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Resolution Agreement
Grand Rapids Public School District (MI)

Resolution Agreement
Grand Rapids Public School District
OCR Docket No. 15-08-5001

The Grand Rapids Public School District (District) enters this Agreement to resolve the proactive compliance review, OCR Docket No. 15-08-5001, conducted by the U.S. Department of Education (Department), Office for Civil Rights (OCR). The review addressed whether African American students are provided equal access to and an equal opportunity to participate in rigorous college and career preparatory courses within the District.  During the course of this review, the District also began implementation of its “Transformation Plan,” which was adopted by the District Board of Education in December 2012 and has resulted in the closure and transfer of a number of schools and programs. The District enters this Agreement to ensure its compliance with the requirements of Title VI of the Civil Rights Act of 1964 (Title VI), 42 U.S.C. § 2000d et seq., as amended, and its implementing regulation at 34 C.F.R. Part 100, which prohibit discrimination on the basis of race, color and national origin by recipients of Federal financial assistance from the Department. Accordingly, the District agrees to implement the action steps set forth below:

ACTION STEPS

I.  CONSULTANT

By December 3, 2013, the District will retain a consultant with expertise in addressing the underrepresentation of African American students in college and career preparatory courses to study and make recommendations as to what measures the District will take as part of its ongoing efforts to provide all students with equal access to and an equal opportunity to participate in:

  1. college and career preparatory courses offered by the District, including the District’s International Baccalaureate (IB) program at City Middle/High School, Advanced Placement (AP) courses, dual enrollment courses, Centers of Innovation, and high school honors courses;
  2. three specialty sixty-grade feeder schools (i.e., Zoo, Blandford, and the Center for Economicology);1
  3. foundation courses at the elementary, middle school and high school level, i.e., those courses that are necessary for enrollment in later CCP or specialty courses/programs/schools.

The consultant will examine and make recommendations to address the root cause(s) of any disparity in enrollment of African American students in these programs, course and schools. The consultant may be an independent contractor for the District or a District employee. The District, after retaining its consultant, shall promptly provide the consultant with all appropriate information the consultant believes is necessary to engage in this process.  At a minimum, the consultant will provide recommendations to and assist the District, as requested, with Action Step II below.

Action Step I - Reporting Requirement

  • By December 3, 2013, the District will submit documentation to OCR showing implementation of Action Step I, including the date the consultant was retained, a copy of the consultant’s bio or resume or other summary of the consultant’s qualifications and experience, the consultant’s name, statement regarding whether the consultant is a District employee or independent contractor, specific responsibilities (including term of any contract) and qualifications of the consultant retained by the District.

II.  REVIEW AND ASSESSMENT BY DISTRICT

By January 10, 2013, the District will complete a review and assessment of the District’s courses, programs and school identified in Action Step I.1 above for the 2008-2009 to 2013-2014 school years. As part of its review and assessment, the District, at a minimum, will:

  1. review enrollment data, including trend data (i.e., student enrollment data for each course, program, and school identified in Action Step I.1, for each year, disaggregated by race and grade);
  2. review the correlation between enrollment in the identified elementary/middle school courses, programs, and school in Action Step I.1 and later enrollment in CCP high school courses, programs and schools;
  3. review the correlation between elementary and middle school performance and subsequent enrollment in CCP high school courses, programs and schools, including the correlation between the courses students elect to enroll in during high school and their elementary and middle school academic profiles (e.g., grades, previous test scores, other indicators) and any additional support provided for students (such as counseling, peer mentoring groups, or tutoring or rigorous academic preparation) at the elementary and middle school levels to prepare them for CCP courses at the high school level;
  4. review and assess any potential barriers to increased student participation in the CCP courses, programs and school identified in Action Step I.1 relating to:
    1. the location, number, and subject matter of such course offerings, programs and schools;
    2. participation (or lack of participation) in such courses, programs, and schools;
    3. transportation to and from the location where the courses and programs are offered;
    4. the lack of a structured program of course offerings or lack of available foundation courses at the elementary school and middle schools (such as eighth grade algebra or foreign language courses) to prepare students for more rigorous courses later in their education;
    5. any District enrollment, registration, or other policies and procedures related to enrollment in such courses or programs, including the District’s Student Academic Request (STAR) system;
    6. teacher qualifications to teach such courses or programs;
    7. communication and outreach to students and parents/guardians about these courses, programs and school;
    8. advertisement of such courses, programs and schools;
    9. peer pressure;
    10. lack of requirement that parents/guardians approve student course selection(s) at the high school;
    11. early awareness on the part of parents/guardians/students of the relationship between the elementary/middle school curriculum and the high school curriculum for college and career readiness;
    12. the role of guidance counselor services;
    13. support services for students enrolled in such courses, programs or schools or preparing to enroll in them;
    14. identify any other potential barriers to increased student participation in courses, programs and school identified in Action Step I.1; and
    15. identify any other potential barriers to increased student participation not listed above.

  5. review and assess methods by which the District may expand the CCP programs, and courses identified in Action Step I.1 to additional building locations in the District to increase access to and opportunities for student participation in these programs and courses;
  6. review and assess which methods undertaken by the District, to date, have been effective (or ineffective) for early awareness and in encouraging student participation in the programs, courses and schools identified in Action Step I.1, starting at the elementary school level;
  7. By January 29, 2014, host meetings for interested District parents/guardians and age-appropriate meetings for interested 1st through twelfth grade students to share information about the programs, courses and school identified in Action Step I.1, identify any perceived barriers to increased enrollment and solicit recommendations for increasing enrollment.  The District will ensure that it effectively and widely disseminates notice of the meeting in appropriate language(s) and will hold the meeting at a time and place that it reasonably believes to be most convenient for parents/guardians and will work with parents/guardians and community leaders to encourage attendance;
  8. By January 29, 2014, develop and administer a survey to offer to parents of students in grades 3-7 and students and their parents in grades 8-11, and relevant staff, the opportunity to submit information about their perceptions and understanding with respect to the recruitment, selection, and/or participation of students in the programs, courses and school identified in Action Step I.1;
  9. By January 29, 2014, schedule a reasonable number of date(s)/time(s) for interviews to offer relevant school administrators, faculty and staff, and parents/guardians and students of the District, the opportunity to submit information about their perceptions and understanding with respect to the recruitment, selection and/or participation in the programs, course and school identified in Action Step I.1;
  10. consider the impact of the 2013 closure of Creston High School and the relocation of Grand Rapids Pre-College Engineering Program (GRAPCEP) to Central High School on the access of African American students to CCP courses, programs and schools and, if there has been a negative educational impact on the affected students, identify appropriate support, transition or other services for the District to provide and a timeline for the services to be provided;
  11. consider the impact of the 2013 relocation and expansion of City Middle/High School and the 6th grade Center for Economicology to the former Creston High School building on the access of African American students to CCP courses, programs and school and, if there has been a negative educational impact on the affected students, identify appropriate support, transition or other services for the District to provide and a timeline for the services to be provided; and
  12. consult with other similar, public school districts concerning effective methods for increasing student enrollment in CCP courses, programs, and schools.

Action Step II - Reporting Requirement

  • By February 12, 2014, the District will submit documentation to OCR showing implementation of the actions required by Action Step II above, including but not limited to a copy of the District’s assessment, including any trend data; any identified barriers to student enrollment in such courses or programs; a detailed description of the effectiveness of methods undertaken by the District to encourage participation and to consider preparation of students beginning at the elementary school level; the date(s), location(s), and time(s) of any meeting(s) held pursuant to II.A.7, including a copy of the meeting minutes, participant lists; etc.; a copy of the survey, including the results, a list of the individuals interviewed, by name, title, etc., and a summary of information gathered pursuant to II.A.9; and a list of school districts or other organizations consulted by the District, including notes of such consultations and any related data collected pursuant to II.A.12.

III.  CONSULTANT RECOMMENDATIONS

  1. By February 12, 2014, in collaboration with the consultant, the District will review the results of the assessment of past enrollment in the courses, programs and schools identified in Action Step I.1 conducted in accordance with Action Step II.A.1-6, as well as the surveys and interviews, and any consultations, conducted in accordance with Action Step II.A.7-12.
  2. By February 12, 2014, the District shall obtain from the consultant a written report outlining the recommendations relating to measures the District could take to further facilitate its efforts to provide all students with equal access to and an equal opportunity to participate in the courses, programs and schools identified in Action Step I.1.
  3. By February 26, 2014, the District will consider and identify what action it will take with respect to the recommendations made by the consultant, based on Action Step II.A.1-6 above, and to incorporate those recommendations into the action plan it develops. If the District rejects and/or modifies any recommendations made by the consultant(s), the District will provide to OCR a reasonably comprehensive explanation for the rejection or the modification of the recommendation.
  4. By June 30, 2014, and by the same date annually thereafter, the District will submit documents to OCR showing implementation of any further modifications to its programs made pursuant to Action Step II above.

Action Step III - Reporting Requirement

  • By February 21, 2014, the District will provide to OCR a copy of the consultant’s written report outlining the consultant’s recommendations after the completion of the District’s review and assessment of past enrollment, interviews, and surveys in conjunction with the Action Steps above; and
  • By February 28, 2014, the District will provide to OCR its response to the recommendations made by the consultant and its plan for implementing recommendations made by the consultant.  If the District rejects and/or modifies any recommendations made by the consultant, the District will provide to OCR a reasonably comprehensive explanation for the rejection or the modification of the recommendation.

IV.  ELIGIBILITY/SELECTION CRITERIA

  1. By March 12, 2014, after reviewing the recommendations of the consultant, the District will consider whether to revise and/or expand its eligibility and selection criteria for the CCP courses, programs and schools identified in Action Step I.1 in order to further facilitate its efforts to provide all students with equal access and an equal opportunity to participate.  The District also will ensure that:
    1. if it retains the criteria currently utilized for identification/selection rubrics, it will specifically consider whether a modest modification of such criteria (such as considering classroom performance) would result in an increase of students that would be considered for participation and an increase in participation by African American students;
    2. any District/school personnel responsible for conducting any assessments or evaluations as part of the identification/selection process will receive consistent and accurate training in the implementation of any additional, revised or modified criteria; and adequate instruction on how to access information regarding students’ eligibility;
    3. it provides students at the elementary and middle school level information and assistance to ensure that such students are well prepared for receiving any assessments or evaluations that remain part of the identification/selection process;
    4. the District’s appeal processes for students who apply to but are not selected for enrollment in the District’s CCP courses, programs and schools, as applicable, are clearly set forth in the District’s application materials, in letters sent to such students informing them that they were not selected, and in the District’s policies related to the selection process.  The information will fully explain how appeals are handled, including all applicable time frames, necessary documentation to support an appeal, and definitions of all terms related to an appeal (e.g., “special circumstances” that would constitute acceptable grounds for an appeal); and
    5. any revised or expanded criteria adopted by the District will be used to determine eligibility and selection for enrollment in these programs beginning with the 2014-2015 school year.

Action Step IV - Reporting Requirement

  • By June 30, 2014, and by the same date annually thereafter, if any further changes are made, the District will provide OCR with documentation that the revised or expanded criteria were disseminated.  After the District’s adoption of the revised or expanded criteria, if any, the District will update any relevant printed publications and on-line publications with the revised or expanded criteria within a prompt and reasonable timeframe.  Inserts may be used in printed publications until re-printing.  Thereafter, the District will disseminate the revised or expanded criteria to all relevant students, their parents/guardians, administrators, teachers and staff of the District within a prompt and reasonable timeframe, and will utilize the revised or expanded criteria to determine eligibility and selection for enrollment in City Middle/High School and its specialty feeder schools, beginning with the 2014-2015 school year.

V.  PARENT/GUARDIAN AND STUDENT OUTREACH

  1. By March 12, 2014, after reviewing the recommendations of the consultant, the District will determine whether changes are needed to its current outreach plan for the parents/guardians of elementary, middle, and high school students regarding its CCP courses, programs and schools.  If not already being done as part of its outreach plan, the District will ensure that the outreach conducted at each elementary, middle, and high school sites includes at a minimum:
    1. a description of the benefits and opportunities available to students in its CCP courses, programs and school, and any applicable changes made at the elementary and middle school level District-wide to prepare students for success in such programs;
    2. information regarding the identification/selection process for the aforementioned courses/programs/school, including information about the importance of taking foundation courses in the elementary and middle school years to prepare students for enrollment in later courses, programs, school;
    3. information regarding the identification/selection criteria (such as test scores) for the District’s CCP courses, programs and school;
    4. the name(s) and contact information for the committee or coordinators for the District’s CCP courses, program, and schools at the parent/guardian’s respective school site and at the District’s main administrative office; and
    5. information regarding how to appeal decisions made regarding the identification and selection of students for such programs, courses, and schools.

  2. The District will also consider outreach to community organizations, including those that are in regular contact with the parents/guardians of African American students regarding the opportunities and benefits of these programs, courses, and schools as well as the importance of the foundation courses in elementary and middle school.
  3. By March 12, 2014, after reviewing the recommendations of the consultant, the District will determine whether changes are needed to its current outreach plan for students.  If not already being done as part of its targeted outreach plan, at a minimum, the outreach activities should include peer presentations on a voluntary basis by available and interested African American students enrolled in such courses and programs regarding their experiences in such courses and programs.  The District may consider and implement others actions not otherwise described in this Agreement in an effort to increase student participation, including race/ethnic-targeted recruitment and outreach efforts to directly encourage African American students to consider participation.

Action Step V – Reporting Requirement

  • By June 30, 2014, and annually by the same date thereafter, the District will provide to OCR documentation demonstrating that the parent/guardian and student outreach plans were implemented during the previous school year consistent with Action Step V above, including copies of any written notices or other correspondence, and details and documentation of any events held with parents/guardians and students.

VI.  ACADEMIC COUNSELING SERVICES

  1. By March 28, 2014, after reviewing the recommendations of the consultant, the District will determine whether changes are needed to its current academic counseling services at the middle school and high school levels and make any changes necessary to ensure that all students receive counseling that:
    1. informs each student of all available program and course options and encourages participation in these programs and courses, including foundation courses and course progression at the District’s elementary and middle schools, as applicable. This will include individual counseling as well as inclusion of information on the District’s CCP courses, programs and schools in any information sessions provided to students about middle and high school enrollment and the college application process. These sessions may include presentations by college admissions coordinators and testimonials from a diverse group of students and from their parents/guardians, as well as from teachers and principals;
    2. allows each student to meaningfully consider enrollment in the programs, courses, and schools that are most likely to meet their educational needs and objectives;
    3. advises students of the significance given to CCP courses, programs and schools by colleges and universities in the admissions process and of the opportunity to receive college credit for certain AP, IB, and dual enrollment courses; and
    4. directly and personally encourages each student to enroll in programs or courses that are appropriately challenging and will appropriately prepare each student for CCP courses and programs and later for higher education.

The District will thereafter continue to assess its counseling services to ensure that all students are reasonably informed of all available and relevant program and course options, including information on the District’s CCP courses, programs and schools.

Action Step VI - Reporting Requirement

  • By June 30, 2014, and by the same date annually thereafter, the District will provide to OCR documentation demonstrating that academic counseling services were reasonably implemented during the previous school year consistent with Action Step VI above, including, but not limited to, a description of how these services were provided to students.

VII.  TRANSFORMATION PLAN

As used in this Agreement:

“Receiving school” means all schools that received students due to school closures or student reassignments resulting from the implementation of the District’s Transformation Plan (the Plan).

“Displaced students” means all students whose school assignment changed due to school closures or student reassignments made pursuant to the implementation of the Plan.

  1. The District agrees to implement the Transformation Plan adopted by the District’s Board of Education in December 2012 in a manner that is consistent with Title VI.  The District agrees, at a minimum, to:
    1. inform OCR of any major changes to the Plan 90 calendar days prior to the scheduled implementation date of the changes or immediately after adoption by the board of education;
    2. ensure that the academic programs and extracurricular activities provided to displaced students at their new schools are of the same or better quality than those at their closing schools; and
    3. designate a School Transition Coordinator (School Coordinator) to be responsible for coordinating the overall transition of displaced students on a District-wide basis. The Coordinator will, based on the recommendations of the expert described in the Action Steps above, ensure that affected students are provided appropriate and timely support, transition or other services related to the closures of their schools. The Coordinator will ensure that students negatively affected by future school closures receive appropriate and timely support, transition or other services related to the closures of their schools

Action Step VII - Reporting Requirements

  • By December 20, 2013, the District will submit documentation to OCR showing implementation of Action Step VII above, including the date the Transition Coordinator was selected, a copy of the coordinator’s bio or resume or other summary of the Coordinator’s qualifications and experience, the Coordinator’s name and title, a statement regarding whether the Coordinator is a District employee or independent contractor, specific responsibilities (including term of any contract); and qualifications of the Coordinator.
  • By January 29, 2014, the District will submit documentation to OCR a copy of the timetable and action steps to be completed, and by whom.
  • Within 30 calendar days after each action step specified on the timetable, the District will submit documentation to OCR showing implementation of the Action Step.

VIII.  TRAINING FOR DISTRICT STAFF/ADMINISTRATORS

  1. By March 28, 2014, after reviewing the recommendations of the consultant, the District will determine whether changes are needed to its current training plan for relevant District and school site administrators, counselors and teaching staff regarding its CCP courses, programs and schools and its foundation courses at its elementary and middle schools. If not already being done, any training plan will include, at a minimum:
    1. an assessment that ensures that teachers are qualified to teach in the areas they have been assigned to teach and that counselors provided accurate information about the District’s CCP programs, courses and schools;
    2. a review of the enrollment demographics for students enrolled in the District’s CCP courses, programs, and schools, including enrollment at each CCP course, program and school, by race, at each school site, including comparisons to the rates of enrollment at other schools in the District and the overall District enrollment rate;
    3. a presentation by an expert during the 2013-2014 school year, which may be the consultant, in best practices for identification/selection and retention of African American students in such programs, courses and school;
    4. instruction on encouraging student participation in these courses, programs and schools;
    5. an overview of the identification/selection criteria for these programs;
    6. an overview of parent/guardian and student outreach efforts regarding these programs; and
    7. information or instruction regarding other actions the District may be taking in an effort to increase student participation in these programs, including race/ethnic-targeted recruitment and outreach efforts to directly encourage African American students to consider participation.

Action Step VIII – Reporting Requirement

  • By June 30, 2014, the District will provide to OCR documentation demonstrating that it has provided training to district personnel during 2013-2014 school year in accordance with Action Step VIII above, including: (a) the name(s) and title(s) of the individuals who conducted the training; (b) a list of the individuals who attended the training and their positions; (c) the date(s) the training was conducted; and(d)copies of any training materials disseminated.

IX. DATA MAINTENANCE

  1. Beginning with the 2013-2014 school year, and annually thereafter, the District will maintain the following data:

  1. the number of students, by race, enrolled in each District school in the just-completed school year;
  2. the number of students, by race, enrolled in each CCP course, program and school, in each of the District’s middle/high schools in the just-completed school year – the information will be provided for each program/course, so that an accurate percentage of overall students is possible – i.e., data should be reported in such a manner so that students who are taking more than one of the specified courses are not double-counted; and
  3. the number of students, by race and school, in the three specialty sixth-grade feeder schools (i.e., Zoo, Blandford, and the Center for Economicology), as well as enrollment in City Middle/High School and any elementary and middle school honors, foreign language, or algebra courses in the just-completed school year – the information will be provided for each course, so that an accurate percentage of overall students is possible – i.e., data should be reported in such a manner so that students who are taking more than one of the specified courses are not double-counted.

Action Step IX - Reporting Requirements

  • By June 30, 2014, June 30, 2015, and June 30, 2016, the District will provide to OCR the data referenced in Action Step VIII.A.1-3. If June 30 falls on a weekend, then the report is due the next business day.
GENERAL REQUIREMENTS

The District understands that OCR will not close the monitoring of this agreement until OCR determines that the District has fulfilled the terms of this agreement and is in compliance with Title VI and its implementing regulation at 34 C.F.R. § 100.3(a) and (b), which were at issue in this case. Prior to the conclusion of OCR’s monitoring, the District will provide documentation establishing that any disparities relating to underrepresentation of African American students in rigorous college preparatory courses in the District are not the result of discrimination prohibited by Title VI and its implementing regulations.

The District understands that by signing this agreement it agrees to provide data and other information in a timely manner in accordance with the reporting requirements of this agreement.  Further, the District understands that during the monitoring of this agreement, if necessary, OCR may visit the District, interview staff and students, and request such additional reports or data as are necessary for OCR to determine whether the District has fulfilled the terms of this agreement and is in compliance with Title VI and its implementing regulation at 34 C.F.R. § 100.3(a) and (b).

The District understands and acknowledges that OCR may initiate administrative enforcement or judicial proceedings to enforce the specific terms and obligations of this Agreement.  In the event that OCR decides to initiate administrative enforcement proceedings pursuant to 34 C.F.R. §§ 100.9, 100.10, or judicial proceedings to enforce this Agreement, OCR shall give the District written notice of the alleged breach and a minimum of sixty (60) calendar days to cure the alleged breach.

 

 

          /s/ 12/2/13

Grand Rapids Public School
Superintendent or designee

Date

 

 

1 Hereafter, the courses and programs listed in 1 and 2 will be referred to as “college and career preparatory courses” or “CCP” courses and programs.

 



   
Last Modified: 09/25/2018