Educational Service Center of Lake Erie West Community Schools Center

Targeted Intervention Procedures

The Educational Service Center of Lake Erie West, Community Schools Center (“Sponsor”) is responsible to provide monitoring, oversight, and technical assistance to the community schools (“Schools”) that it sponsors. The Sponsor and Schools have included in the community school contracts as Attachment 11.6 a Performance Accountability Framework detailing the several ways in which the Sponsor assesses the performance of each School, the general conditions that trigger intervention, and the various interventions and technical assistance that the Sponsor may utilize.

Academic Intervention and Assistance

Designation on the Ohio Local Report Card of a D or F in any measure, a drop of more than one grade level in any component or measure, or designation of “Does Not Meet Standards” for a dropout prevention and recovery school will trigger targeted intervention for a School. The Sponsor also requires targeted intervention for any academic contract goal that the School fails to meet, as delineated in Section C of Attachment 11.6.

Within thirty (30) days of receipt of such a local report card designation or of failing to meet an academic contract goal, the School must submit to the Sponsor all data that make up the relevant measure(s), or component(s) of the measure. The School must list each component with all proof of accurate data to support it.

The Sponsor will work the School’s Chief Academic Officer or his/her designee to develop a Corrective Action Plan (“CAP”), which must be finalized within thirty (30) days of receipt of relevant data. All academic interventions require a thorough data-driven understanding of weaknesses, based on data derived from assessment tools selected in conjunction with the Sponsor and a targeted plan to cure that particular weakness or those weaknesses.	The CAP must be reviewed by the School’s Governing Authority prior to finalization.

Once the CAP is finalized, the School must report to the Sponsor on a monthly basis with a narrative as to how the plan is achieving progress and any relevant data, if applicable. Should the School fail to make adequate or appropriate progress, the plan may be re-evaluated and changed, with either additional interventions or supplements to the existing interventions. Such progress reports must also be submitted to the School’s Governing Authority.

Non-Academic Contract Goal and Other Contract Violation Intervention and Assistance

The Sponsor will assess the School’s progress toward meeting its non-academic contract goals, as delineated in Section C of Attachment 11.6, as a part of its annual evaluation and report to the School. If the School has failed to meet or is not on track toward meeting any of these contract goals, or if the Sponsor has identified any additional material weakness, the Sponsor will notify the School’s Chief Administrative Officer, Governing Authority President, and Operator, if applicable.

The Sponsor will also provide notification to the School’s Chief Administrative Officer, Governing Authority President, and Operator, if applicable, for all material contract violations or other violations of federal or state law, rules, or regulations, within ten (10) business days of actual knowledge of such a violation.

Educational Service Center of Lake Erie West Community Schools Center

The School must cure the identified violation or weakness within thirty (30) days, or within a reasonable timeframe agreed upon with the Sponsor, depending on the nature of the circumstances. If the School has not presented adequate evidence of having cured the violation within this timeframe, the Sponsor will work with the School’s Chief Administrative Officer or his/her designee to develop a CAP, which must be finalized within thirty (30) days. The CAP must be reviewed by the School’s Governing Authority prior to finalization.

Once the CAP is finalized, the School must report to the Sponsor on a monthly basis with a narrative as to how the plan is achieving progress and any relevant data, if applicable. Should the School fail to make adequate or appropriate progress, the plan may be re-evaluated and changed, with either additional interventions or supplements to the existing interventions. Such progress reports must also be submitted to the School’s Governing Authority.

Probation, Suspension, and Termination

If a School does not cooperate with the Sponsor in the CAP process or adhere to and participate in the required interventions, or if the School fails to cure the identified deficiency, the School may be subject to additional discipline, at the discretion of the Sponsor.

Probation, which may lead to suspension, may be used for any cause allowed by the Ohio Revised Code, including but not limited to:
	Untimely submissions or lack of cooperation in submissions required by the State or the Sponsor for two (2) or more times per year, or for over five (5) business days
	Lack of compliance with laws or the Contract
	Failure to achieve academic goals, as listed in the Performance Accountability Framework 	Any fiscal matter of any level of risk
	Governance, administrative, or minor financial issues that can be adequately corrected by CAP acceptable to Sponsor
	Potential or actual ethics or conflicts violations

Suspension, which may lead to termination, is more likely to be used for matters such as, but not limited to:
	Health or safety matters
	Consistent failure to achieve academic goals, despite CAPs and technical assistance
	Money owed to the State or its agencies, vendors, or Sponsor that is delinquent, overextended, or may or does render insolvency
	Inability to make payroll
	Undisclosed debt or obligations
	Lack of accuracy in or misrepresentation, cheating, or fraud in any reporting figures, data, or testing results that is not corrected within timeframes allowed by law or which create financial, reputational, governance or academic risk
	Other matters of noncompliance, the magnitude or risk of which may be assessed by Sponsor as good cause or allowed by the Code
	Uncorrected or actual ethics or conflict violations
	Inability to meet, or lack of progress in meeting, the terms of the Contract, the laws, rules, regulations or requirements, or the reasonable requests of Sponsor geared to correct deficiencies as cited in a probation notice or corresponding CAP

Educational Service Center of Lake Erie West Community Schools Center

Termination of the Contract will occur if the School fails to develop a CAP or fails to comply with or remedy the problems cited in the CAP developed with the Sponsor as part of a suspension.

Non-Renewal and Permanent Closure

Upon the expiration of the Contract, the Sponsor may renew the Contract pursuant to R.C. 3314.03(E). Corrective action may be required at the discretion of the Sponsor as a condition of renewal. Prior to its determination, the Sponsor shall conduct a high stakes review or evaluation and provide the School with a cumulative report on its findings and on the School’s performance over the contract term.

The Sponsor may choose not to renew the Contract for (1) failure to meet student performance requirements stated in the Contract; (2) failure to meet generally accepted standards of fiscal management; (3) violation of any provision of the Contract or applicable state or federal law; or (4) other good cause.

Renewal decisions are based upon an analysis of the following:
	the School’s progress in meeting the educational program listed in Attachment 6.3; 	the School’s progress in meeting the Academic Goals listed in Attachment 11.6;
	the School’s progress in meeting the Non-Academic Goals listed in Attachment 11.6;
	the School’s progress or performance on actions required by CAPs or other interventions, if any; 	the degree to which the School is compliant with the terms of the Contract;
	the School’s fiscal viability and financial audits; 	the School’s organizational viability; and
	other good cause.

Permanent closure under R.C. 3314.35 or 3314.351 will occur under the following circumstances:
	For schools with grades no higher than 3, for two of the past three years, the school has either been in academic emergency, received an F in improving literacy in grades K-3, or received an overall F.
	For schools with grades 4-8, but no higher than 9, for two of the past three years, the school has either been in academic emergency and not met value-added growth, received an F for the performance index score and an F for value-added progress, or received an overall F and an F for value-added progress.
	For schools with grades 10-12 that are not drop-out recovery schools, for two of the past three years, the school has either been in academic emergency, received an F for the performance index score and not met AMOs, or has received an overall F and an F for value-added progress
	For drop-out recovery and prevention program schools, for two of the past three years and beginning on July 1, 2014, the school received a designation of “does not meet standards.”

Currently, schools in which a majority of the enrolled students are children with disabilities receiving special education and related services are exempt from statutory closure on the basis of academic performance. However, the Sponsor may discipline or non-renew a special education status school on the basis of academic performance or other cause as indicated in the Contract.