The Massachusetts Board of Elementary and Secondary Education

Charter Schools — Recommendation to Renew the Charter of City on a Hill Charter Public School New Bedford with Probation

Members of the Board of Elementary and Secondary Education
Jeffrey C. Riley, Commissioner
January 11, 2019

This month, the Board of Elementary and Secondary Education (Board) will discuss and vote on the charter renewal application for City on a Hill Charter Public School, New Bedford (CoaH NB). I recommend that the Board renew the school's charter and place it on probation with the conditions described later in this memorandum.

City on a Hill Charter Public School, New Bedford
Type of Charter
(Commonwealth or Horace Mann)
CommonwealthLocationNew Bedford
Regional or Non-RegionalNon-RegionalDistricts in Region
(if applicable)
Year Opened2014Year(s) Renewed
(if applicable)
Maximum Enrollment280Current Enrollment217 (as of October 2018)
Chartered Grade Span9–12Current Grade Span9–12
Students on Waitlist0 (as of March 2018)Current Age of School5 years
Mission Statement
City on a Hill New Bedford graduates responsible, resourceful, and respectful democratic citizens prepared for college and to advance community, culture, and commerce, and to compete in the 21st century. We do so by emphasizing academic achievement, citizenship, teacher leadership, and public accountability.

School History

City on a Hill Charter Public School New Bedford (CoaH NB) is part of a three-school network of charter schools. The original City on a Hill Charter Public School, now known as City on a Hill Circuit Street (CoaH CS), opened in Boston in 1995. In 2012, CoaH CS's board of trustees applied to open two additional charter schools, another one in Boston and one in New Bedford. The Board granted the two charters; City on a Hill Dudley Square opened in Boston in 2013, followed by City on a Hill New Bedford in 2014.

When CoaH CS's board of trustees was granted two additional charters, it also established a network office to provide services to all three schools in the CoaH network of charter schools1. Since 2013, three people have served as executive director for the network of charter schools. In May 2018, the board of trustees hired a permanent chief executive officer, rather than an executive director, who began in June 2018. During the 2017-2018 school year, teachers and non-instructional staff across the City on a Hill network engaged in discussions with the Boston Teachers Union (BTU), eventually voting to join the BTU. Negotiations between the board of trustees and the union are ongoing; no contracts have been signed yet.

Basis of Recommendations Regarding the Renewal of Charters

The charter school regulations state that "[t]he decision by the Board to renew a charter shall be based upon the presentation of affirmative evidence regarding the success of the school's academic program; the viability of the school as an organization, including the extent to which the school has followed its recruitment and retention plan; and the faithfulness of the school to the terms of its charter." 603 CMR 1.11(2). Consistent with the regulations, recommendations regarding renewal are based upon the Department of Elementary and Secondary Education's (Department) evaluation of the school's performance in these areas as outlined in the Charter School Performance Criteria and the memorandum dated October 7, 2013, regarding Considerations for Charter School Renewal. In its review, the Department has considered the school's absolute performance at the time of the application for renewal and the progress the school has made during the past four years of its charter. The accountability process for charter schools recognizes that in exchange for increased freedom, a school must demonstrate results within the term of its five-year charter or risk non-renewal or other possible sanctions, including revocation.

The superintendent of the public school district served by CoaH NB was invited to submit written comment to the Department regarding the renewal of the school's charter. The superintendent of New Bedford submitted comment in which he stated concerns about CoaH NB's attrition, drop-out, and attendance data as well as low teacher and staff retention data. The mayor of New Bedford also provided written comment to the Department to express opposition to the renewal of CoaH NB's charter, citing concerns about student attrition and academic performance. Evidence related to the superintendent's and mayor's concerns is presented below.

Recommendation for Board Action

Based upon the evidence described in the attached Summary of Review, I recommend that the Board renew the school's charter and place it on probation with conditions requiring major improvements in the school's faithfulness to its charter as well as academic program and performance. I am not recommending non-renewal at this time because the school is making efforts to address these deficiencies.

My recommendation to place the school on probation with conditions is based on concerns regarding whether the school is operating in a manner faithful to its mission and key design elements and concerns regarding the school's academic performance. CoaH NB is in its fifth year of operation. While a relatively new school, it received a charter to replicate the proven model of City on a Hill Charter Public School, Circuit Street. I expect a charter granted to a "proven provider" as used in the charter school statute to deliver a robust program of study. Instead, the school has failed to demonstrate consistent academic success. In fact, the school's MCAS scores have declined during its first charter term. The recent hiring of a permanent chief executive officer for the network of charter schools, and recent changes to staffing and academic programming, give me hope that the school will be able to address these issues.

I have additional concerns about the school's rates of attrition and rates of suspension for some student subgroups. My hope is that, through probationary conditions, the school will develop a plan and work to improve the school's academic programming, decrease attrition, and decrease the use of suspension. The Department will monitor the school closely during the next few years.

Evidence relating to my concerns follows.

Lack of Faithfulness to the Charter

Information collected during site visits and other data from the charter term reflects limited evidence of successful implementation of the school's mission envisioned in its final charter application to prepare students to "compete in the 21st century."

City on a Hill Charter Public School New Bedford graduated its first senior class in 2018. Early post-secondary data do not demonstrate success in preparing students for college. During the past two years, the school's drop-out rate increased and was above state averages at 5.6 percent; and chronic absenteeism increased to 34.3 percent in 2018. During the charter term, attrition rates remained high for rising grade 10 students at approximately 20 percent, and suspension rates remained much higher than statewide averages.

The Department found limited evidence that CoaH NB fully implemented its key design elements of academic achievement, citizenship, teacher leadership, and public accountability. During classroom observations, the Department found limited evidence of high expectations, student engagement, and environments conducive to learning. Additionally, the Department found limited evidence that CoaH NB has successfully implemented programming aligned with its goal of teaching citizenship to students or that it has fully provided teachers with leadership opportunities.

The Department also gathered evidence that the school is making efforts to realign its programming with its mission and key design elements. During the October 2018 renewal inspection, the board reported that the current network and school leadership teams have made efforts to refocus the network and school on meeting the school's mission and implementing the key design elements with fidelity. School and network leaders reported that, based on declining academic data, the school restructured its leadership team, ended its contract with City Year, and hired additional staff for its tutorial program.

The Summary of Review, attached to this memorandum, also notes concerns with the degree to which CoaH NB is providing students with equitable access to the school's program. The school has been successful in recruiting a student population demographically comparable to its sending districts. During the 2017-2018 school year, CoaH NB enrolled the following percentages of student subgroups: 29.7 percent students with disabilities, 17.4 percent English learners, and 68.6 students who are economically disadvantaged. Attrition rates, however, have been variable, sometimes above and sometimes below the median attrition rates for comparison schools. Additionally, during the charter term, the school suspended students at rates higher than the statewide average. The school has participated in the Department's Rethinking Discipline Professional Learning Network (PLN) since 2016. The PLN works to reduce the inappropriate or excessive use of long-term suspensions and expulsions, including disproportionate rates of suspensions for students with disabilities and students of color. The school has recently begun implementing a restorative justice model in its efforts to reduce suspensions.

The Summary of Review contains the additional concern that CoaH NB is not providing physical education as required by state law.

Lack of Academic Program Success

During its first charter term, CoaH NB has not demonstrated progress in student academic achievement. In 2018, CoaH NB is classified as requiring assistance or intervention, met 46 percent of its improvement targets, and is performing in the 4th percentile when compared to other high schools statewide. While CoaH NB is a relatively new school, I have grave concerns about its poor academic outcomes. CoaH NB is connected to the well-established City on a Hill Charter Public School, Circuit Street. I expect that CoaH NB would have benefitted from the experience and established systems of the flagship charter school.

For the past three testing cycles, CoaH NB administered legacy grade 10 MCAS tests. In 2018, 81 percent of CoaH NB grade 10 students earned proficient or advanced in English language arts (ELA), 44 percent earned proficient or advanced in mathematics, and 47 percent earned proficient or advanced on the science and engineering/technology assessment. All 2018 grade 10 MCAS results were below state averages, but above results of New Bedford High School for ELA and science and engineering/technology. Composite Performance Index (CPI) scores have shown an overall decline in all three subject areas from the 2016 assessment to the 2018 assessment. Student growth percentile (SGP) data demonstrate low to the adequate growth range for the past three grade 10 cohorts. The school's 2018 grade 10 SGPs were 43.4 for ELA and 41.3 for mathematics, below New Bedford High School's SGPs for its grade 10 students (47.1 and 47.3, respectively).

Due to its age, CoaH NB does not have graduation data for its 2018 class. In 2016 and 2017, the school's dropout rate was 5.0 and 5.6 percent respectively, compared to the statewide average of 1.9 and 1.8 percent, and New Bedford High School's rates of 4.4 and 2.7 percent, respectively.

As noted above, throughout the charter term, the Department observed a lack of high quality instruction during multiple visits to the school. Specifically, the Department gathered evidence of inconsistent implementation of the school's expected instructional practices, a lack of high expectations for students, a lack of student engagement, and classroom environments that were not always respectful or conducive to learning.

Conditions Imposed with Probation and Charter Renewal

I recommend that the Board vote to place CoaH NB on probation and impose the conditions that follow on the school's charter.

Condition 1: Until further notice, the school must submit to the Department of Elementary and Secondary Education (Department), at or 75 Pleasant Street, Malden, MA 02148, board meeting agendas, materials, and minutes prior to each board meeting at the same time that these items are sent to the school's board members. Additionally, if board materials do not already include this information, the school must also submit monthly financial statements.

Condition 2: By February 28, 2019, CoaH NB must submit evidence to the Department that it has provided the school community with notice of the school's renewal and that the school's charter has been placed on probation with conditions that the school must meet. The school must inform parents/guardians, teachers, staff, board members, students, and other community members of the school's current status.

Condition 3: By April 30, 2019, CoaH NB must submit to the Department a comprehensive evaluation of the school's mathematics, English language arts, and science programs. Additionally, the comprehensive evaluation should address school climate, student discipline practices, and retention of students. Such comprehensive evaluation must be conducted by an external consultant(s) acceptable to and approved in advance by the Department. The evaluation must be informed by disaggregated performance data from the statewide accountability system and aligned with the Charter School Performance Criteria.

Condition 4: By May 31, 2019, the school must submit to the Department for approval a comprehensive action plan (action plan) for improving academic performance and addressing other areas for improvement identified by the comprehensive evaluation. Such action plan must include a needs assessment aligned to the 2018 statewide accountability results for CoaH NB. The action plan must also specify the evidence-based strategies the school will use to improve performance in mathematics, English language arts, and science for all student subgroups. The plan should also include strategies to improve school climate, student discipline practices, and retention of students. The action plan must set clear and specific implementation benchmarks, with a clear timetable and deadlines for completion of key tasks, sufficient to allow the school's board of trustees and the Department to monitor implementation. The school must provide evidence that it has shared its improvement plan with the school's community including, but not limited to, students, parents, and staff.

Condition 5: By December 31, 2020, the school must demonstrate that it is an academic success by providing evidence that the school has exhibited significant and sustained academic improvement in mathematics, English language arts, and science on the statewide assessment. Further, in its next accountability plan, CoaH NB must articulate measures it will take beyond the statewide assessment to demonstrate student academic achievement in all grades through a valid and externally verifiable assessment. If CoaH NB does not demonstrate academic improvement by December 31, 2019, the Commissioner and the Board of Elementary and Secondary Education will take further action including, but not limited to, revocation of the school's charter.

In addition to meeting the terms of probation, CoaH NB, like all charter schools, must also comply with the terms of its charter. Failure of CoaH NB to meet the conditions placed on renewal of its charter within the timelines specified may result in immediate suspension and revocation of the school's charter. I will review and report to the Board on CoaH NB's success or lack of success in meeting the terms of probation.


If you have any questions regarding this recommendation or require additional information, please contact Alison Bagg, Director (781-338-3218); Cliff Chuang, Senior Associate Commissioner (781-338-3222); or me.


Download Word Document
Summary of Review for City on a Hill Charter Public School, New Bedford, School's response to Summary of Review, as needed.

Comment received from Mayor Mitchell

Comment received from Superintendent Anderson



1 CoaH network staff are employees of the flagship school (CoaH CS) and the other two charter schools in the network pay a fee (based on a percentage of tuition) to the flagship for its administrative/operational support.