Public Comment: 

DC Public Charter School Board’s Mergers and Acquisitions Policy

Jessica Giles 

Executive Director, DC Office

Center for Strong Public Schools Action Fund

The Washington, DC Office of the Center for Strong Public Schools Action Fund (Action Fund) is pleased to submit a public comment to the DC Public Charter School Board (PCSB) on its draft Mergers and Acquisitions policy. 

The Action Fund is committed to ensuring every student—especially Black, Brown, and low-income students—has access to a high-quality, well-run traditional public or public charter school, regardless of their zip code. Families deserve true, high-quality public school choice, and that choice must come with the assurance of safety, rigor, and strong outcomes. 

Why Mergers & Acquisitions Must Be Done Well

When public schools are not delivering on the promise of a quality education, closure must remain an option but it cannot be the only option. We have seen firsthand how abrupt closures destabilize entire communities: students displaced, families scrambling, educators uncertain about their future. Much of this is preventable.

The draft Mergers and Acquisitions Policy offers DC PCSB a chance to add a much-needed tool to its toolbox—a tool that, when used well, can strengthen school quality, preserve stability, and expand opportunity. When a struggling school can be paired thoughtfully with a strong operator, outcomes improve. We appreciate that DC PCSB is recognizing this and taking steps to build a responsible framework.

Areas of Strength

The draft policy reflects many best practices. It is ensures oversight, requires transparency, and includes essential components—clear eligibility thresholds, an emphasis on performance, finance, and organizational capacity, and thoughtful set of pathways. These are strong foundations. Several areas, however, should be strengthened to ensure that mergers and acquisitions are never used as a back door for low-quality growth. 

Recommendations to Strengthen the Policy

1. Student Protection Must Be More Explicit

“Inclusiveness” is the right goal, but the draft lacks detail on student transition logistics. PCSB should require:

• Guaranteed continuation of IEP and 504 services
• Enrollment protections for all impacted students
• Records transfer protocols
• Transportation and scheduling continuity
• A clear plan for English Language Learners, students with disabilities, and at-risk supports

Students must experience stability, not disruption.

2. Personnel Transition Planning Is Essential

Human capital determines school quality. PCSB should require a detailed personnel transition plan including:

• Leadership and staffing chart
• HR transition timelines
• Special education staffing considerations
• Teacher credential verification and onboarding
• Analysis of impacts on staff compensation and benefits

     3. Community Engagement Must Have Minimum Standards

The draft encourages community and family engagement but does not outline what meaningful engagement requires. PCSB should require a publicly posted engagement plan that includes:

• Meeting dates, formats, and language access
• Summaries of feedback from families, staff, and students

• Public meeting notices and agendas
• Posting of merger/acquisition plans on both LEA and PCSB websites

Families deserve transparency and clear communication.

     4. Planning Year Expectations Need Clarity

The policy mentions a planning year but not what is expected during it. PCSB should outline:

• Planning year milestones
• Quarterly progress reviews
• A readiness-to-open process for merged or acquired schools

This ensures quality and prevents rushed or underprepared openings.

     5. Emergency Acquisitions

Emergency acquisitions should only occur under extreme circumstance. Their very existence signals that intervention came too late. PCSB must:

• • Ensure gatekeeping stays strong. Urgency does not justify waiving readiness or quality expectations. A larger LEA is not automatically a more capable one. PCSB must preserve rigorous standards even under pressure. 

• Continue oversight post-crisis for 1–3 years, since nationwide emergency acquisitions often unravel in years 2 or 3. This oversight should include quarterly academic and financial check-ins, monitoring of SPED and ELL service continuity, and early-warning metrics and flags.

Lastly, PCSB must lead on school quality by maintaining a proactive role: supporting boards, setting expectations for quality governance, identifying distress early, and monitoring key metrics regularly. Stronger early-warning systems and shared accountability structures can prevent emergencies altogether. 

DC’s students deserve nothing less than excellent schools—every ward, every neighborhood, every day. When done thoughtfully, mergers and acquisitions can be tools that protect school quality, preserve stability, and expand opportunity. When done poorly, they risk harm to the very communities they are meant to serve.

We appreciate DC PCSB’s leadership in proposing this policy and look forward to partnering to ensure that DC leads the nation with strong public schools.

Resources:

Aspire Public Schools and Oakland Unified School District. Community Impact and School Consolidation Planning Documents. Aspire/OUSD, 2021. https://resources.finalsite.net/images/v1758908928/ousdorg/wdsai0ic81lbhloincbq/ACAMR_CommunityImpactQuestionnaire1.pdf 

Bankert, Lina, and Lauren Schwartze. “When Done Right, Mergers Can Improve Student Outcomes and Save Schools Money: Here Are 4 Lessons for Ed Leaders.” The 74 Million, 1 Dec. 2019. the74million.org/article/bankert-schwartze-when-done-right-mergers-can-improve-student-outcomes-and-save-schools-money-here-are-4-lessons-for-ed-leaders/ 

Bellwether Education Partners. Nine Considerations for Charter School Mergers in an Era of Limited Budgets. Bellwether, 2020. https://bellwether.org/blog/9-considerations-for-charter-school-mergers-in-an-era-of-limited-budgets-2/ 

Bross, Whitney, Douglas N. Harris, and Lihan Liu. “The Effects of Performance-Based School Closure and Charter Takeover on Student Performance.” Education Research Alliance for New Orleans, 2016. https://educationresearchalliancenola.org/files/publications/Bross-Harris-Liu-The-Effects-of-Performance-Based-School-Closure-and-Charter-Takeover-on-Student-Performance.pdf 

Center on Reinventing Public Education (CRPE). Lake, Robin. Performance Management in Portfolio School Districts. CRPE, 2009. https://files.eric.ed.gov/fulltext/ED532895.pdf 

“Conscious Coupling: Exploring and Executing Charter Mergers and Partnerships.” Bellwether Education Partners Blog, 10 Oct. 2024. bellwether.org/blog/conscious-coupling-exploring-and-executing-charter-mergers-and-partnerships/ 

Indiana Charter School Board (ICSB). ACE Preparatory Academy and Circle City Prep Merger Materials. ICSB, 2025. https://www.in.gov/icsb/files/S2025-ACE-CCP-Merger-Application-Supplemental.pdf 

Minnesota Department of Education. Charter School Merger Guidance. MDE, 2023. https://education.mn.gov/mdeprod/idcplg?IdcService=GET_FILE&dDocName=MDE074053&RevisionSelectionMethod=latestReleased&Rendition=primary  

NACSA (National Association for Charter School Authorizers). Principles & Standards for Quality Charter School Authorizing. NACSA, 2023. qualitycharters.org/resource-center/principles-standards 

New York State Education Department (NYSED). Procedures for Merging Education Corporations. NYSED Charter School Office, 2020. https://www.nysed.gov/sites/default/files/programs/charter-schools/10-27-21-final-sed-charter-merger-guidelines.pdf 

SUNY Charter Schools Institute. Guide to Merging Education Corporations. SUNY Charter Schools Institute, 2020. https://www.newyorkcharters.org/wp-content/uploads/Guide-to-Merger.Final_.11.13.2020.pdf 

The Elliott School of International Affairs and Education Research Alliance for New Orleans. Back to the Future? The Evolution of Charter Governance and Accountability in New Orleans. ERA–New Orleans, 2023. educationresearchalliancenola.org/publications/back-to-the-future-charter-governance-new-orleans