Fresno County 2012-2013 Grand Jury Report # 4 MAR 1 5 2013 0 FRESNO COUNTY SUPERIOR COURT DEPUTY Investigation of the New Millennium Institute of Education INTRODUCTION On Septem ber 16, 2 0 1 2 the Fresno B ee published a story detailing problems with a charter school within Fresno Unified School District (F U S D ), the N ew Millennium Institute of Education. T h e article alleged that the school operated in violation of its charter and perhaps w as allowed to continue to operate due to the area it served and the presence of a F U S D board m em b er on its payroll. Subsequently two citizens cam e forth with formal complaints regarding the school. After a preliminary review of the issues and interviewing people with knowledge of the school's operations, it was concluded that a full-scale investigation by the grand jury w as warranted. BACKGROUND California Education Code Section 4 7 6 0 0 was enacted in 1992 to permit community m em bers to establish schools that operate independently from the school districts in which they are formed. T h e intent was to allow more creative ways of delivering curriculum, while still holding the schools accountable for meeting established school outcomes. T h es e "charter schools" could focus on targeting the needs of specific student populations. Each charter w as granted initially for a period of five years, with the possibility for subsequent five-year renewals based on satisfactory performance. W hile charter schools are established under the authority of a local school board, they operate independently of that board's policies. T he chartering school board has a limited oversight role that entails making an annual site visit, designating a contact person, reviewing the fiscal condition of the school, and ensuring the school files all reports required of it. C harter schools, as well as traditional schools, are funded by the State at a per-student rate that is based on a verag e daily attendance (ADA). T h ere are also several other state and federal funding sources which are based on such factors as poverty, lunch programs, non-English speaking students, etc. N ew Millennium Institute of Education (N M ) w as originally chartered in 1998 by Fresno Unified School District (F U S D ) under the auspices of Youth Opportunities Unlimited. This organization underwent nam e and focus changes and is currently called Fresno C are er D evelopm ent Institute, Inc. (FC D I). It continues to be the sponsoring agency of NM. T he school's target Page 1 of 6 3 /7 /2 0 1 3 FY 2 0 1 2 -2 0 1 3 Fresno County Grand Jury population h ^ s ^ lw ^ ys been the ^t-risk students from the W e s t side of Fresno, most of whom h^d either dropped out or been expelled from traditional schools. T h e article in the Fresno 8 e e ^ n d the complainants alleged t h ^ tN M w ^ s being grossly mism ^n^ged, the students w ere being poorly educated, ^nd there w^s no fin^nci^l accountability. re fe re n c e w ^ s m ^ d e to the charter renewal process in 2 0 0 8 when several stipulations w ere m ^de of NM, but most of those seem ed to h^ve been ignored. Further, the article ^ lle g e d ^ c h ^ n g e in the method of how the students w e re taught w ^ s m ^ d e ,f r o m ^ "seated" program to one b^sed almost exclusively on independent study, without ^pprov^l of FU SD . After conducting initial interviews ^ n d t^ k in g ^ to u r of N ew Millennium facilities the gr^nd jury decided to m ^ k e ^ n independent recommendation to Fresno U nifiedS chool D is tric t's to w hether the charter for the school should be renewed, ^s scheduled, ^t the end of the 2 0 1 2 -1 3 s ch o o lye ^r In M^y 2 0 0 8 the charter of N ew Millennium w^s renewed w ith ^ s e t of 14 stipulations th^t w ere to h^ve been addressed within one ye^r. T h e most egregious of these issues w ^s the potential need to re p ^ y ^ s much ^s ^2 million to the St^te Departm ent of Education (C D E ) due to failures within the independent study program to properly docum ent the work com pleted A s o f th e f^ ll of 2 0 1 2 th e r e w ^ s little documentation th^t showed the problems h^d been resolved. T h e fin^nci^l issue, however, w^s negotiated with the C D E whereby the school is repaying ^ 8 0 0 ,0 0 0 o v e r8 y e ^ rs . T h e gr^nd jury decided ^g^inst getting involved with the issue o f^ F U S D O o ^ r d m em ber being in the employ of NM. A F U S D ^o^rd m em ber cannot be ^n em ployee o f^ s c h o o l within F U S D , but charter schools ^ re co n s id ere d outside the district,hence such em ploym ent is ^ccept^ble. T h e role of the F U S D bo^rd concerning oversight of charter schools w^s questioned during this investigation Currently the bo^rd only reviews the schools w hen the charters com e up for renewal or they b e c o m e ^ re g u l^ r^ g e n d ^ ite m .F U S D h ^ s ^ o n e p e r s o n office in charge of oversight responsibilities for charter schools W ith currently ten schools to o v e rs e e ,^ n d w i t h in ^ v e r^ g e o ftw o coming up for renewal every y e ^ r,th is person's ability to monitor programs for com pliance is limited In the c ^ s e o f^ s c h o o l such ^s N ew M illen n iu m ,w h ere m^ny sanctions ^re imposed ^s conditions of renewal, the school m^y not receive the necessary scrutiny. It m^y be ^dvis^ble for the F U S D bo^rd to h ^ v e ^ p ro c e d u re in pl^ce to ensure the school rem edies the noted problems If stability is the cornerstone o f ^ s c h o o l ,N M i s ^ c l^ s s i c e ^ m p le of ^n organization in constant flu^. T h e leader of the b o ^ rd h ^ s not changed, but he is ^n individual with admittedly no background in education. Since the 2 0 0 8 charter renewal there h^ve been ^ t le ^ s t 8 p e o p le overseeing academ ics, with such titles as superintendent, principal, and vice principal. T h e board of directors has lost three of its seven mem bers, and the ten person teaching staff has no m em bers who w ere with the school in 2008. There clearly is a lack of stability and continuity. This is a school that claims to have the students foremost in mind, but the evidence points that the primary interest is retaining the charter and the funding associated with it. T h ere are numerous exam ples of actions taken to m eet a standard or impress those with oversight, only to revert back to business as usual once the appropriate notice has been taken of the action. T h es e actions range from seeking W A S C (W estern Association of Schools and Colleges) accreditation to purchasing unnecessary and unused computerized teaching aids. In an independent study program students are given a packet of assignments that may encom pass several subjects. T h ey are expected to work on that packet during the w eek, at the end of which they are required to m eet with a teacher for one hour to discuss the work. T h ere is no formal instruction of the material by the teacher. At the end of the session with the teacher forms are signed, which becom e the basis for the paym ent of A D A money by the C D E . Such a system is ripe for abuse and was the basis for the conditions under which the school was required to repay $ 8 0 0 ,0 0 0 in unearned funds from a 2 0 0 8 audit. T h e C D E code allows for schools to deliver curricula on an independent study basis. It recognizes there is a student population for which this is an appropriate m ode of instruction. T h ere is a w e b page devoted to the subject: "Is Independent Study Right for My Student?" It notes that in order to be successful, students electing independent study need to be motivated and highly committed, with sufficient academ ic preparation. T he students at N M do not fit this profile. T h es e students have either been expelled or have dropped out of traditional programs and are usually performing below grade level upon entry into NM. T h ey require more, rather than less, attention to their academ ic needs. T h e bottom line is this school, which is chartered to target its programs towards the academ ic success of a particular student population, has failed miserably to accomplish this goal. After fifteen years of operation the test scores of its students are among the lowest within the schools of F U S D , including other charter and continuation schools, with few er than five percent proficient in any of the core subject areas. Table 1, S T A R Test Results by School/District by Y e a r details these results. In addition to the raw data, there is no indication that any progress is being m ade to correct these deficiencies. In contrast, F U S D test results show that each year its students reach a higher level of proficiency in every subject area. This is w hat one should expect from a school chartered to serve a specific student profile. On page 21 of their 2 0 0 8 renewal petition, N ew Millennium m ade a com m itm ent "...A LL students will participate in the S T A R and C A H S E E testing opportunities to dem onstrate their progress toward meeting state standards" (emphasis theirs). They note that in the latest year available at that time, 2 0 0 6 -0 7 , a significantly higher percentage had participated in the testing process than ever before (this percentage w as 8 7.2 % ). It should be noted that the very next Page 3 of 6 3/7/2013 FY 2 0 1 2-201 3 Fresno County Grand Jury year the percentage dropped to 6 4 % It w o ^ ld a p p e a rth e commitment w as to charter renewal, not the evaluation of student progress T h e poor perform ance of N ew Millennium's students cannot be attributed t o a la c k o ffen d s. With annual revenues in excess of $ 2.2 m illion(over $ 9 ,0 0 0 per student) the school seem s to be doing very well fin an cially.F or the fiscal year ending 6 /3 0 /1 2 th e school h a d a s ^ rp l^ s of $ 1 6 6 ,0 0 0 ,which led t o a n e t asset balance of $ 4 6 4 ,0 0 0 This is after repaying $ 1 0 0 ,0 0 0 to C O E for the 2 0 0 9 settlement and $ 1 1 2 ,0 0 0 to FCOI for administrative services. O ver $ 4 0 0 ,0 0 0 w ent to "other e x p e n s e s ",a c a te g o ry that excludes any student services or support. It appears N ew Millennium had resources it co^ld have ^sed to provide additional help to its struggling students. T h e grand j^ry interview ed m o re t h a n a d o z e n people with knowledge of N ew Millennium's operations Only those who are currently associated with the school believed the school's charter should be renewed. Several derisive com ments w ere m ade concerning the school, including one that said the school was c o n s id e re d a jo k e by the community. T h e first-day enrollment numbers ( T a b le l) indicate support fo rth e school by the local community is declining The students being served by this school clearly need to be accom m odated, b^t equally c le a rly ,N e w Millennium is not the answer T h ere a r e a n ^ m b e r of alternative schools available to these students, both within F U S O and other charter schools. T h es e students d e s e r v e a b e tte r opportunity at getting their high school diplomas A ^e r almost ^ e e n years of operation, N e w Millennium has shown no indication that it is capable of p ro vid in g ac o m p e ten t education to its target student constituency. T h e common criteria for comparison of schools is the standardized tests administered annually to all schools and N ew Millennium has performed a t a r a t e far below that which should be expected o f a school chartered expressly to s e r v e a ta r g e te d s e t of students W e recom m end the charter not be renewed F401 N ew Millennium ^ tiliz e s a m o d e of instruction that is largely inappropriate fo rth e ir student population. F40 2 After fifteen years, no more than five percent of N ew Millennium's students are proficient in subject m atter considered essential fo r a h ig h school graduate This is far less t h a n a c o m p arab lech artersch o o l, S O U L (Table 1) F403 T h e Fresno Unified School District ^oard needs to be more involved in ensuring the conditions and stipulations specified in the M em orandum s of Understanding and Notices to C ^re are responded to in a tim e ly m anner a nd ap p ro priate actions are taken. Page 4 of 6 3/7/2013 FY 2 0 1 2 -2 0 1 3 Fresno County Grand Jury RECOMMENDATIONS T h e 2 0 1 2 -1 3 Fresno County Grand Jury recom m ends that the following be implemented: R401 The Fresno Unified School District Board not renew the charter for N ew Millennium Institute of Education when it com es up for renewal as of July 1, 2 013. (F401, F402) R 40 2 The Fresno Unified School District Board implement a process, such as using a subcommittee, w hereby charter M O U 's are reviewed on a timely basis. (F 4 0 3) REQUEST FOR RESPONDENTS Pursuant to Penal C ode ? 93 3.0 5, the Fresno County G rand Jury requests responses to each of the specific findings and recommendations. It is required that responses from elected officials are due within 6 0 days of the receipt of this report and 90 days for others. RESPONDENTS o President, Fresno Unified School District Board of Trustees with concurrence of other board m em bers (F401, F402, F403, R 401, R 402) SOURCES AND REFERENCES "Troubled C harter Keeps Getting C hances"; Alan W ilem an and Sam Cosby; Fresno Bee, Sept. 16, 2012, pg 1. California State D epartm ent of Education W e b Site: http://ww w.cde.ca.gov; numerous references including test results and statutes 2 01 0-11 and 2 0 1 1 -1 2 Audited Financial Statem ents for N ew Millennium Institute of Education W itnesses Interviewed included but w ere not limited to: Board m em bers and administrators of N ew Millennium Institute for Education Form er teachers and administrators at N ew Millennium Board m em bers, administrators, and staff of Fresno Unified School District Page 5 of 6 3/7/2013 FY 2 0 1 2 -2 0 1 3 Fresno County Grand Jury ATTACHENTS Table 1 STAR Test Results by School/District by Year New Millennium Institute o f Education English - Language Arts _______History_______ Total Year 2008 2009 2010 2011 2012 Total enroll number Pet Students Pet Proficient Students 1st Day tested Tested w/scores w/scores 570 365 359 64.0% 3.90% 202 264 259 254 98.1% 2.40% 166 309 255 243 147 82.5% 5.30% 235 176 74.9% 165 124 2.40% 184 176 167 95.7% 4.20% 93 Pet Proficient or adv 1.50% 4.80% 2.70% 1.60% 1.10% Mathematics Students w/scores 224 198 137 98 159 Pet Proficient Science CIS or adv Students w/scores 2.70% 3.00% 6.60% 0.00% 0.60% 136 59 65 56 48 Cambridge Continuation High School English - language Arts _______History_______ Mathematics Total Total Pet Pet enroll number Pet Students Pet Proficient Students Proficient Students Proficient Year 1st Day tested Tested w/scores or adv w/scores or adv w/scores or adv 241 2009 240 240 99.6% 3.80% 208 5.80% 146 1.40% 2010 230 225 97.8% 216 4.20% 195 11.30% 126 4.00% 234 2011 232 99.1% 228 3.50% 213 12.70% 198 1.50% 2012 245 245 100.0% 242 227 5.00% 16.30% 144 0.70% Pet Proficient o r adv 2.20% 11.90% 3.10% 0.00% 4.20% Science CTS Students w/scores 77 43 49 49 Pet Proficient or adv 2.60% 0.00% 10.20% 6.10% Science End-of-course Pet Students w/scores 134 134 75 67 84 Proficient or adv 0.70% 2.20% 4.00% 3.00% 4.80% Science End-of course Students w/scores 78 51 94 87 Pet Proficient or adv 12.80% 25.50% 21.30% 11.50% School o f Unlimited Learning (S.O.U.L.) Year 2009 2010 2011 2012 English - Language Arts _______ History_______ Mathematics Total Total Pet Pet enroll number Pet Students Pet Proficient Students Proficient Students Proficient 1st Day tested Tested w/scores or adv w/scores or adv w/scores or adv 185 155 83.8% 151 94 6.00% 77 8.50% 3.90% 155 154 99.4% 153 117 6.50% 71 6.80% 2.80% 146 132 90.4% 120 10.00% 93 64 4.30% 3.10% 147 146 99.3% 138 87 9.40% 81 6.90% 4.90% Science CTS Students w/scores 43 46 44 43 Pet Proficient o ra d v 4.70% 8.70% 4.50% 7.00% Science End-of-course Students w/scores 46 64 57 63 Pet Proficient or adv 13.00% 9.40% 10.50% 6.30% Fresno Unified School District * Total enroll Total number Pet Year 1st Day tested 2009 2010 2 0 1 l| 2012 56,212 55,291 54,550 54,201 55,572 54,868 53,964 53,654 Tested 98.9% 99.2% 98.9% 99.0% English - Language Arts _______ History_______ Mathematics Pet Pet Students Pet Proficient Students Proficient Students Proficient w/scores or adv w/scores w/scores or adv or adv 52,456 35.90% 15,230 28.50% 51,690 37.10% 51,442 37.80% 14,836 32.10% 50,646 39.50% 50,284 39.20% 14,336 34.70% 48,783 40.10% 49,899 42.10% 14,281 35.70% 49,668 42.30% Science CTS Students w/scores 15,187 14,932 14,354 14,215 Pet Proficient or adv 35.00% 37.70% 39.80% 42.30% Science End-of-course Students w/scores 13,724 13,171 12,679 12,868 Pet Proficient or adv 20.50% 24.40% 26.20% 25.90% * It is noteworthy that in every subject area, each year the percentage o f students who are proficient has increased. Page 6 of 6 3/ 7/2013 FY 2 0 1 2 -2 0 1 3 Fresno County Grand Jury Over the past few months New Millennium Institute of Education has been the subject of at least four articles, editorials or op-ed pieces contained in the Fresno Bee that raise the question of our fitness to operate our charter school. These articles became the impetus for a Fresno County Grand Jury inquiry. An editorial on the Grand Jury's findings appeared in the Bee on Sunday, March 24, 2013. With our renewal approaching and our credibility once again publicly questioned, we want to clarify the findings in the Grand Jury report with the facts about our progress. We believe that FUSD Trustee Board should approve our charter renewal petition because we have complied with every requirement that FUSD and CDE established for the operation of a charter school. We have for several months been under strict review by FUSD charter review committee and expect to get their recommendation for renewal. We have in the last two years developed and this year implemented an educational/career program that provides service to a segment of students that may otherwise pursue a path of crime, gangs and/or welfare. We accept and attempt to work with students, many of whom have dropped out or been kicked out of schools in Fresno Unified, Washington Unified, Central School Districts, and other charter schools. We try to focus our students on understanding the world of work and prepare them for entry level jobs as the beginning of their careers, and impress upon them the importance of a high school diploma as the first step toward a successful career and model citizenship. The derogatory commentary about New Millennium for the last two years of operation is made by former employees and consultants, none of whom have direct knowledge of what we are doing now. There is some validity in their criticisms which largely accounts for them being former employees and consultants. They are the basis for a Fresno State Student's article published in the Bee. We provided documents to correct many of their comments but they were not reflected in the article. Our responses and comments to the Grand Jury findings are contained in the following paragraphs: Grand Jury Committee: "......The most egregious of these issues was the potential need to repay as much as $2 million to the State Department of Education (CDE) due to failures within the independent study program to properly document the work completed. As of the fall of 2012 there was little documentation that showed the problems had been resolved. The financial issue, however, was negotiated with the CDE whereby the school is repaying $800,000 over 8 years." NMIE Response: It was an independent audit finding that confirmed FUSD's oversight revelation that some of the student files lacked the signature of a NMIE employed supervising teacher. As the independent study program was then being operated by an educational consulting service, the Ed Code required student records to be signed by an employee of NMIE as the supervising teacher. The absence of signatures on some student files resulted in an $870,000.00 disallowance. Our students did received academic credit for their work. The school acknowledged the error and requested that CDE approve a repayment plan. The plan was approved. There was no negotiation, there was never a 2 million dollar repayment issue presented to NMIE. The Board decided the mode of independent study delivery had to be restructured. With the help of a retired FUSD Independent Study teacher, NMIE redesigned its independent study program to reflect that of Fresno Unified's independent study school, J.E. Young Academic Center. Consequently, in each year since our transition, we have received no audit findings or disallowances. Grand Jury Committee: "......In the case of a school such as New Millennium, where many sanctions are imposed as conditions of renewal, the school may not receive the necessary scrutiny. It may be advisable for the FUSD board to have a procedure in place to ensure the school remedies the noted problems." NMIE Response: We have worked very hard to maintain an effective working relationship with the districts charter office has been an effective monitor of our operations. They have been an invaluable resource to us as a result of multiple on-site visits that have focused on every facet of our operations. We can say that we have benefitted greatly from their expertise and honest counsel. Grand Jury Committee: "......Since the 2008 charter renewal there have been at least 6 people overseeing academics, with such titles as superintendent, principal, and vice principal. The board of directors has lost three of its seven members, and the ten person teaching staff has no members who were with the school in 2008." NMIE Response: In 2008 our board made a conscious decision to delay the hiring of a permanent instructional leader until the issues of a Notice to Cure were resolved. We instead hired interim leaders including a consulting team to transition the school. Effective charter school operations require a breadth of knowledge in many different areas. We have had mixed results using retired FUSD administrators who have in effect had our charter school operating as a standard district school. We realize that what we needed most, was someone with explicit charter school experience that could lead the school back to its original mission. We feel that we have finally found a leader in our present administrator that fits that profile. Three of our board vacancies have come as a result of the deaths of former FUSD School Board Trustee William "Bill" Riddlesprigger, Carole Ponchetti and Hon. Judge Lawrence Jones. In an effort to meet the ever-changing needs of our student population, we have retained more than half of the 2008 teaching staff, most of who are retired from FUSD's J.E. Young Academic Center. Grand Jury Committee: "......There are numerous examples of actions taken to meet a standard or impress those with oversight, only to revert back to business as usual once the appropriate notice has been taken of the action. These actions range from seeking WASC (Western Association of Schools and Colleges) accreditation to purchasing unnecessary and unused computerized teaching aids." NMIE Response: All of our decisions are intended to improve the quality of instruction for our students. All purchases including Instructional Technology aids and software are designed to enhance student achievement. We do fully utilize every tool at our disposal in order to make the curriculum accessible to our students. We sought WASC accreditation because it was the prudent thing to do. Many charter schools use WASC's Self Study process as a tool to assist in providing introspection into the school's operations. Through the accreditation process we were able to identify our strengths and weaknesses. We used that information to make needed changes. Accreditation validates the integrity of a school's programs in order to support student learning and manage organizational change. That's why schools seek their approval. As a result of the hard work put in by our staff and teachers, we were awarded our WASC accreditation in 2011. Grand Jury Committee: "......There is a web page devoted to the subject: "Is Independent Study Right for My Student?" It notes that in order to be successful, students electing independent study need to be motivated and highly committed, with sufficient academic preparation. The students at NM do not fit this profile. They require more, rather than less attention to their academic needs." NMIE Response: The same document which the Grand Jury cites in the above paragraph also states; "Because students in independent study work closely with their teachers, in one-on-one meetings or small group instruction, independent study can be a highly personalized form of instruction. Independent study also offers a high degree of flexibility and individualization, so it can serve a wide range of students including: o Students who, for a variety of reasons, have fallen behind in their studies and need an individualized approach to fill in gaps in their learning or make up credits. o Students who are at risk of dropping out of school. Some districts use independent study as a dropout prevention or recovery mechanism-they have found that for a subset of discouraged students who have very little connection with high school, independent study can sometimes facilitate a turnaround in student engagement. This can happen when students develop close relationships with teachers in one-on-one and small group settings, and when they are able to take charge of their own learning through an individualized approach." For years, there has been an ongoing debate on whether or not independent study is an appropriate mode of instruction for students of any background. The value of this debate has not been lost on the leadership at NMIE. We decided to dedicate our resources and our focus to the Personalized Learning model because we viewed its inherent flexibility as a benefit for the majority of our student population, some of whom have children and other responsibilities that restrict their availability for daily instruction. However, considering our at-risk student population and realizing we needed to provide additional interventions within our program to support them and meet them, we developed our Academic Resource Labs (ARC). These three labs are staffed with at least one certificated tutor to provide one-to-one attention and focus on pre-assessed areas of weakness. We never make the assumption that one approach will fit all students. Additionally, the one-on-one setting allows teachers and personnel to focus on the whole child. We have the opportunity to get to know the students in a more personal manner and identify further needs that are addressed within the school setting. We employ Drug and Alcohol intervention, anger management, gang intervention and socio-emotional counselors that are available to all students. Grand Jury Committee: "......After 15 years of operation the test scores of its students are among the lowest within the schools of FUSD, including charter and continuation schools, with fewer than five percent proficient in any of the core subject areas. Table 1, STAR Test Results by School/District by Year details these results. In addition to the raw data, there is no indication that any progress is being made to correct these deficiencies." NMIE Response: The students that come to us, as with most charter schools, are already achieving at the lower ends of the performance bands. Whenever we are measuring the progress of students in schools, we have to take into account where the students are beginning. It is unrealistic to set an arbitrary goal for all students in all schools for any given year without first taking into consideration where they are starting. What we also have to do is make sure that we are holding these students to the same high standards in the long run. It takes a while for progress to be made for students who have to catch up. We can say that the biggest difference in what we are doing now as opposed to the past is that we are getting better at focusing on meeting our students at their present levels of performance and providing them the support they need to achieve more. We have become more proficient in our assessment, analysis and corrective action as it relates to student achievement results. In reference to the data included in Table 1 of the GJ report, STAR Test Results by School/District by Year, we would like to note the following: o All three schools including NMIE experienced a growth in AYP over the last two years o NMIE students experienced a growth in Percent Proficient in 4 of 5 categories (that is in contrast to 2 of 5 categories for Cambridge and 3 of 5 categories for S.O.U.L.) o Although the percentage has fluctuated, NMIE has been able to maintain its Percent Tested well above the low levels of 2008. Although our achievement levels are nowhere near our intended results for the future, New Millennium has met its API Growth targets for the last 4 years. According to the 2012 Growth API LEA List of Schools Report (CA Department of Education), New Millennium students experienced the third highest API Growth of high schools in the district (25 points), following only S.O.U.L. with 31 points and Hoover with 26 points. Grand Jury Committee: "Over $400,000 went to "other expenses", a category that excludes any student services or support. It appears New Millennium had resources it could have used to provide additional help to its struggling students." NMIE Response: The "other expenses" that the report refers to includes Business Operating Services which include Utilities, Rent, Educational Consultants, Advertising, Liability Insurance and Postage. Each year 90%+ of the budget is allocated to direct student services. Less than 10% is allocated to management expenses in which mandatory oversight fees are included. We have had meetings with community members concerned with the quality of education we provide. We invited them and continue the invitation to anyone interested in what we do, to visit our school to get a first hand understanding.