The Massachusetts Board of Elementary and Secondary Education

Charter Schools - Request by Pioneer Valley Chinese Immersion Charter School for Review of Commissioner's Decision

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The board of trustees of the Pioneer Valley Chinese Immersion Charter School (PVCICS) has requested that the Board of Elementary and Secondary Education (Board) review my decision to not recommend an increase of the school's maximum enrollment from 584 to 952 students. The charter school regulations, 603 CMR 1.10(8), state that "should the Commissioner (of Elementary and Secondary Education) deny an amendment request, the charter school's board of trustees may seek review of the Commissioner's decision by the Board." At its June 25, 2019 meeting, the Board will review and discuss the basis for my decision and consider the school's request in light of the evidence gathered and presented by the Department of Elementary and Secondary Education (Department). Representatives of the school will be present at the June meeting to provide information to the Board. Department staff will also be available to answer your questions.

In 2007, the Board granted a charter to PVCICS to serve 300 students in grades K–8. The school has requested increases in enrollment eight times since it opened in 2007. The Board granted one such request from the school in 2013, increasing the school's maximum enrollment to 584 students and expanding the school's grade span to K–12.

In August 2018, the Department received PVCICS's eighth request to increase the school's maximum enrollment. The school requested an additional 368 seats in order to double student enrollment in its elementary grades. The Department evaluated the school's request by following the process and criteria used to evaluate all other such amendment requests. After review of the request was completed, I informed PVCICS in a letter dated January 17, 2019, that I would not recommend the increase to the Board, for several reasons. The request of PVCICS and its vision for a K–12 school do not align with the requirements of the charter school statute, regulations, and the criteria for approval of amendments in the Department's Charter Amendment and Notification Guidelines (Amendment Guidelines) and the Charter School Performance Criteria. Most importantly, PVCICS has not provided evidence of enrollment demand comparable with other expansion requests that the Board has approved and has not revised its enrollment numbers to align with overall demand. Over its 12-year history, PVCICS has consistently fallen short of its annual enrollment projections and its maximum enrollment, and it currently enrolls 55 students fewer than its maximum enrollment. Further, the enrollment capacity in districts from which the school primarily draws students is decreasing both as the student population decreases and as the net school spending caps in those districts are reached.

This memorandum summarizes the Department's review process for charter amendments and the options for the Board when a school seeks review of my decision; the school's request submitted on August 1, 2018, and the Department's review of the request; and the context for my decision to not recommend this expansion request to the Board for approval.

Charter Amendments Subject to Board Approval and Reviews of Denial

Under the charter school regulations, the Board approves amendments to a charter with respect to grade span, maximum enrollment, districts served, and a contract with an education management organization. 603 CMR 1.10(1). The regulations describe the scope of review of such amendment requests. "The Commissioner and the Board may consider a charter school's compliance with applicable state, federal, and local law and evidence regarding the three areas set forth in 603 CMR 1.11(2) in reaching a determination regarding a school's request to amend its charter." 603 CMR 1.10(3). The "three areas" stated in 603 CMR 1.11(2) are "faithfulness of the school to the terms of its charter, including the extent to which the school has followed its recruitment and retention plan and has disseminated best practices in accordance with M.G.L. c. 71, § 89(dd); the success of the school's academic program; and the viability of the school as an organization." Requests for amendments are considered each year, and charter schools with unsuccessful requests may reapply in following years.

The Department's review of proposed charter amendments that are subject to Board approval includes the following considerations:

• The charter school's compliance with applicable state, federal, and local law;
• Affirmative, credible evidence regarding the faithfulness of the school to the terms of its charter, including the extent to which the school has followed its recruitment and retention plan and has disseminated best practices;
• Affirmative, credible evidence regarding the success of the school's academic program; Affirmative, credible evidence regarding the viability of the school as an organization;
• The merits of the school's amendment request when judged against the criteria outlined in the Department's Amendment Guidelines and the Charter School Performance Criteria;
• The eligibility of the board of trustees for proven provider status based upon the criteria described in 603 CMR 1.04(4)¹; and
• the public comment received regarding the request.

These considerations align with the charter school statute and regulations and the application, accountability, and renewal application processes for charter schools.

When the Commissioner presents an amendment request to the Board for consideration, the Commissioner has determined that the request has substantially met the criteria for approval. In cases where the Commissioner declines to bring a charter school's amendment request to the Board for consideration, the school's board of trustees may ask the Board to review that decision. In reviewing a decision of the Commissioner, the Board in general may:

• Vote to approve the school's amendment request, notwithstanding the Commissioner's objections;
• Vote to deny the amendment request, based upon the reasons the Commissioner has presented;
• Vote to approve a modified version of the school's request, although it is challenging to do so and ensure adequate consideration of the variables involved, including how the school would prepare for and implement an enrollment growth plan different from what was originally proposed and whether a proven provider determination is required and has been made by the Commissioner; or
• Take no formal action, in which case the denial stands for the reasons presented by the Commissioner.

School Summary and History of Expansion Requests

PVCICS has requested an expansion eight times since opening in 2007, with one request granted in 2013. Attached in Table A is a history of the school's requests for expansion. PVCICS opened with 42 students in kindergarten and first grade and added an additional grade each year as students progressed through the school's grade span, reaching its full K–8 grade span by the time of its first renewal in 2012. Attached in Table B is the school's actual enrollment by grade from 2007 through 2019. PVCICS submitted two expansion requests during its first charter term, in 2008 and 2010; these were denied because the school had not yet established a track record of performance.

In 2013, the Board granted PVCICS an expansion to increase enrollment from 300 to 584 students and to offer grades 9–12. This was approximately one year after the school's second charter renewal and concurrent with the Board's decision to remove conditions from the school's charter.⁵ At the time of the Board's decision, the school's approved growth plan projected completion of its expansion by the time of the Board's next renewal decision in 2016-2017. (See Attachments for Table C, the school's growth plan to grow to a K–12 school serving 584 students.)

For two of the school's expansion requests, in 2012 and 2016, PVCICS submitted sufficient evidence to merit a Commissioner recommendation for additional enrollment. In both instances, however, the Commissioner's recommendation reflected a modification of the school's original request due to ongoing concerns regarding demand. For the 2016 request, the recommendation included a conditional, time-bound approval contingent upon the school reaching certain enrollment levels. The Board did not approve the modified enrollment increase.⁶

In its eighth and most recent (2018) request, PVCICS requested an increase of 368 seats to reach a total enrollment of 952 students in grades K–12.⁷ The table below outlines several different enrollment patterns proposed by the school since it opened and the school's current enrollment for the 2018-2019 school year and its approved growth plan to reach 584 students.

PVCICS's 2018 request proposed to double its enrollment in grades K–5 to increase access for families seeking enrollment through the kindergarten entry point while maintaining its current staffing model in these grades. In addition, the charter school statute requires schools to fill vacancies in grades K–6 when students leave, resulting in a consistent cohort size in grades K–6. The school's 2018 proposal reflected a slight decrease from the total number of seats requested in the school's three prior submissions. The school had proposed total enrollment of 1,036 students in its 2017 request and reduced that to 952 total students in the 2018 request by increasing its estimated attrition rates for grades 7–12, as noted above in the table, and by eliminating entry of new students at ninth grade.

As of October 1, 2018, PVCICS's enrollment has not yet reached the school's approved maximum enrollment of 584; the school enrolled 529 students during the 2018-2019 school year. The school reports two reasons for its enrollment below its current maximum enrollment: the school's addition to the facility, completed in 2015, was not sufficient to accommodate full enrollment under the 2013 expansion to 584, and the school experiences significant traffic "congestion" in their parking lot at the beginning and end of the school day. The school has made additional renovations to create more space and buses students to another location to ease congestion at arrival and dismissal. In its 2017-2018 annual report, PVCICS reported a capital plan for a facility addition and indicated "PVCICS will be submitting an updated charter amendment to secure authorization for additional student seats needed to justify financing the addition."

Department Review of 2018 Request

The Department recognizes that requests for expansion require differentiation based upon the type of expansion proposed, enrollment or grade span, and the size of the requested enrollment increase. The Department's Amendment Guidelines provide specific criteria and require schools to demonstrate the capacity to implement the proposed request while maintaining or improving the school's performance. The Department's review process is designed to ensure that any proposed expansion is consistent with applicable law and the Charter School Performance Criteria while preserving the discretion of the Commissioner and Board to make these decisions based on the totality of evidence presented by the charter school.

The Department conducts a multi-step review after receiving a request for expansion. All requests are reviewed against the criteria in the Department's Amendment Guidelines and through the lens of our charter school accountability framework, which includes a performance review of the school's current charter term and the most recent renewal. Documentation includes, but is not limited to, the school's response to the Amendment Guidelines criteria, the most recent site visit reports and renewal documentation, annual reports, accountability plans, recruitment and retention plans, financial audits, and student performance metrics, including metrics required for a proven provider determination. Additionally, if a school proposes a substantial expansion that is eligible for federal Charter School Program grants, the Department also interviews representatives of the school similar to what occurs during the charter application process.

The Department followed this same process and used the same criteria that are used to evaluate all other such amendment requests. The Department interviewed school leaders and officers of the PVCICS board of trustees in December 2018 to address specific concerns that arose during the review of the amendment request, including assessment of demand and governance practices related to oversight of school leadership. The Department also solicited public comment in response to the school's request, including from superintendents of sending districts within the school's charter region.

The Department's review of expansion requests also intersects with its administration of the net school spending (NSS) caps⁹ for all cities and towns where residents choose to enroll at Commonwealth charter schools. Based on a number of factors, the number of seats available under NSS caps changes on an annual basis. Because of the mandatory language in the charter school statute, the Department has multiple systems to monitor, to publish, and to notify districts, operating charter schools, and groups seeking to open a charter of NSS caps and seats remaining under these caps.

The calculation of the number of seats available is always based upon the projection of several variables and the best available information. Because of the complicated nature of these projections and their inherently changeable nature, the Department imposes a buffer on seats available to protect against year-to-year variations and the possibility that charter school tuition would be pro-rated should total charter tuition in any district exceed its NSS cap. The Department uses these annual projections in evaluating evidence of demand and expansion requests by charter schools. The Commissioner avoids recommending expansion requests that would threaten a charter school's financial viability due to limited or lack of seats available under relevant NSS caps.

In addition to the considerations above, in cases where a school's charter region includes districts performing in the lowest 10 percent of the Commonwealth's school districts, the Commissioner must evaluate the school's performance and determine whether the school qualifies as a proven provider, as defined in 603 CMR 1.04(4), for the school to be eligible for additional seats. PVCICS's charter region includes five districts currently identified as being in the lowest 10 percent. These districts include Easthampton, Hawlemont, Holyoke, Greenfield, and Springfield.¹⁰ Therefore, the Commissioner would need to determine that the school is a proven provider in order for PVCICS to be eligible for additional seats.

When I decline to recommend a request for expansion, as in this case, it is based upon consideration of the relevant evidence and the requirements of the charter school statute, regulations, and the criteria in the Amendment Guidelines and the Charter School Performance Criteria. I am unable to recommend a request that fails to demonstrate the need for an expansion and, in particular, fails to provide evidence of enrollment demand comparable with other expansion requests that the Board has approved. PVCICS failed to adequately address concerns around the misalignment of the proposed size of the school and historical patterns of student enrollment, applications for admission, waitlists, and the diminishing number of seats available under the NSS caps in the districts where demand is most evident and from which the school has historically received most of its applications and students. Additionally, in order to lower the overall proposed enrollment, the school proposed a model that assumes significant rates of attrition, particularly at the high school level, that are at odds with the directives of the charter school statute.

Evidence Relevant to Decision

I considered PVCICS's request on its merits and in the context of the Department's amendment review process. In my consideration of all expansion requests by a charter school board of trustees, evidence of enrollment demand aligned to the proposed growth is paramount, and the board of trustees must articulate this evidence consistent with the requirements of state law. An expansion proposed by an existing charter school must be supported by evidence that the school has ongoing, substantial enrollment demand from students in districts from which it actually will be able to enroll students and move beyond simply sustaining current enrollment. The adage "build it and they will come" is not a policy that the Commissioner or Board has adopted or followed in authorizing or expanding charter schools.

In evaluating PVCICS's request, I reviewed a variety of indicators of demand¹¹ in an effort to corroborate the school's assertion that there is substantial interest in the school from families in surrounding districts and a significant opportunity to move beyond current enrollment levels. I did not come to the same conclusion as PVCICS. Based upon the evidence provided in the attached tables, I have concluded that the proposed increase is not supported by a historical demand for enrollment, applications for admission, or the school's waitlist. I have also concluded that the school's proposed growth is predicated upon increased enrollment from districts where charter school enrollment is already near its NSS cap or where demand is not yet evident.

The school has never met its pre-enrollment targets and has consistently fallen short of its targets in its approved growth plan since its approved expansion in 2013.

Please see Table B attached to this memorandum for the historical enrollment patterns at PVCICS. The school has not yet reached its maximum enrollment, as evidenced by its inability to meet the targets in its approved growth plan in Table C. The school projected that it would reach its maximum of 584 students in 2016-2017. Currently the school enrolls 529 students, as indicated in Table B. In every year of its operation, PVCICS has not had sufficient applications for admission to reach full enrollment. As seen in Table D, PVCICS's actual enrollment has never met its pre-enrollment targets and, at times, has fallen short of its targets by a substantial margin.

The school's waitlist demonstrates insufficient demand for the proposed increase to 952 students.

Please see Table E attached to this memorandum for the school's waitlist data over time. The school's waitlist history does not demonstrate sufficient demand to support an additional 368 seats. While PVCICS's waitlists have demonstrated demand for the kindergarten entry point, waitlists at every other grade level are not sufficient to support increases to the proposed levels at grades 1–6 through backfilling, as required by law. Please see the Department's compiled waitlist reports for a comparison of enrollment demand at PVCICS against that of other charter schools.

While still limited, the school's greatest enrollment demand comes from districts approaching their NSS caps. Based upon projections, the majority of new students must come from districts within the school's region that are not currently represented in its applicant pool.

Overall, population trends indicate an ongoing and sustained decrease in public school enrollment in the school's charter region; total public school enrollment in that region has decreased by over 5,400 students since PVCICS opened in 2007. An overwhelming majority of communities within the school's region have experienced a decrease in public school enrollment, with the exception of four communities, including Springfield and West Springfield.¹² See Table F. Additionally, data regarding the school's enrollment and applications demonstrate that demand is most evident in districts where the number of seats available under the NSS caps are rapidly decreasing and from which students will not be eligible to enroll. Please see Tables G and H attached to this memorandum for a summary of the enrollment trends at PVCICS and the seats projected to have been available within the school's region for the upcoming 2019-2020 school year.

As stated above, it is the Department's obligation to provide analysis, publication, and notice of annual limits on charter school enrollment by sending district. It is the obligation of any charter school seeking an expansion, or an applicant for a new charter, to assess how enrollment limits affect availability of additional seats and to assess potential sources of demand for such seats. PVCICS has been unaware of these trends in seat availability within its region or has been unsuccessful in recruiting or retaining students from districts where seats may continue to remain under NSS caps.

The school's proposed growth plan and assumed attrition are at odds with the directives of the charter school statute.

The policies codified in the 2010 revision of the charter school statute and the subsequent regulatory revisions are designed to ensure broad and equitable student access to all Commonwealth charter schools and to eliminate obstacles to enrollment and attendance. The 2010 amendments to the charter school statute specifically created new expectations for the recruitment and retention of students. PVCICS proposed its original enrollment growth plan in its 2006 charter application before the statute was amended. The school originally proposed a K–8 grade span serving 300 students, with two sections of 20–22 students in kindergarten and first grade, the school's only entry points. With an enrollment of 40–44 kindergarten students assumed and no new students admitted after first grade, the school originally planned for significant attrition through grades 2–8 to ensure the school did not violate the terms of its charter by exceeding the total maximum enrollment of 300 students at its full grade span.

This type of enrollment plan, with assumed attrition, is no longer a viable choice under the current charter school statute. In 2010, the charter school statute was amended, adding new statutory requirements to backfill vacancies,¹³ to create and augment recruitment and retention plans,¹⁴ and to retain students.¹⁵ The changed statute made impermissible significant planned attrition in the first half of the school's grade span.

Consistent with the statutory directives, the Board and Department have supported charter school proposals that increase access across a school's grade span rather than limiting access to a single-entry point or default to backfilling only the first half of grades as required. In prior Board decisions to award substantial expansions, schools have proposed or maintained access beyond the requirements envisioned by the statute. Alma del Mar Charter School and Benjamin Franklin Classical Charter School permit entry at all grades in their K–8 schools. Charter schools that have expanded to include high school grades permit new enrollment in high school grades, exceeding statutory requirements; these schools include Excel Academy Charter School, Atlantis Charter School, Roxbury Preparatory Charter School, and Neighborhood House Charter School. Other schools that have expanded maximum enrollment have continued their commitment to access through maintaining or introducing access in high school grades, including South Shore Charter Public School, Pioneer Charter School of Science, Boston Preparatory Charter School, and Boston Collegiate Charter School.

In the school's 2016 request, PVCICS committed to providing entry points beyond statutory requirements. The school committed to accepting new students in grades K–6 and to expanding enrollment of new students to fill vacancies in grades 6–9, which exceeded the statutory requirement to fill vacant seats. This year, PVCICS's request to increase the school's maximum enrollment to 952 students eliminated the backfilling of vacancies beyond grade 6, eliminated the entry point at grade 9, and increased the estimated rate of attrition in grades 7–12. See Table A.

The Department is bound by the charter school statute and its commitment to ensure equitable access to charter schools for students seeking enrollment and for those currently enrolled in a charter school. In that light, I cannot recommend a proposal that limits access and plans for increased student attrition.

Conclusion

The Department has consistently encouraged PVCICS to integrate its vision for a K–12 Chinese language immersion school, including an IB Diploma Programme in grades 11 and 12, with its historical enrollment patterns. In its three most recent expansion requests, the school made adjustments based upon discussions with the Department regarding demand and the school's educational model. The 2017 and 2018 requests included higher cohort sizes in the elementary grades, where the school has experienced consistent demand for kindergarten seats in recent years, and lower cohort sizes in the middle and high school grades, where the school has not yet established the same evidence of demand. These requests, however, failed to supply sufficient evidence of demand for the number of seats requested.

Based on the lack of compelling evidence that the school can maintain sustained enrollment under the proposed growth plan it submitted as part of the 2018 request, I did not recommend the request. Further, it is not the Department's role to map out an alternative growth plan for PVCICS; that is the role of the school's board of trustees. In short, for the school to present an approvable expansion request, it must address the concerns the Department has identified.

As noted above, the Board may take any of the actions that follow on the school's request for review of my decision.

• Vote to approve the school's amendment request, notwithstanding the Commissioner's objections.
• Vote to deny the amendment request, based upon the reasons the Commissioner has presented.
• Vote to approve a modified version of the school's request, addressing how the school would prepare for and implement an enrollment growth plan different from what was originally proposed and whether a proven provider determination has been made by the Commissioner; or
• Take no formal action, in which case the denial stands for the reasons presented by the Commissioner.

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If you have any questions regarding the school's request for review or require additional information, please contact me; Jeff Wulfson, Deputy Commissioner; Cliff Chuang, Senior Associate Commissioner; or Alison Bagg, Director of Charter Schools and School Redesign.

Enclosures:

The following documents are public records and are available upon request.*

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* Due to the volume of documents, limited web server space, and the Department's commitment to achieving meaningful accessibility to this online environment for all users, but most particularly for users with disabilities (we follow specific Commonwealth Enterprise Standards designed to meet the needs of our citizens with disabilities), we are unable to post this document on our webpage. Please send an email to boe@doe.mass.edu to request the document and we will respond promptly. Thank you.

¹ If a request for an expansion meets the criteria for approval in a community with a net school spending cap above 9 percent, the Commissioner then examines the evidence and determines whether the charter school meets the criteria to be a "proven provider." Proven providers must meet the performance criteria described in 603 CMR 1.04(4) ("evidence, satisfactory to the Commissioner, to demonstrate a significant management or leadership role at a school or similar program that is an academic success, a viable organization, and relevant to the proposed charter school"; emphasis added). The Commissioner has not made a determination with respect to proven provider for PVCICS this year because the school's request for an expansion did not meet the criteria for approval; a proven provider determination by the Commissioner would be required prior to the award of any additional seats to PVCICS.

² These districts include Agawam, Amherst, Amherst-Pelham, Belchertown, Chesterfield-Goshen, Chicopee, Conway, Deerfield, East Longmeadow, Easthampton, Frontier, Gill-Montague, Granby, Greenfield, Hadley, Hampden-Wilbraham, Hampshire, Hatfield, Hawlemont, Holyoke, Leverett, Longmeadow, Ludlow, Mohawk Trail, Northampton, Pelham, Pioneer Valley, Shutesbury, South Hadley, Southampton, Springfield, Sunderland, West Springfield, Westfield, Westhampton, Whately, Williamsburg, and Southwick-Tolland-Granville.

³ As reported in the Student Information Management System (SIMS) as of October 1, 2018.

⁴ As reported in the Massachusetts Charter School Waitlist Report Update for 2018-2019 from October 1, 2018. The school initially reported 144 students on the waitlist in March 2018 after the school's principal lottery. Fifty-one students were removed from the waitlist between the initial report in March and the follow-up report in October. The school reported that 48 new students were added to the waitlist after the principal lottery.

⁵ In February 2013, the Board removed the 2012 conditions and approved a modified charter amendment to increase the school's maximum enrollment to 584 students and to add high school grades. At the time, the Commissioner's recommendation and the Board's approval of the additional 284 seats was 100 seats fewer than the school's request but aligned to the school's proposed growth plan. The Commissioner indicated that any additional requests for growth should be submitted in connection with the school's next renewal in 2017, once the high school grades were fully implemented and demand for the maximum enrollment of 684 students as proposed by the school could be supported by evidence. The approval of the high school grades also permitted the implementation of an IB Diploma Programme in grades 11 and 12.

⁶ In 2016, concurrent with submitting its renewal application, PVCICS submitted a request to increase its enrollment from 584 to 1,144 students. In response to the Department's concerns regarding evidence of demand, the school decreased its request to 1,036 students by assuming student attrition in grades 7-12. The Commissioner's recommendation to the Board in February 2017 included a condition that if the school failed to increase student enrollment consistent with the growth plan in its revised enrollment policy or failed to report at least 800 students enrolled on October 1, 2021, the Board could have reduced the school's maximum enrollment accordingly.

⁷ Department staff received a copy of the proposed growth plan on July 20, 2018, in advance of the school's submission on August 1, 2018. The Department scheduled a phone call for July 30, 2018 with representatives of PVCICS to discuss the school's methods to determining the proposed maximum enrollment and growth plan. Tim Nicolette of the Massachusetts Charter Public School Association joined the call to facilitate.

⁸ The school subsequently identified that the total maximum enrollment originally awarded to the school would not accommodate enrollment at its full grade span due to attrition rates that were lower than anticipated and the change in the 2010 charter school statute requiring backfilling of vacancies.

⁹ Under the charter school law, generally no more than 9 percent of a district's net school spending may be transferred to Commonwealth charter schools. In districts that perform in the lowest 10 percent of all school districts, including Springfield and Holyoke, the cap on charter tuitions is increased to 18 percent.

¹⁰ Springfield had exceeded its 9 percent NSS cap at the time of this request; there were approximately 425 seats remaining in last year's projections. Hawlemont and Holyoke were closed to significant new enrollment due to only 13 seats and 43 seats projected to remain under their respective NSS caps in last year's projections. Easthampton and Greenfield still had seats remaining under their 9 percent NSS caps in our projections, 53 and 76 seats respectively, with additional seats available under the 18 percent NSS cap.

¹¹ In soliciting evidence related to these considerations, the Amendment Guidelines direct charter schools seeking an increase in enrollment to provide ample evidence of: "the progress made in attracting, enrolling, and retaining a student population that is demographically comparable to similar grades in schools from which the existing charter school(s) enrolls students," "sufficient parent support to fill existing and proposed seats," and "a historical pattern of an increase in submitted admission applications, and a growing population of eligible students in local region."

¹² Chicopee and Greenfield experienced very modest increases in overall enrollment during this same period.

¹³ The charter school statute provides as follows.

G.L. c. 71, § 89(n).

¹⁴ Under G.L. c. 71, § 89(e)(xvi), "a student recruitment and retention plan, including deliberate, specific strategies the school will use to ensure the provision of equal educational opportunity" and "to attract, enroll and retain a student population that, when compared to students in similar grades in schools from which the charter school is expected to enroll students, contains a comparable academic and demographic profile."

¹⁵ Under G.L. c. 71, § 89(f), the recruitment and retention plan shall contain "a detailed description of deliberate, specific strategies . . .to maximize the number of students who successfully complete all school requirements and prevent students from dropping out." "When deciding on charter renewal, the board shall take into account the annual attrition of students." G.L. c. 71, § 89(dd).