Communications Policy FAQ
The State Charter Schools Commission of Georgia has provided responses to Frequently Asked Questions (FAQs) regarding the State Charter School Communication Policy.
Charter Schools Communication Policy Frequently Asked Questions (FAQs)
What is the State Charter Schools Communication Policy?
The State Charter Schools Communication Policy (Policy) is an administrative procedure that establishes minimum communication standards for state charter schools to report to the State Charter Schools Commission of Georgia (SCSC). The Policy requirements are in addition to, not a replacement of, reporting obligations established by the charter contract, SCSC rules, State Board of Education (SBOE) rules, and state and federal law.
What is the rationale for State Charter Schools Communication Policy?
State charter schools must provide data and report information to the SCSC at specific times throughout the fiscal year, e.g., during the enrollment and data collection process and as a part of SCSC monitoring activities. However, these standardized data collections do not capture important information on an ongoing basis. Although many state charter schools independently report important information, such as safety concerns and changes to governing board membership, the SCSC had yet to establish clear guidelines for what should be reported and when.
Transparency in Communications
Regular and transparent communication between the SCSC and its charter schools promotes a healthy charter/authorizer dynamic. Further, it permits the SCSC to maintain current and accurate information about charter school governance and operations, identify potential problems and signs of distress early, and offer support and intervention when necessary.
When did the Policy go into effect?
Effective Date: January 25, 2023
The Policy was adopted and became effective on January 25, 2023. The Policy is not retroactive. Failure to report required information before the Policy’s adoption does not violate the Policy. However, state charter schools should consider reporting conditions that would have been subject to the Policy before its adoption if it will promote increased transparency. For example, schools are strongly encouraged to report changes to governing board composition, amendments to governing board Bylaws, and changes to key personnel not previously reported to the SCSC.
How was the communication policy developed?
The Policy was developed with input from all SCSC divisions. Division staff identified critical information gaps not otherwise captured during standard data collection processes and considered reporting timelines that would allow the SCSC to execute its obligations more fully. In addition, SCSC staff reviewed reports from national authorizing entities related to improving authorizer/school relations and identifying warning signs of distress in charter schools. The Policy was developed to balance state charter school autonomy and the SCSC’s obligation to hold schools accountable.
More specifically, SCSC staff sought to clarify the requirement that state charter schools communicate promptly with the SCSC by identifying what information should be shared and when. Reporting requirements are intended to be manageable and will typically not require further action from the charter school or SCSC.
The Policy identifies three types of information (and timelines) that must be reported to the SCSC:
General SCSC Notice Requirements (Article II, Section 2);
Immediate SCSC Notice Requirements (Article II, Section 3); and,
Governing Board Meetings (Article II, Section 3).
General SCSC Notice Requirements
The General SCSC Notice Requirements are intended to ensure that the SCSC maintains accurate and current information about state charter schools, including changes to governing board composition and policies, key personnel changes, and matters that may have a long-term impact on school operations, such as budgetary shortfalls, the assumption of debt, and possible litigation.
Immediate SCSC Notice Requirements
The Immediate SCSC Notice requirements reflect the SCSC’s need to be aware of conditions that immediately disrupt charter school operations; and, thus, should be prudently communicated to the SCSC.
Governing Board Meetings
The Governing Board Meetings notice requirement aligns with an existing charter contract provision that requires the state charter school governing board to notify the SCSC if it schedules any meeting other than a regularly scheduled meeting with less than twenty-four (24) hours’ notice.
How should information subject to the Policy be reported to the SCSC Executive Director?
The Policy requires that reports be made to the SCSC Executive Director or designee. For purposes of this Policy, the Executive Director’s designee is the SCSC Office Coordinator. Reports must be submitted using the State Charter Schools Commission web form here. The web form will timestamp and date all submissions. When making a report, include all information requested to ensure the report is routed to the appropriate SCSC division and that follow-up, if required, is timely.
The SCSC may, on a case-by-case basis, consider oral (telephone) reports or direct email messages to the SCSC Office Coordinator compliant with the Policy. In making compliance determinations, the SCSC will consider the extent to which the report is general, immediate, or notice of a special called governing board meeting and the nature and severity of the reported conditions. For example, if a charter school calls the SCSC Office Coordinator to report that its digital or electronic information systems have been compromised, the SCSC may consider that phone call complaint with the Policy, given that the circumstances might impede immediate access to the SCSC reporting web form.
How should schools determine what information must be reported pursuant the Article II, Section 3 (Immediate SCSC Notice Requirements)?
Article II, Section 3
Article II, Section 3 (Immediate SCSC Notice Requirements) aims to ensure the SCSC is aware of conditions that immediately disrupt charter school operations or otherwise threaten the health, safety, or welfare of the school’s students, staff, or visitors. Charter schools should consider these goals when determining whether to report information.
How should schools determine when to make a report under Article II, Section 3(a) – circumstances that place the health, safety, or welfare of the state charter school’s students, staff, volunteers, or visitors at risk?
Article II, Section 3(a)
Article II, Section 3(a) requires schools to report circumstances that place the health, safety, or welfare of the state charter school’s students, staff, volunteers, or visitors at risk. Considering the aims of this provision, a school should not report individual instances of illness or accidents that occur on campus if the single incident does not rise to the level of disrupting charter school operations (e.g., school closure) or pose a risk to the school or campus or at large.
As written, this provision requires a discretionary determination by the school as to what qualifies as a health, safety, or welfare risk. In determining whether a particular situation qualifies, the school should consider factors such as the likelihood of severe harm to students, staff, volunteers or visitors. Regarding illnesses in particular, the school should consider the severity of the disease, common availability of treatment, disruption to school operations, and the number of students, staff, volunteers, or visitors at risk in determining whether the situation requires reporting to SCSC.
Should school report trainings, such as fire and tornado drills, under Article II, Section 3(c)-initiation of the procedures or protocols in the school safety plan required by O.C.G.A. § 20-2-1185?
Article II, Section 3(c)
Article II, Section 3(c) also requires schools to report “initiation of the procedures or protocols in the school safety plan required by O.C.G.A. § 20-2-1185.” O.C.G.A. § 20-2-1185 is intended to ensure that schools have safety plans to (1) help curb the growing incidence of violence in schools; (2) respond effectively to such incidents; and (3) provide a safe learning environment for Georgia’s children, teachers, and other school personnel.
School safety plans must address staff training, plan updates, strengthening partnerships, and enhancing crisis communication plans. However, schools are not required to report procedures or protocols referenced in the school safety plan that are not directly responsive to natural disasters, hazardous materials, radiological accidents, acts of violence or acts of terrorism, or other circumstances that cause immediate campus-wide disruptions or impact the health and safety of the school community on a broad level.
Because safety plans are school-specific and not generally publicized, when deciding what information to report, the charter school should determine whether it is initiating school safety protocols for training or planning or if it is doing so because there is a campus-wide threat. For example, a school should not report a fire or other drill under this provision. School safety plan procedures initiated for the primary purpose of practice, preparation, or training are not subject to the Policy.
On the other hand, if a school initiates lockdown procedures under its school safety plan in response to a tornado warning in its area, the school should make a report to the SCSC because it is explicitly responding to conditions that disrupt operations and place the school community at risk. However, a school would not need to report a tornado watch if there is no immediate risk.
In interpreting the Policy, schools are encouraged to use reasonable discretion and to act in good faith to comply with the language and intent of the Policy. The Policy does not contemplate all specific circumstances that may disrupt school operations or place the school community a risk. The SCSC will respect school autonomy, applied reasonably, in determining whether a particular situation warrants an SCSC report.
9. Must minor disruptions to school communications systems be reported under Article II, Section 3(f)-scheduled or unanticipated disruptions to the school’s communication systems?
Article II, Section 3(f)
Article II, Section 3(f) requires schools to report scheduled or unanticipated disruptions to the school’s communication systems, including but not limited to disruptions to the school’s telephone lines; digital communication system; website; or data, information, or physical security breaches. For practical purposes, the school should interpret this requirement to apply when stakeholders’ ability to contact the school is significantly impacted.
For example, the school would not need to report one five-minute disruption to its communication system on the weekend. Alternatively, if systems are down for an hour during the school day, the school must notify the SCSC.
Whom can schools contact if they have questions about the Policy’s application?
If you have additional questions about the application of this Policy, please contact SCSC General Counsel, Cerrone Lockett.Cerrone Lockett