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April 15, 2014 Dr. Pamela C. Brown Superintendent Buffalo Public Schools 712 City Hall Buffalo, NY 14202 Dear Superintendent Brown: On December 20, 2013, Distinguished Educator Judy Elliott and Assistant Commissioner Ira Schwartz met with you, your staff, and representatives of the Buffalo Board of Education regarding the options available for Bennett High School and Martin Luther King, Jr. Multicultural Institute (MLK). On March 12, 2014, Buffalo Public Schools (BPS) submitted a plan to phase-out MLK (grades kindergarten through eight) and replace it with the Martin Luther King Medical Campus School (grades five through twelve). On April 7, 2014, the United States Department of Labor announced that it had awarded BPS a $3.5 million Youth CareerConnect grant to create the Buffalo Medical Campus High School. In presentations to the media and to the Buffalo Board of Education, BPS staff stated that the grant would be used to phase in the opening of Buffalo Medical Campus High School as a replacement to phasing out MLK. I congratulate you on the grant award and request that you provide the State Education Department (SED or the Department) with further information regarding how the Youth CareerConnect grant is related to the phase-out of MLK. If BPS wishes SED to consider this grant in making a determination whether to approve the phase-out/phase-in plan for MLK, BPS must submit the following documents for review and approval: Revised school registration documentation. Specifically, the petition to request to register a new public school, Form A and Form D. A copy of the full approved Youth CareerConnect grant application, as submitted to the United States Department of Labor, including all attachments, such as those that provide a workplan/timeline, etc. Responses to Questions Regarding the Development of the CTE Pathways at Buffalo Medical Campus High School. (Attachment A)

Additionally, it should be noted that in the initial review of the phase-out/phase-in plans submitted for MLK, SED staff found the plans lacked the following critical information:

1. The plan lacks evidence that the district has intentionally planned how all of the extensive preparatory work for the new school model including curriculum, staffing, and professional development, will be accomplished by September 2014. No timeline for accomplishing this work was provided with the plans. 2. The plan does not provide information on how the district will directly support the implementation of the new school model. The district support plan included in the March 12 submission deals exclusively with the support of the phase-out school. The district addressed neither how it will support the new school nor how the district will work with the school leadership teams prior to September 2014 to make all of the important decisions related to curriculum, staffing, and professional development that are necessary for the success of the new school model. 3. The district has not provided a timeline or a comprehensive description of how school leadership will be recruited, hired, and supported. BPS plans to conduct a national search for the principal of the new MLK Medical Campus; however, there does not appear to be a plan to ensure that the individual is hired as soon as possible, so that he or she can be involved in critical decisions regarding staffing, curriculum, etc. 4. The district has not provided a plan for supporting the needs of students at the phase-out school. It is not adequate to continue with the plan of district support already in place, as that support has not had the desired impact on student achievement. 5. There are several issues related to public school choice. The transfer process, as described in the submitted plans, is unclear and could cause confusion to parents. BPS states that students from the phase-out school can transfer to any other school within the district. However, the transfer application included in the March 12 submission states that parents can only transfer their children for the following reasons: safety/welfare; medical necessity; sibling preference; or hardship. Closure of a school is not listed. Therefore parents may receive this application and conclude that they are not eligible to transfer. Additionally, BPS states that classrooms will be added to other schools in order to accommodate transfer students, if necessary. This statement is contrary to BPSs current public school choice policy, where students are denied access to schools that do not have seats available. Finally, it appears from the information provided by the district that students with disabilities and English language learners at MLK do not have a choice in where they will attend school. BPS states that they will be moving the selfcontained classrooms at MLK to other schools and that six ELL students will also be moved to other schools. This action raises concerns regarding choice and equity for all students. 6. The plans do not provide adequate evidence of consultation with administrative and teacher collective bargaining units. This consultation is required by Commissioners regulations and necessary to ensure that the hiring and transitioning of teaching and

administrative staffs resulting from the phasing out and reconstituting of these two schools is accomplished consistent with collective bargaining agreements. 7. BPS did not provide adequate evidence of shared planning and decision-making with families in the development of the plans submitted, as required under Commissioners Regulation 100.18. Notification was provided to parents regarding the future of the schools, and information meetings were held, but BPS did not document how stakeholders were given an opportunity to participate in plan development. Although the submitted plans reference parent information meetings to be held next year, there was no information on plans to involve parents in the development of the new schools during the 2013-14 school year. These issues must be addressed in the revised registration documents submitted by BPS. Failure to do so will result in denial of the phase-out/phase-in plans for MLK and the petition for registration of a new school for Buffalo Medical Campus High School. Next Steps The requested grant application, revised registration documents (inclusive of the information listed above), and responses to Questions Regarding the Development of the CTE Pathways at Buffalo Medical Campus High School, must be submitted to SED by April 25, 2014. Additionally, we will be contacting your staff to arrange a meeting during the week of April 14, 2014, to discuss further the relationship between the actions required for MLK and the United States Department of Labor Youth CareerConnect grant. I look forward to working with you to ensure that students at MLK receive the education they deserve - one that prepares them for college and careers. Sincerely,

Ken Slentz Deputy Commissioner c: Members of the Buffalo Board of Education John King Judy Elliott Ira Schwartz

Attachment A: Questions Regarding the Development of the CTE Pathways at Buffalo Medical Campus High School Prior to submitting an application to the Department, the self-study and external review committees will have reviewed the program in its entirety to ensure that the: curriculum design provides rigorous content which is non-duplicative and provides the student with a coherent sequential program of study; curriculum has been aligned to both state and national learning standards; secondary curriculum is aligned with postsecondary education; faculty is state certified with the appropriate academic and/or technical certification; technical assessment meets current industry standards; articulation agreements are constructed to provide students with direct benefit; program provides work-based learning opportunities for all students; and data reporting infrastructure has been developed to report student performance in order to evaluate success on Regents examinations, approved alternatives, technical assessments, and placement in higher education, employment or the military.

Questions to the District pertaining to the program approval process When will the District conduct the CTE self-study? When will the District assemble a committee of stakeholders and conduct the external review? Will the recommendations of the external review committee be taken in to account with modifications made to the program? Have formal articulation agreements for these new programs been executed between the school district and the college? Has all appropriately certified CTE faculty been identified prior to application submission to SED? Will all facility modifications be completed in time for September program start? Has the Chief Administrators and Board of Education Presidents sign off been obtained on the applications?

Questions pertaining to the pathways Medical Assisting Programs follow the health science format (2 units in health occ. core, one unit of concentration and one unit of teacher-supervised clinical experience) and there are a few industry recognized national certifications, however while these certifications are desirable and even required by employers, it is not mandated for employment in NYS. Because NOCTI exams meet the definition of assessment for technical skills, schools often use the NOCTI Medical Assistant exam in lieu of the national certifications that would have meaning in the health care industry and create employment opportunities for students. Please explain why this certification is the most appropriate for this program. Medical Laboratory Technician It is not clear from the proposal that this is a separate pathway for students. Medical Assisting and Laboratory Technician programs have unique tasks associated with each. Approved programs in this area (Nassau BOCES, Western Suffolk BOCES) are run as separate programs. Are these two programs linked or are they separate? And is the technical assessment appropriate for both? Health Information Technology Health Information Technology is a relatively new pathway. It is essentially the comprehensive management of health information across computerized systems and its secure exchange between consumers, providers, government and quality entities, and insurers. The question is similar to the Medical Assisting question, in lieu of the national certifications that would have meaning in the health care industry and create employment opportunities for students, why is the NOCTI certification exam the most appropriate for the program? Environmental Facility Management While this could be a promising emerging occupational pathway, it could also be a lower level building maintenance program with an impressive name. This pathway proposes to lead to an AOS degree, which many consider a terminal degree without opportunities for continuing their education. Please explain how this program will present and maintain a high degree of rigor (so as to ensure that this does not become a lower track for students). Please explain why this certification is the most appropriate for this program.