A few weeks ago, the office of the state superintendent of education (OSSE) sent out notice of proposed amendments to rules for residency verification. The comment period ends October 24; comments can be sent in via email (information at the link above) or snail mail (ditto).

The purpose of the rule making, according to a memo from OSSE head Hanseul Kang, is “to provide local education agencies (LEAs), parents and stakeholders with additional context to understand OSSE’s current practices for residency verification and investigation, and the new regulations and practices OSSE proposes to put into place to further prevent residency fraud while reducing burden and lift barriers for LEAs and families.”

Right now, anyone who has a child and does not live in DC must pay tuition to send his or her child to a DC public school. The principle is that it’s not sustainable or fair to have seats in public schools go to children who live outside the district.

At one point, however, the explanatory memo gets downright funny:

“OSSE’s residency fraud prevention program has a rigorous process for investigating tips of non-residency. Once a tip is received, OSSE requests residency verification and enrollment forms from the charter LEA for internal review.” [boldface mine]

(Maybe someone should tell OSSE that residency fraud happens in DCPS?)

Anyhoo, yesterday, about the time that a “stakeholder engagement session” was held in the middle of the day at OSSE’s offices (for 1 hour), I and another DCPS parent, Caryn Ernst, sent in our thoughts.

I have put Caryn’s comment below, as it gets to what seem to be the critical issues involved (even if OSSE may have a notion that this is all about charter schools):

“I’m writing to comment on the proposed residency verification rules.  While I was glad to see that District tax records will be allowed as a proof of residency, which in theory would enable OSSE to link families records with the city’s tax database, I was distressed to see that there won’t be a proactive verification of residency by OSSE. As I read these rules, verification will still be the job of individual LEAs, and I’m assuming individual schools within DCPS.

“The recent data on student mobility, which shows the vast majority of mid-year moves being in and out of state, confirms what many of us in communities near the DC/Maryland border have long known: there’s a significant percent of students enrolled in public schools in DC from neighboring states. Leaving it up to individual schools and LEAs to “self-police” is absurd given the huge burden residency fraud places on the public school system and tax-paying residents in DC, and the tremendous incentives for schools to “look the other way.”

“Obviously if school budgets are based on enrollment, there’s a significant incentive for schools and LEAs to allow residency fraud if it will help them reach enrollment targets and increase their budgets. I will also say from experience that when school communities try to police themselves if can lead to significant tensions and conflict and undermine school climate. In addition, allowing parents/guardians to submit the same materials they have used in previous years, instead of verifiable tax records, means that these new rules won’t be any more effective than the old rules.

“I can’t see any rationale for why OSSE wouldn’t use the data readily available to it to verify residency and ensure families AND schools aren’t defrauding the public school system. A centralized system of residency verification would enable families to submit documentation either at the school or online and would enable OSSE to prevent residency fraud in a consistent and reliable way.”

Happy commenting–and while you’re at it, send a note to your state board of education members, who are eager to hear public comments on this rule making.