyze enrollment, population, and demographic trends to determine if there is a need to reorganize or, in this case, expand the district’s offerings.

Enrollment

Student enrollment, or lack of it, is the element most directly related to the need for considering school restructuring. A low number of students in a school is usually followed by the inability to provide a varied program that meets the needs of all types of students. In evaluating the feasibility of reopening a high school in the district, the team studied the following enrollment data:

• Potential enrollment for the proposed high school, including any home school students enrolled in a home school assistance program or dually enrolled;

• Certified enrollment, which is the number of resident students in the district (Table 2); • Basic Educational Data Survey (BEDS) enrollment, which records the actual number of students being

served in the district (Table 2); and • Number of Hamburg students open enrolling in or out and tuitioning in or out of the district (Table 3).

Potential High School Enrollment The potential enrollment for the proposed high school is at most 60 students. This number assumes all of the students that had open enrolled out, and all students attending Sidney via the tuition agreement, will return to Hamburg for the high school. The team also reviewed the certified enrollment data, which indicated Hamburg does not have any home school students enrolled in a home school assistance program or dually enrolled.

Table 2. Certified and BEDS Enrollment for Hamburg: Fall 2015 to Fall 2023

Year Certified Enrollment BEDS Enrollment Number of Students

FTE Change

Percent Change

Number of Students

FTE Change

Percent Change

Fall 2015 246.2 2 0.82 182 -25 -12.08

Fall 2016 235 -11.2 -4.55 160 -22 -12.09

Fall 2017 221 -14 -5.96 143 -17 -10.63

Fall 2018 227 6 2.71 139 -4 -2.80

Fall 2019 199 -28 -12.33 131 -8 -5.76

Fall 2020 221.5 22.5 11.3 NA NA NA

Fall 2021 218.4 -3.1 -1.4 NA NA NA

Fall 2022 217.2 -1.2 -0.5 NA NA NA

Fall 2023 214.6 -2.6 -1.2 NA NA NA Source: Iowa Department of Education, Certified Enrollment and BEDS. Notes. Yellowed cells indicate a loss in enrollment from the previous school year. NA = Not available. The projected enrollment numbers provided were based on 2018 certified enrollment. In the fall of 2019, Hamburg's enrollment declined by 28 students (-12%). At the time of this report, the new projected numbers had not been calculated.

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Table 3. Hamburg’s Open Enrollment and Tuition Summary: 2000-2001 to 2019-2020

Year Certified Enrollment

Open Enrolled Out

Tuitioned Out

Tuitioned In

Open Enrolled In

2000-01 329.4 7 4 0 1

2005-06 313.2 6 4 0 5

2010-11 257 15 3 0 5

2011-12 242 25 56 49 7

2012-13 259 42 51 47 4

2013-14 247.3 30.2 51 50 4

2014-15 244.2 30.2 52 40 5

2015-16 246.2 48.2 70 53 2

2016-17 235 78 14 0 16

2017-18 221 73 20 0 15

2018-19 227 68 30 0 10

2019-20 199 47 37 0 16 Source: Iowa Department of Education, Certified Enrollment.

Population

In addition to the enrollment data, the team studied the following population and demographic data:

• Total populations of Iowa, Fremont County, and Hamburg (Table 4); • Fremont County workforce (Table 5); and • Number and percent of students eligible for free and/or reduced lunch (Table 6).

Table 4. Annual Estimates of the Resident Population: July 1, 2010 to July 1, 2018

Year Iowa Fremont County Hamburg

2010 3,050,767 7,434 1,185

2011 3,066,054 7,370 1,169

2012 3,076,097 7,140 1,132

2013 3,093,078 7,069 1,116

2014 3,109,504 7,030 1,106

2015 3,121,460 6,913 1,085

2016 3,131,785 6,951 1,091

2017 3,143,637 6,952 1,085

2018 3,156,145 6,993 1,089 Source: U.S. Census Bureau, Population Division (2019). Notes: The estimates are based on the 2010 Census and reflect changes to the April 1, 2010 population due to the Count Question Resolution program and geographic program revisions. All estimates are as of July 1.

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Table 5. Fremont County Workforce: 2016 to 2019

Year Jan Feb March April May June July Aug Sept Oct Nov Dec 2016 2,580 2,619 2,618 2,617 2,534 2,513 2,325 2,256 2,430 2,434 2,378 2,368

2017 2,320 2,310 2,363 2,371 2,380 2,412 2,304 2,263 2,247 2,294 2,274 2,257

2018 2,186 2,173 2,163 2,212 2,259 2,302 2,189 2,183 2,194 2,233 2,209 2,196

2019 2,144 2,147 2,154 2,207 2,209 2,244 2,148 2,111 2,132 2,174 2,141 2,142 Source: Iowa Workforce Development, Labor Market Information Division, Current Employment Statistics (CES) program.

Demographics In the January 2020 letter submitted to the State Board, the district’s superintendent argued that an “undue burden is placed on our high school student[s] because they are denied educational opportunities which can be offered in our community” (p. 4). The superintendent further argues that the decision to reopen a district high school should be based on the:

1. Decision of locally elected decision makers (i.e., the Hamburg School Board), 2. Financial position of the school, and 3. Ability of the school to have highly qualified professional staff that meets the standards set by the

Department. In the letter, the superintendent states that: “Hamburg meets and exceeds these requirements and thus has a legal basis for making the local decision…. Therefore, the Iowa State Board of Education basing a decision on a school’s location in the state or the size of school, would be a clear violation of the Equal Protection Clause and a violation of the individual rights of all students” (p. 5). Legal Review Following the argument from the superintendent, the team gathered comparative poverty data for the district (Table 6) and requested a legal review of the argument presented. The following responses were provided by the Department’s attorney:

• In regard to the Iowa Civil Rights Act citation, neither poverty/income nor urban-rural are listed as protected classes in Iowa Code section 216.9 (discrimination in education) or Iowa Code section 216.7 (discrimination in public accommodations or services).

• Regarding the Equal Protection Clause citation, classification based on poverty or income is not subject to the "undue burden" analysis that Superintendent Wells asserted. Income is not a "suspect classification" and under pertinent Supreme Court cases; therefore, the proper standard of review is "rational basis" (San Antonio Indep. Sch. Dist. v. Rodriquez, 441 U.S. 1 (1973); see also Kadrmas v. Dickinson Pub. Sch., 487 U.S. 450 (1988)). Generously, assuming that the State Board decision on reconsideration is based on poverty, Hamburg would "carry the heavy burden of demonstrating that" the Board's decision "is arbitrary and irrational" (Kadrmas, 487 U.S. 450).

Table 6. K-12 Students Eligible for Free and Reduced-Price Lunch by District: 2018-2019

District Name

K-12 Enrollment

Number Eligible Percent Eligible for Free or Reduced- Price Lunch

Free Lunch

Reduced Lunch

Free or Reduced Lunch

Essex 179 74 19 93 52

Fremont-Mills 468 127 44 171 36.5

Hamburg 139 85 8 93 66.9

Shenandoah 1033 493 126 619 59.9

Sidney 476 219 37 256 53.8

South Page 120 65 7 72 60

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Source: Iowa Department of Education, Bureau of Information and Analysis, SRI Merged 2018-2019 Fall File. Notes. If a student was reported as eligible for both free and reduced, that student is included in the "Free Lunch" count. Shenandoah is the only district that participated in the Community Eligibility Provision (CEP).

Educational Programs and Personnel Educational Programs

Among the most important considerations of a feasibility study is the evaluation of whether the reorganization will result in an improved educational program, including improved student services and co-curricular and extracurricular opportunities, for the district’s students. Following review of the proposed course offerings and opportunities, it is the view of the team that high school students would not receive an educational program that is better than the current opportunities available with neighboring districts. Accreditation - Offer and Teach Iowa Code section 256.11(5) states the minimum program to be offered and taught for grades 9-12 must include:

• Five units of science; • Five units of social studies, including a half unit of United States government and one unit of United

State history; • Six units of English language arts; • Four units of a sequential program in mathematics; • Two additional units of mathematics; • Four sequential units of world language; • One unit of physical education; • Three sequential units in at least four of the career and technical education (CTE) areas; • Three units of fine arts; and • One unit of health.

Prior to entering into a whole grade sharing agreement with Farragut in 2011, Hamburg operated a high school. During school years 2006-2007 to 2010-2011, the district’s high school did not meet the minimum number of units required for accreditation, Table 7.

Table 7. Hamburg High School Courses Offered and Taught Prior to Sharing: 2006-2007 to 2010-2011

Area Minimum Units

State Average

2006-2007

2007-2008

2008-2009

2009-2010

2010-2011

English/Language Arts 6 7.9 6 9 5.5* 8 7.5

Fine Arts 3 7.28 7 7 9 9 6

World Languages 4 5.25 2 4 2 2 3

Health 1 0.91 1 1 1 1 1

Mathematics 6 8.05 8 8 8 9.5 6

Physical Education 1 1.37 0.25 0.5 2 1 2

Science 5 6.89 4 7 8 10 7.5

Social Studies 5 5.88 5.5 7 7 7 6.5

CTE 12 22.18 15 20.5 14 16.5 16 Source: EDInsight Curriculum Accreditation Report. Notes. Yellowed cells indicate unsatisfied requirements. *Upon consultant review, the consultant determined that the original number was not accurate because it did not meet all the requirements.

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Program Differences

In the proposal submitted to the State Board in January 2020, Hamburg proposed using a combination of face-to-face and online classes to meet requirements for an accredited high school. These online courses are provided by private providers and/or Iowa school districts. Hamburg proposed using the Department-approved private provider, Edgenuity, to offer their online coursework. Although online courses maybe used to meet Offer and Teach, a waiver is required if the district is using more than two online courses to do so. Table 8 indicates the number of course offerings at each school to fulfill the minimum number of required units specified for accreditation. Due to the potential that an online offering may not meet the required student enrollment threshold, the proposed online offerings are not included in Hamburg’s column below. Table 8 shows the proposed offerings would not meet the minimum state accreditation requirements nor an improved educational program over what is currently offered and taught at neighboring districts. Specifically, when compared to the current offerings available at Sidney, Hamburg’s proposal will offer less courses in English, mathematics, science, social studies, and CTE.

Table 8. Comparison of Proposed Hamburg High School Courses to Courses Offered and Taught at Neighboring Districts

Area Minimum Units

Hamburg (Proposed)

Sidney Fremont-Mills

Shenandoah South Page

Essex

English Language Arts

6 6 7 6 7 5.5 6

Fine Arts 3 9 6.5 6 9 3 4

World Languages

4 4 4 4 4 2 3

Health 1 0.5 1 1.5 1 1 1

Math 6 6 7 8 6.5 5 6

Physical Education

1 2 2 2 2 1 1

Science 5 6 7 5 7 5.25 5

Social Studies

5 5 5.5 5 5.5 5 5.5

CTE 12 9 19.99 16 25.24 14.75 11 Source: Student Reporting in Iowa. Notes. Yellowed cells indicate the district is short of meeting the minimum requirements. To meet the minimum unit requirement for CTE, a district must provide three units in four service areas.

Career and Technical Education To meet the minimum unit requirement for CTE, a district must provide three units in four service areas. The areas are:

• Agriculture, Food, and Natural Resources; • Arts, Communication, and Information Systems; • Applied Sciences, Technology, Engineering, and Manufacturing, including transportation, distribution,

logistics, architecture, and construction; • Health Services; • Human Services, including law, public safety, corrections, security, government, public administration

and education and training; and • Business, Finance, Marketing, and Management.

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Career Academies In the proposed list of coursework, Hamburg included career academies that would be seemingly conducted in partnership with IWCC. These academies are proposed to allow students to attain a certificate, diploma, or associate’s degree in the respective programs. Career academies are proposed in the following areas:

• Health Occupations (2020-2021), • Construction Trades (2020-2021), • Culinary Arts (2020-2021), • Technology (2021-2022), and • Welding (2021-2022).

Assuming IWCC enters into an agreement with Hamburg to provide the proposed offerings and that the program offerings are approved by the Department and AEA, Hamburg will not meet or exceed the CTE course offerings available at neighboring school districts until 2021-2022. To date, no formal contract is in place with IWCC, and it does not appear that Hamburg has consulted with the AEA or the Bureau of Career and Technical Education at the Department regarding CTE program approval.

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Table 9. CTE Areas and Number of Units Offered by District

CTE Program of Study

Agriculture, Food & Natural Resources

Applied Sciences, Technology, Engineering & Manufacturing

Business, Finance, Marketing & Management

Human Services

Health Sciences

Information Solutions

Total Units

Hamburg (Proposed)

0 units Construction Trades (2 units); Welding (1 unit; available 2021-22)

Business (3 units) Culinary Arts (3 units)

Health Occupations (no doc.)

Technology (available 2021-22)

9

Sidney Agricultural Business & Management (4 units)

Woods; Welding; Automotive (10.96 units)

Business (4 units) Cooking & Related Culinary Arts (3 units)

0 units 0 units 21.96

Fremont-Mills Agricultural Business & Management (7 units)

Construction Trades (4 units) 0 units Family & Community Services (3 units)

Health Services (4 units)

0 units 18

Shenandoah Agricultural Business & Management (5.16 units)

Drafting/Design Engineering Technologies; Welding Technology; Automotive/Automotive Mechanics (8 units)

Business (5 units) Family & Consumer Science (6 units)

Health Services (1.39 units)

0 units 25.55

South Page Agricultural Business (3.5 units; at Clarinda)

Drafting (Woods & Metals) (3.5 units; at Clarinda)

Business (3.75 units)

Family & Community Services (3 units; at Clarinda)

0 units 0 units 13.75

Essex 0 units Manufacturing Engineering Technology (4 units)

Business (3 units) Cooking & Related Culinary Arts (3 units)

0 units Web Page, Digital/ Multimedia (3 units)

13

Red Oak Agricultural Business & Management (8.5 units)

Manufacturing Engineering Technology (4 units); Welding Technology (3 units)

Business (3.9 units)

Family & Consumer Science (5.57 units)

0 units 0 units 24.97

Source: Student Reporting in Iowa and Secondary CTE Reporting (2019-20). Notes. Hamburg proposes to offer and teach high school coursework through a combination of face-to-face and online classes. Red Oak is added because the proposed coursework from Hamburg includes sharing with Essex, which shares CTE courses with Red Oak.

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Student Services and Co-Curricular and Extracurricular Programs

While the district has provided information regarding proposed coursework, several key components have not been addressed. The district will need to develop the following board policies and programs for a high school:

• Graduating seniors (281—IAC 12.1(7)); • Personnel evaluation (281—IAC 12.3(3)); • Student records (281—IAC 12.3(4)); • Graduation requirements (281—IAC 12.3(5)); • School or school district building grade-level organization (281—IAC 12.3(9)); • Standards for school counseling programs (K-12 comprehensive school counseling program; 281—IAC

12.3(11)); • Library program (K-12 library program to support the student achievement goals of the total school

curriculum; 281—IAC 12.3(12)); • Staffing policies—secondary schools (281—IAC 12.4(6)); • Teacher (instructional professional staff who holds a license/certificate endorsed for the type of position

in which employed; 281—IAC 12.4(8)); • Secondary credit (281—IAC 12.5(4)(I)); • High school program, grades 9-12 and CTE (281—IAC 12.5(5)); • Provisions for gifted and talented students (281—IAC 12.5(12)); • Provisions for at-risk students (281—IAC 12.5(13)); • Unit, which is the equivalent of 120 hours of instruction (281—IAC 12.5(14)) • Credit (281—IAC 12.5(15)); • Subject offering (Offer and Teach; 281—IAC 12.5(16)); • Twenty-first century learning skills (281—IAC 12.5(17)); • Cardio-pulmonary resuscitation course (281—IAC 12.5(20)); • Provisions for district professional development plans (281—IAC 12.7(1)); • Content standards and benchmarks (281—IAC 12.8(1)); • Annual reporting requirements (281—IAC 12.3(3)); • Revised District Delivered Service Delivery Plan (DDSDP) for special education; and • Activity program, grades 9-12 (281–IAC 12.6).

Student Outcomes

Due to the short timeframe, the team was only able to study the following student outcome data:

• Learning measures from the Iowa School Performance Profile for 2018 and 2019 (Table 10),2 and • The percent of K-3 students at benchmark for literacy (Table 11).

Table 10. Iowa School Performance Profile Indicators: 2018 and 2019

Learning Measure 2018 2019

Hamburg State Average Hamburg State Average

Assessment Participation Mathematics 100 99.37 100 99.39

Assessment Participation Reading/English Language Arts

100 99.35 100 99.47

Average School Achievement Reading/English Language Arts

49.97 50 50.35 50

2 For additional student data, see the Department’s Student Performance webpage.

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Learning Measure 2018 2019

Hamburg State Average Hamburg State Average

Average School Achievement Mathematics

49.64 50 48.88 50

Conditions for Learning Composite 41.86 47.46 45.81 37.15

Growth Reading 58 50 57.5 50

Growth Mathematics 79 49 56 50

Percent Proficient Mathematics 75.56 76.25 71.43 70.16

Percent Proficient Reading/English Language Arts

72.22 75.32 73.63 69.81

Source: Iowa School Performance Profiles 2018 and 2019. Notes. In the 2018 data, English Language Arts is Reading.

Table 11. Percent of Hamburg Students K-3 at Literacy Benchmark: Spring 2015-16 to Fall 2019-20

District Spring 15-16

Fall 16-17

Spring 16-17

Fall 17-18

Spring 17-18

Fall 18-19

Spring 18-19

Fall 19-20

Hamburg 52 41 49 49 50 39 48 52

State 68 65 68 70 71 65 70 64 Notes. Screening data is based on the school’s selected default assessment. At benchmark is based on 2015-16 literacy benchmarks for all years.

Personnel

The Hamburg high school proposal relies heavily on Essex staff to teach courses at both Hamburg and Essex. This creates a number of questions related to Essex staff and leadership stability, licensure, and delivery of instruction. Essex Staff and Leadership Stability In the spring of 2019, Essex administration and school board began discussing the need for additional sharing to address declining enrollment. Based upon a review of board minutes, there were ten resignations in the spring of 2019, including resignations of a high school mathematics teacher, high school science teacher, and superintendent. Four board members also resigned last spring (March 6, June 12, June 19, and June 24). Personnel Sharing According to board minutes, Essex shares the following positions to meet the needs of students for the 2019-2020 school year:

• An art teacher with Red Oak at 6/7 FTE, • An FFA teacher with Red Oak (per pupil charge), • A Spanish teacher with Red Oak at 3/7 FTE, • A librarian teacher with Hamburg, • A PE/Industrial Arts teacher with South Page, • A Title/TAG teacher with South Page, • An Ag/PE teacher with South Page, and • A Spanish teacher with Red Oak and Sidney.

Related question: If the Hamburg high school proposal is approved, will Essex continue to share staff with Red Oak, South Page, and Sidney?

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Licensure and Commuting At the January State Board meeting, the Hamburg/Essex superintendent mentioned that staff will receive assignments based on the contracts per duties as assigned. However, a review of potential teachers indicated possible licensure issues. For example, Dr. Wells does not appear to have a history endorsement but is planning to teach Constitutional History. Related question: Are Essex teachers prepared to commute between districts and teach classes remotely? If a district is requiring a staff member to travel between buildings, the district must either provide a mileage reimbursement or provide a district vehicle for this purpose. Delivery of High School Instruction The high school master schedule submitted by Hamburg indicates the proposed school will run an eight- period day, five days a week, with the proposed Hamburg high school using a majority of Essex’s teachers. This eight-period day will ensure courses taught will meet the minimum definition of a unit, 120 hours, defined in 281—Iowa Administrative Code (IAC) 12.5(14). This proposal raises questions:

1. How will students at Essex or Hamburg receive instruction when the teacher is in the other school district?

2. When and how will teachers be provided with professional development to make the transition to providing courses from in-person to over some form of technology (281—IAC 15.5)?

3. Who will teach the online courses proposed by the district? The Hamburg plan also includes a number of online course opportunities that will be available for students to take. The approved private providers on the Department website do not provide an Iowa licensed teacher. Providing appropriately licensed teacher will be Hamburg’s responsibility (281—IAC 15.2).

4. If Hamburg uses more than two online courses to meet Offer and Teach requirements, the district will need to seek a waiver (Iowa Code § 256.42).

Transportation This section reviews the distance between Hamburg and surrounding districts and discusses transportation.3 Table 12 provides the distance and estimated travel time from Hamburg to the respective high schools at surrounding districts. Sidney is the closest district to Hamburg. On February 5, 2020, the Sidney school board sent a letter to Hamburg expressing interest in whole grade sharing and consolidation, and the willingness to transport Hamburg students to Sidney if the districts agree to a whole grade sharing agreement. To date, no formal discussion has occurred on these topics. The Department has received several reports that Hamburg students that have open enrolled to Essex being transported to Essex, a noncontiguous district, in a school van. Despite notifying Dr. Wells that this was not allowable, it has been reported to the Department that the practice continues by allowing an Essex staff member to transport students to Essex from Hamburg in a private vehicle. Dr. Wells reports that transportation is being provided by parents, not staff members. Whether parents or staff members are providing transportation, there are continued questions that require additional exploration, including whether drivers of the vehicles are being compensated, directly or indirectly, by either school district or other parents (see, e.g., Iowa Admin. Code r. 281-43.6). At the very least, this arrangement raises questions of liability and sustainability. In addition, the Department does not have any transportation information regarding how staff will fulfill their roles at multiple districts. If a district is requiring a staff member to travel between buildings, the district must either provide a mileage reimbursement or provide a district vehicle for this purpose.

3 See the vicinity map in the Maps section.

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Table 12. Distance between Hamburg and Neighboring Districts

Neighboring District Distance from Hamburg Estimated Student & Personnel Travel Time

Sidney 9.7 miles 13 minutes

Fremont-Mills 19.8 miles 26 minutes

Shenandoah 24.7 miles 30 minutes

South Page 28.5 miles 39 minutes

Essex 30.2 miles 36 minutes Source: Google Maps (2020). Note. Distance was measured from Hamburg to the listed school districts’ high school.

Long-Term Viability It is the view of the team that the long-term viability of a reopened high school in Hamburg is questionable, both programmatically and financially. Several factors were considered in this evaluation, including:

• The steady decline in population and student enrollment. Population of the county and town continue to decline (Table 4). In the fall of 2019, Hamburg enrollment declined 28 students to a K-12 enrollment of 199 (Table 2). The floods of 2019 damaged 70 homes and a large portion of the town.

• The number of feasibility studies conducted to date. Prior to this study, five feasibility studies have been conducted. While the circumstances in which the feasibility studies varied, the recommendations were consistent in recommending the district consolidate with Sidney (see Previous Feasibility Studies).

• A preliminary review of financial data indicates that the proposed high school might only have funds to be operational for two years. For more on this, see the following Finances section.

• Concerns of the AEA, students, and neighboring districts. In previous site visits, students voiced the opinion that only one high school should be operating in the county. Neighboring districts also expressed concerns about their current working relationship with the superintendent and the district and spoke to the negative impact the proposed re-opening of Hamburg’s high school would have on their respective districts. The concerns are included in the following section.

Impact on Neighboring Districts

As part of the feasibility study, the team conducted interviews of the neighboring school district administrators and with the AEA chief administrator. When asked of the impact a reopened Hamburg high school would have on their respective districts or on Green Hills AEA, the responses were overwhelming negative. The following questions were asked:

1. Would the reopening of a high school in Hamburg impact your district/AEA? 2. What current sharing agreements do you currently have with Hamburg and/or other surrounding

districts? 3. What are your current CTE offerings?

Green Hills AEA – Chief Administrator, Dr. LaDarla Haws Dr. Haws was asked if she believes the addition of Hamburg high school will have an impact on the surrounding districts. She stated it will have a detrimental economic and academic impact on the surrounding districts with Sidney seeing the most impact and other districts, such as Red Oak, Shenandoah, South Page, and Essex to a lesser extent. Dr. Haws is concerned about the academic well-being of the students involved and expressed concerns about the academic value of the maker space program and farm school. In addition, she expressed concerns with some leaders and staff overstating and mischaracterizing the impact and quality of the proposed high school, finding and keeping quality staff, overstating enrollment and not being forthcoming about cost. Dr. Haws believes Hamburg’s proposal is dubious at best, and there is not a positive reason to do it.

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Sidney – Superintendent, Tim Hood The biggest impact of Hamburg reopening a high school in the district will be on Sidney, due to their current high school tuition in agreement with Hamburg. Based on an interview with Sidney, the termination of the agreement will mean a budget cut of $250,000 (four or five staff members). In addition, Sidney purchased a building with three portable classrooms at a cost of $60,000 to meet the needs of the additional high school students from Hamburg. Since the Hamburg high school discussion has started, Sidney has noted an increase in Hamburg students harassing other Hamburg students that plan to continue to attend Sidney next year. During the interview with Sidney administration, it was noted the district was waiting on payment from Hamburg for items agreed upon in the original tuition agreement. This included a $30,689 technology bill from Hamburg. On February 5, 2020, the Sidney school board sent a letter to the Hamburg board asking if they have any interest in discussing whole grade sharing and consolidation. The letter also proposed providing transportation to and from school each day. To date, no formal discussion on these topics has occurred. Red Oak – Superintendent, Tom Messinger Red Oak does not border Hamburg but borders Essex. Essex will be sharing with Hamburg, if the high school is approved. Red Oak signed a two-year agreement with Essex beginning in the 2019-20 school year. These positions include art and Spanish with a shared agriculture program. At the start of the 2019-20 school year, Essex changed its high school schedule, which made it impossible for Essex students to travel to Red Oak for Agriculture classes. Essex is planning to terminate the agreement at the end of the 2019-20 school year, one year into a two-year agreement. (Red Oak administration and school board members documentation indicated this was a two-year sharing agreement. Essex documentation indicated this was a one-year agreement.) This may lead Red Oak to lay off teachers depending on the staff model developed at the Red Oak district. Fremont-Mills and Stanton – Shared Superintendent, Dave Gute Fremont-Mills does not share a border with Hamburg but has had some Hamburg students open enrolled into the district. Stanton does not share a border with Hamburg but shares a border with Essex. Stanton has had several students open enroll in from Essex. If the Hamburg high school proposal is approved and Hamburg shares teachers with Essex, Stanton may see students terminate open enrollment and return to Essex. Stanton has shared athletics (football, golf, and softball) with Essex. The districts have agreed to sharing a football team for the next two years. Golf and softball were shared last year, but the districts are not sure if it will be shared during the summer of 2020. Stanton will be able to offer softball without sharing with Essex. Although Stanton shared golf with Essex last year, they are considering having their own golf team. Shenandoah – Superintendent, Dr. Kerri Nelson Shenandoah has concerns about open enrollment. After it became public that Essex was in financial trouble and needed to make decisions, Shenandoah received 22 timely open enrollment requests. However, the political climate in Essex changed when Dr. Wells was hired. Less than half of the 22 students that opened enrolled actually came to Shenandoah in the fall. There were three new timely open enrollments from Hamburg to Shenandoah, but only two came. Shenandoah did not hire staff based on projected enrollment. Shenandoah expressed concerns about the difficulty of the dissolution of Farragut and future of other districts in the area who have reported financial difficulties. Dr. Nelson noted that when districts are voluntarily or not voluntarily dissolved, it has a profound effect on all the surrounding districts. For example, she stated the following regarding Farragut: “This has been very difficult for the Farragut community to accept. There have been many financial and political challenges to work through… I am increasingly concerned about their ability to sustain and what state actions may or may not be necessary.” At this time, Shenandoah does not have any agreements with Essex. During the 2018-19 school year, the district was asked about sharing possibilities and Shenandoah did send a good faith statement of interest and information about the Shenandoah district. Past athletic sharing agreements have not been continued. Essex and Shenandoah are approximately eight minutes from door to door. Shenandoah currently shares some staff with surrounding districts. These shared positions include a school business official (South Page), auto technology teacher (Sidney), and English language learner teacher (Clarinda). Shenandoah is willing to do more sharing with surrounding districts.

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Shenandoah has a strong commitment to CTE and science, technology, engineering, and mathematics (STEM). They currently offer courses in industrial technology, manufacturing, automotive technology, agriculture, health occupations, business, and family consumer science (culinary and human services), with increasing opportunities for coding and robotics. The district offers a number of hands-on learning opportunities and internships. Additionally, the district offers Advanced Placement (AP) courses both on-site and online.

Finances Although Hamburg is not one of the districts that "early warning" projections indicated would have a potential negative unspent balance for the current or upcoming fiscal year in January 2019, those projections were primarily based on the most recent three-year averages. The district has, in the not so distant past, been in front of the SBRC for incurring a negative unspent balance and to highlight current levels. The following information was intended for further review:

1. For the basis of the financial study, prepare a series of reports combining data from potential sharing/reorganization partners;

2. Explain what financial effects reorganizing might have on the education program; 3. Explain what financial effects reorganizing might have on the taxpayer; 4. Explain what financial options are available; 5. Explain what financial resources are available; 6. Study fund balances and trends; 7. Study efficient/economical operation; 8. Explain assessed valuation and taxable value per pupil; 9. Compare tax rates of the current district with surrounding districts, and estimated tax rates of possible

reorganization options; and 10. Further investigation of the district’s operational sharing, which is currently maxed out at 21 students

(i.e., superintendent = 8 students, business manager = 5 students, school counselor = 3 students, human resources = 5 students)

However, due to the short time frame, the following data has been provided for review of the State Board:

• Unspent authorized budget of Hamburg and Essex (Table 13); • Hamburg’s taxable valuation and total tax rate (Table 14); • Hamburg’s total expenditures (Table 15); • Expenditures for fiscal year 2019 by building for the 10 smallest district high schools and Hamburg

(Table 16); and • Hamburg’s unspent balance history, projected amounts, and additional spending authority (Table 17).

Table 13. Unspent Authorized Budget

Year Hamburg Essex

With Categoricals

Regular Program Without Categoricals

With Categoricals

Regular Program Without Categoricals

FY 2015 $93,188 $-138,570 $607,422 $549,516

FY 2016 $423,902 $180,636 $982,387 $907,580

FY 2017 $878,442 $630,201 $1,271,054 $1,147,623

FY 2018 $1,408,706 $1,210,377 $1,372,787 $1,218,971

FY 2019 (est.) $1,199,290 $1,036,538 $1,347,143 $1,143,292

Source: Iowa Department of Education. Note. The unspent authorized budget (spending authority) does not equate to cash on hand.

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Table 14. Hamburg’s Taxable Valuation and Total Tax Rate: Fiscal Year 2015 to Fiscal Year 2020

Year Net Taxable Valuation Total Tax Rate FY 2015 $114,831,153 $11.98

FY 2016 $117,343,817 $11.68

FY 2017 $132,460,671 $11.60

FY 2018 $145,981,684 $11.64

FY 2019 $145,351,008 $11.04

FY 2020 $149,659,542 $11.01 Source: Department of Management.

Expenditures

Fiscal year 2011 was the last year Hamburg was a K-12 school district. For the next two years, as a K-8 school district, their expenditures increased. In fiscal year 2019, the district’s expenditures increased almost $700,000 with an unspent authorized budget of $1,199,290.

Table 15. Hamburg’s Total Expenditures: Fiscal Year 2010 to Fiscal Year 2019

Year Grades Served Total Expenditures Difference from Previous Year

FY 2010 K-12 $3,187,627 $232,017

FY 2011 K-12 $2,856,797 $-330,830

FY 2012 K-8 $3,028,536 $171,739

FY 2013 K-8 $3,546,741 $518,205

FY 2014 K-8 $3,368,310 $-178,431

FY 2015 K-8 $3,094,831 $-273,479

FY 2016 K-8 $2,894,024 $-200,807

FY 2017 K-8 $3,029,394 $135,370

FY 2018 K-8 $2,712,210 $-317,184

FY 2019 (est.) K-8 $3,401,178 $688,968 Source: Iowa Department of Education.

During the 2018-2019 school year, all districts in Iowa began coding expenditures to the school from which the expenditures were incurred. An analysis of the fiscal year 2019 expenditures by school of the ten smallest districts with a high school and Hamburg were included in an analysis of school level expenditures (Table 16). Although Hamburg does not have a high school, the middle school and high school expenditures include the expenditures incurred for grades seven and eight, as well as the tuition paid to Sidney.

Table 16. Comparison of Hamburg with the 10 Smallest Districts with High Schools: Fiscal Year 2019

District Grades Served Middle School & High School Total Expenditures Hamburg 7-12 $451,769.56 3,401,177.68

Mormon Trail 7-12 $971,428.05 3,390,163.94

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District Grades Served Middle School & High School Total Expenditures Ruthven-Ayrshire 7-12 $777,682.89 3,191,529.21

Essex 6-12 $1,574,222.75 3,161,659.14

South Page 7-12 $567,557.70 3,010,445.82

Whiting 7-12 $1,053,214.41 2,905,513.70

Paton-Churdan 7-12 $1,030,950.49 2,828,005.25

Orient-Macksburg 7-12 $662,562.48 2,767,191.74

Moulton-Udell 7-12 $884,769.87 2,705,091.56

Stanton 6-12 $1,093,267.48 2,501,614.30

Diagonal 6-12 $603,301.73 1,791,561.30 Source: Iowa Department of Education.

As expected, Hamburg’s expenditures specifically coded to grades 7-12 is the lowest among the ten smallest districts with a high school. Although Hamburg ranked 11 of 11 regarding expenditures in grades 7-12, the district’s total expenditures is the highest among these same districts (ten smallest districts with a high school and Hamburg). The average cost of having a high school among the ten smallest districts with a high school is estimated at $921,896. Assuming Hamburg will spend at least the average cost if its high school is reinstated, and taking into account the district already spends $451,770, the district will need to spend an additional $470,126. It is important to note that of the ten smallest districts with a high school, Mormon Trail is the only district with two buildings with one for elementary and another for high school. The remaining nine districts serve all grades, K-12, in one physical location. Mormon Trail’s high school expenditure total is only $50,000 more than the average expenditures of the ten districts.

10 District Average Middle and High School Expenditures = $921,896 Additional Yearly Cost to Hamburg = $470,126

Unspent Balance In fiscal year 2019, Hamburg had an unspent balance of $1,199,290. Not taking into account that certified enrollment is showing a consistent decline (lower expected future revenues), but only accounting for the additional yearly cost to implement a high school, the district is projected to have a negative unspent balance by fiscal year 2022 (at the conclusion of the 2021-2022 school year). Table 17 shows the district’s unspent balance history, projected amounts, and additional spending authority the district received from SBRC-approved requests for modified supplemental amount and operational sharing supplementary weighting from the dissolution of Farragut in 2016.

Table 17. Hamburg’s Unspent Balance History, Projected Amounts, and Addition Spending Authority: Fiscal Year 2004 to Fiscal Year 2022

Fiscal Year

Unspent Balance (Budget Authority)

Additional Spending Authority

Reason

FY 2004 $302,787

FY 2005 $584,901

FY 2007 $181,955

FY 2008 $6,364

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Fiscal Year

Unspent Balance (Budget Authority)

Additional Spending Authority

Reason

FY 2009 $5,347

FY 2010 $-254,903

FY 2011 $320,575 $254,903 SBRC request

FY 2012 $434,758

FY 2013 $-46,350

FY 2014 $-148,951

FY 2015 $93,188 $148,951 SBRC request

FY 2016 $423,902

FY 2017 $878,442 $158,394 Operational sharing from Farragut

FY 2018 $1,408,706

FY 2019 $1,199,290

FY 2020 $729,164 $4,265 SBRC request

FY 2021 $259,038

FY 2022 $-211,088 Source: Iowa Department of Education.

Figure 1 shows a comparison of the ten smallest districts with a high school and Hamburg when examining expenditures for middle and high school grades, total district expenditures, and fall 2019 certified enrollment (resident students).

Figure 1. Comparison of Hamburg to the 10 Smallest District High Schools: Middle and High School Expenditures, Total District Expenditures, and Fall 2019 Certified Enrollment. Note: The legality of 529 individual student accounts has raised more questions that still need to be answered.

0

50

100

150

200

250

$0$500,000

$1,000,000$1,500,000$2,000,000$2,500,000$3,000,000$3,500,000$4,000,000

Fiscal Year 2019 Middle and High School Expenditures and Total District Expenditures with Fall 2019 Certified Enrollment

Middle School & High School Total Expenditures Certified Enrollment

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III. Specific Data The following maps, tables, and charts were prepared or reproduced from other sources, specifically for this study. THE MAP IS NOT INTENDED FOR OFFICIAL USE

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Enrollment Comparisons Certified Enrollment and BEDS Enrollment

Table 18. Hamburg Comparison to Neighboring District’s Certified Enrollment: Fall 2015 to Fall 2019

Year Hamburg Sidney Fremont-Mills Shenandoah South Page Essex Fall 2015 246.2 332.8 464 1189.5 187 203.2

Fall 2016 235 408.9 456 1075.7 197.9 196

Fall 2017 221 393.7 452 1082.9 207.1 194

Fall 2018 227 373.6 471.3 1050.7 195 190.55

Fall 2019 199 372.8 464.1 1058.4 207 187.2 Source: Iowa Department of Education, Certified Enrollment.

Table 19. Hamburg Comparison to Neighboring District’s BEDS Enrollment: Fall 2015 to Fall 2019

Year Hamburg Sidney Fremont-Mills Shenandoah South Page Essex Fall 2015 182 391 453 1,024 112 220

Fall 2016 160 470 457 1,046 127 205

Fall 2017 143 470 461 1,049 132 200

Fall 2018 139 476 468 1,033 120 179

Fall 2019 131 463 465 1,039 110 157 Source: Iowa Department of Education, BEDS.

Enrollment Projections

Table 20. Projected Enrollment by District: Fall 2020 to Fall 2023

Year Hamburg Sidney Fremont-Mills Shenandoah South Page Essex Fall 2020 221.5 364.5 478.5 977.6 190.3 185.9

Fall 2021 218.4 359.5 484.3 953.5 187.6 183.3

Fall 2022 217.2 357.4 491.1 917.2 186.5 182.2

Fall 2023 214.6 353.1 493.1 892.5 184.3 180.1 Source: Iowa Department of Education, Enrollment Projections (2020).

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Table 21. Certified and BEDS Enrollment: Fall 2015 to Fall 2023

Year Certified Enrollment BEDS Enrollment Number of Students FTE

Change Percent Change

Number of Students

FTE Change

Percent Change

Essex

2015 203.2 -19 -8.55% 220 -1 -0.45%

2016 196 -7.2 -3.54% 205 -15 -6.82%

2017 194 -2 -1.02% 200 -5 -2.44%

2018 190.5 -3.5 -1.80% 179 -21 -10.50%

2019 187.2 -3.3 -1.73% 157 -22 -12.29%

2020 185.9 -1.3 -0.70% NA NA NA

2021 183.3 -2.6 -1.40% NA NA NA

2022 182.2 -1.1 -0.60% NA NA NA

2023 180.1 -2.1 -1.20% NA NA NA

Fremont-Mills

2015 464 -4 -0.85% 453 0 0.00%

2016 456 -8 -1.72% 457 4 0.88%

2017 452 -4 -0.88% 461 4 0.88%

2018 471.3 19.3 4.27% 468 7 1.52%

2019 464.1 -7.2 -1.53% 465 -3 -0.64%

2020 478.5 14.4 3.10% NA NA NA

2021 484.3 5.8 1.20% NA NA NA

2022 491.1 6.8 1.40% NA NA NA

2023 493.1 2 0.40% NA NA NA

Hamburg

2015 246.2 2 0.82% 182 -25 -12.08%

2016 235 -11.2 -4.55% 160 -22 -12.09%

2017 221 -14 -5.96% 143 -17 -10.63%

2018 227 6 2.71% 139 -4 -2.80%

2019 199 -28 -12.33% 131 -8 -5.76%

2020 221.5 22.5 11.30% NA NA NA

2021 218.4 -3.1 -1.40% NA NA NA

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Year Certified Enrollment BEDS Enrollment Number of Students FTE

Change Percent Change

Number of Students

FTE Change

Percent Change

2022 217.2 -1.2 -0.50% NA NA NA

2023 214.6 -2.6 -1.20% NA NA NA

Shenandoah

2015 1,189.5 10.6 0.90% 1,024 28 2.81%

2016 1,075.7 -113.8 -9.57% 1,046 22 2.15%

2017 1,082.9 7.2 0.67% 1,049 3 0.29%

2018 1,050.7 -32.2 -2.97% 1,033 -16 -1.53%

2019 1,058.4 7.7 0.73% 1,039 6 0.58%

2020 977.6 -80.8 -7.6% NA NA NA

2021 953.5 -24.1 -2.5% NA NA NA

2022 917.2 -36.3 -3.8% NA NA NA

2023 892.5 -24.7 -2.7% NA NA NA

Sidney

2015 332.8 31.2 10.34% 391 57 17.07%

2016 408.9 76.1 22.87% 470 79 20.20%

2017 393.7 -15.2 -3.72% 470 0 0.00%

2018 373.6 -20.1 -5.11% 476 6 1.28%

2019 372.8 -0.8 -0.21% 463 -13 -2.73%

2020 364.5 -8.3 -2.2% NA NA NA

2021 359.5 -5 -1.4% NA NA NA

2022 357.4 -2.1 -0.6% NA NA NA

2023 353.1 -4.3 -1.2% NA NA NA

South Page

2015 187 -12 -6.03% 112 -15 -11.81%

2016 197.9 10.9 5.83% 127 15 13.39%

2017 207.1 9.2 4.65% 132 5 3.94%

2018 195 -12.1 -5.84% 120 -12 -9.09%

2019 207 12 6.15% 110 -10 -8.33%

2020 190.3 -16.7 -8.1% NA NA NA

2021 187.6 -2.7 -1.4% NA NA NA

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Year Certified Enrollment BEDS Enrollment Number of Students FTE

Change Percent Change

Number of Students

FTE Change

Percent Change

2022 186.5 -1.1 -0.6% NA NA NA

2023 184.3 -2.2 -1.2% NA NA NA

Source: Iowa Department of Education, BEDS and Certified Enrollment. Notes. NA = not available. Yellowed cells indicate decrease in enrollment.

Table 22. Student Sharing for Districts with 300 or Fewer Students: 2019-2020

District 2019-20 Certified Enrollment

Sharing

Adair-Casey 297.4 Sends 9-12 to Guthrie Center

Clarksville 295 No student sharing

Harris-Lake Park 292 No student sharing

Villisca 290 Sends 9-12 to Corning

West Bend-Mallard 289.5 Receives 7-12 from Gilmore City-Bradgate

Glidden-Ralston 288 No student sharing

Clay Central Everly 288 Sends 7-12 to Hartley-Melvin-Sanborn, Okoboji, Spencer or Sioux Central

Tri-County 280.8 No student sharing

Laurens-Marathon 276 Sends grades 9-12 to Pocahontas

Ar-We-Va 274 Sends grades 9-12 to Carroll for a partial day

North Kossuth 272.1 Sends 9-12 to North Union

Seymour 266.8 No student sharing

Charter Oak-Ute 265.6 Sends 9-12 to Maple Valley-Anthon Oto

Alden 264.4 Sends grades 7-12 to Iowa Falls

West Central 262 No student sharing, high school has a charter

GMG 259.2 No student sharing

Schleswig 249 Sends 9-12 to Denison

CAL 247.5 Sends 7-12 to Hampton-Dumont

Andrew 234.3 Sends 9-12 to Bellevue or Maquoketa

Murray 230.5 No student sharing

Mormon Trail 229.7 No student sharing

Ruthven-Ayshire 225 Sends grades 9-12 to Graettinger-Terril for partial day

Olin 225 Sends 7-12 to Anamosa or Midland

Albert City-Truesdale 216.9 Sends 7-12 to Sioux Central

Morning Sun 209 Sends 7-12 to Wapello or Winfield-Mt. Union

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District 2019-20 Certified Enrollment

Sharing

South Page 207 Sends 9-12 to Clarinda for a partial day

Paton-Churdan 205.6 Sends 9-12 to Greene County for a partial day

Hamburg 199 Sends grades 9-12 to Sidney

Bennett 194.4 Sends grades 7-12 to Durant and Tipton

Delwood 193.4 Sends grades 7-12 to Maquoketa

Whiting 189.1 No student sharing

Essex 187.2 No student sharing

Orient-Macksburg 172.1 Sends grades 9-12 to Creston for a partial day

Stanton 170 No student sharing

Gilmore City-Bradgate 163 Sends grades 7-12 to West Bend-Mallard

Twin Rivers 150 Sends grades 6-12 to Humboldt

LuVerne 146.1 Sends grades 6-12 to Algona

Stratford 137.9 Sends grades 7-12 to Webster City

Diagonal 102 Sends grades 9-12 to Mount Ayr for partial day Source: Iowa Department Education, Certified Enrollment and Educational Directory (2020). Notes. Hamburg is among 12 districts under 200 students. Of those 12 districts, three are not involved in any high school program full or partial day sharing. Those three districts have had Offer and Teach citations in the past year.

Open Enrollment

Table 23. Students Open Enrolling Out of Hamburg by District: Fall 2015 to Fall 2019

Year CAM Sidney Shenandoah Fremont-Mills

Essex Clayton Ridge

Glenwood Farragut Total

Fall 2015

0 44 2 1 0 0 0 1 48

Fall 2016

0 74 2 2 0 0 0 0 78

Fall 2017

2 67 2 2 0 0 0 0 73

Fall 2018

1 60 2 3 1 0 1 0 68

Fall 2019

1 39 2 1 3 1 0 0 47

Source: Iowa Department of Education.

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Table 24. Students Open Enrolling to Hamburg by District: Fall 2015 to Fall 2019

Year Sidney Shenandoah Fremont-Mills Essex South Page Total Fall 2015 0 2 0 0 0 2 Fall 2016 11 5 0 0 0 16 Fall 2017 10 5 0 0 0 15 Fall 2018 7 3 0 0 0 10 Fall 2019 12 4 0 0 0 16

Source: Iowa Department of Education.

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Map

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Appendix Iowa Code 275.2 Scope of surveys.

1. The scope of the studies and surveys shall include all of the following matters in the various districts in the area education agency and all districts adjacent to the area education agency:

a. The adequacy of the educational program. b. Pupil enrollment. c. Property valuations. d. Existing buildings and equipment. e. Natural community areas. f. Road conditions. g. Transportation. h. Economic factors. i. Individual attention given to the needs of students. j. The opportunity of students to participate in a wide variety of activities related to the total development of

the student. k. Other matters that may bear on educational programs meeting minimum standards required by law. 2. The plans shall also include suggested alternate plans that incorporate the school districts in the area

education agency into reorganized districts that meet the enrollment standards specified in section 275.3 and may include alternate plans proposed by school districts for sharing programs under section 28E.9, 256.13, 280.15, 282.7, or 282.10 as an alternative to school reorganization.

275.3 Minimum size.

No new school district shall be planned by an area education agency board nor shall any proposal for creation or enlargement of any school district be approved by an area education agency board or submitted to electors unless there reside within the proposed limits of such district at least three hundred persons of school age who were enrolled in public schools in the preceding school year. Provided, however, that the director of the department of education shall have authority to grant permission to an area education agency board to approve the formation or enlargement of a school district containing a lower school enrollment than required in this section on the written request of such area education agency board if such request is accompanied by evidence tending to show that sparsity of population, natural barriers or other good reason makes it impracticable to meet the school enrollment requirement.

Iowa Administrative Code 281—15.5(256) Teacher preparation and accessibility.

A teacher appropriately licensed and endorsed for the educational level and content area being taught shall be present and responsible for the instructional program at the receiving site if a presenter of material transmitted via telecommunications is not an appropriately licensed and endorsed teacher for the educational level and content area. If a presenter of material transmitted via telecommunications is an appropriately licensed and endorsed teacher for the educational level and content area, a supervising teacher, or aide to whom a supervising teacher is readily available for consultation, shall supervise and monitor the curriculum and students and be readily accessible to the students. Prior to being assigned initially to deliver instruction via telecommunications, a teacher shall receive training regarding effective practices which enhance learning by telecommunications.

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281—15.6(256) School responsibilities.

Each board of a school district or an accredited nonpublic school employing telecommunications for instruction shall develop policies relative to the use of telecommunications in the delivery of the educational program that are consistent with effective clinical practice. The school district or accredited nonpublic school shall report its use of telecommunications for instruction annually to the department on forms provided by the department. This report shall include:

1. To whom the instruction was delivered including class size, type of class (such as seminar or lecture), and grade level;

2. The course description and schedule of instruction; 3. The number, assignment, licensure including the licensing folder number, and the training received

regarding effective practices which enhance learning by telecommunications of all staff involved in the teaching/learning process at both the origination and the receiving sites; and

4. The type of telecommunications used for course delivery, e.g., Internet, ICN, Polycom, etc.

281—15.7(256) School district responsibilities.

15.7(1) General. Any online coursework offered by a school district shall be offered to resident students of the school district, students attending the school district through a sharing agreement with another school district, or students attending the school district pursuant to Iowa Code section 282.18. Online coursework shall be aligned with the Iowa core standards as applicable and shall be taught by a teacher appropriately licensed and endorsed for the educational level and content area being taught. The teacher may be employed directly by the school district or by a third-party provider of the online curricula used by the school district. Teachers employed by the school district shall be subject to the provisions of Iowa Code chapters 272, 279, and 284. Teachers employed by a third-party provider shall be subject to the provisions of Iowa Code chapter 272; these teachers must be given access to appropriate professional development by the school district, but otherwise are not subject to the provisions of Iowa Code chapters 279 and 284.

15.7(2) Monitoring and supervision. A school district providing educational instruction and course content delivered primarily over the Internet shall do all of the following with regard to such instruction and content:

a. Monitor and verify full-time student enrollment, timely completion of graduation requirements, course credit accrual, and course completion.

b. Monitor and verify student progress and performance in each course through a school-based assessment plan that includes submission of coursework and security and validity of testing components.

c. Conduct parent-teacher conferences. d. Administer assessments required by the state to all students in a proctored setting and pursuant to state

law.