UCFSD Residency Report - Chester County Intermediate Unit

Independent Review of
UNIONVILLE-CHADDS FORD SCHOOL DISTRICT
RESIDENCY PRACTICES
Respectfully submitted by
Dr. Joseph J. O’Brien
Executive Director
CONTENTS
OBJECTIVES.......................................................................1
EXECUTIVE SUMMARY.....................................................4
COMPARATIVE RESIDENCY COSTS...............................19
NEW UCFSD POLICY.......................................................23
CORRESPONDENCE........................................................32
SPECIFIC RESIDENCY CASE...........................................51
UCFSD RESIDENCY COSTS.............................................63
INTERVIEW QUESTIONS.................................................66
DOCUMENTS REFERENCED...........................................71
INDEPENDENT REVIEW
OBJECTIVES
1
2
3
INDEPENDENT REVIEW
EXECUTIVE SUMMARY
4
An Independent Review of
Unionville-Chadds Ford School District
Residency Practices
Commissioned: March, 2014
Completion Date: July 14, 2014
Respectfully Led by
Joseph J. O'Brien,
Executive Director
Chester County Intermediate Unit
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I. Purpose of the Review
The following report was commissioned at the request of Dr. John Sanville,
Superintendent of Schools for the Unionville-Chadds Ford School District
(UCFSD). The goal of the report is four-fold:
1. Provide an analysis of current UCFSD practices related to student
residency. As appropriate. We compared UCFSD practices with other
school districts. Our analysis is to include commendations and
recommendations as appropriate.
2. To review the XXXXXXX residency case. Provide an evaluation of the
district’s handling of this case, including commendations and
recommendations as appropriate.
3. We were specifically asked if the current UCFSD’s practices relative to
residency investigations are cost effective. We were further asked to see
how UCFSD’s costs compared to other school districts.
4. Review policies and guidelines that govern student residency. Do
UCFSD’s policies and practices conform to industry standards?
Thus, this is a limited review that is to address the four specific items as
detailed by the Unionville-Chadds Ford School District (UCFSD) Board.
The final report will include analysis, commendations, and recommendations
as appropriate. The focus of the Chester County Intermediate Unit review will
be to strengthen the policies and procedures of the UCFSD to improve the
student residency process.
II.
Background
UCFSD is an outstanding public school district located in a wonderful area
of Chester County. Everything about the area and the school district is
extremely attractive to local residents, and to many people looking for a
quality place to live and go to school. Unionville-Chadds Ford is considered
to be exactly that: a great place to live, to work, and to attend school. The
specific reputation of the UCFSD is truly world class – and this is the school
district of choice for many people. Unfortunately, such a quality school
district can become very attractive to non-residents who live in nearby
areas, and the school district must assume the burden of insuring that
taxpayers of Unionville-Chadds Ford do not pay for the educational program
of non-residents who seek to have the value of a UCFSD education without
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actually living within the school district, and/or paying the same taxation
rate as legal residents.
As Superintendent Sanville assumed the leadership of UCFSD on September
1, 2011, he inherited a student residency issue that dated back to 2004.
Specifically a case involving the XXXXXXX family.
Starting in February, 2014, Superintendent Sanville asked Dr. Joe O'Brien,
the Executive Director of Chester County Intermediate Unit (CCIU), if he
would undertake a review of this case and the UCFSD residency policies
and practices. This agreement was formalized on March 24, 2014, when Dr.
O'Brien signed the Confidentiality Agreement. During this time, the UCFSD
announced that they had asked the CCIU to conduct an Independent
Review of Unionville-Chadds Ford’s Residency Practices.
This report represents that review. It consists of several sections, as detailed
in the Table of Contents at the beginning to this report. This section
represents an Executive Summary of the entire report – and is included at
the front of the full residency review report.
III: The Process Followed:
The review process began in earnest at the end of February/beginning of
March – and has lasted approximately four months. Several CCIU staff
members assisted Dr. O’Brien– all of whom are listed at the end of this
review. The following steps have been taken:
1. Dr. O'Brien informed Dr. Sanville that he would be using the
services of the CCIU’s HR department and communication
department. Specific people mentioned were Iain Strachan, HR
Director for Chester County Intermediate Unit; Mary Curley,
Communications Director for Chester County Intermediate
Unit; Jessica Corry and Stacy Ososkie, two communications
specialists for Chester County Intermediate Unit and general
secretarial assistance from an Administrative Assistant, Ms.
Janice Heagy. All of these CCIU staff have been involved.
2. Dr. O’Brien discussed with Dr. Sanville if the school district
wished to have an independent legal review. Dr. Sanville said
that he had already discussed this possibility with school
solicitor Jack Merrick and if the Board so desired the district
would engage MacElree Harvey, Ltd. for such a review.
3. Ms. Ososkie and Ms. Corry have contacted all school districts in
Chester County, plus selected school districts from Delaware
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County, Montgomery County, and Camden County, New Jersey.
A summary of this work will be included in the final report, as
well as the documentation compiled by Ms. Corry and Ms.
Ososkie and analyzed by Dr. O’Brien and Mr. Strachan.
4. Dr.Manzone provided the CCIU with a folder/binder filled with
information about the XXXXXXX student residency case in
question. She did this when she met with Dr. O’Brien on March
26, 2014. (3/26)
5. Dr. Sanville provided the CCIU with a comprehensive binder full
of information germane to this review. This binder contained
information about the XXXXXXX specific case – and further
information about the residency policies and procedures of
UCFSD. He sent this around the end of February, 2014.
6. During the months of March, April, May and June, Dr. O’Brien
reviewed all of the information provided by Dr. Sanville and Dr.
Manzone.
7. Dr. O’Brien met with Dr. Manzone on March 26, 2014 and with
Dr. Sanville on April 14, 2014. Both of these discussions
centered primarily on the XXXXXXX student residency case.
8. Prior to meeting with Dr. Sanville, Dr. O’Brien also met with Mr.
Victor Dupuis, Unionville-Chadds Ford Board President and Dr.
Sanville on April 14, 2014. This discussion centered on the
XXXXXXX student residency case – and a social interaction
between Mr. Joe Lubitsky (Chester County Intermediate Unit
Business Manager) and Mr. Jack Merrick (UCFSD solicitor).
9. Dr. O’Brien also met with Mr. Jeff Hellrung, the UnionvilleChadds Ford Intermediate Unit Board representative on April
23, 2014 after our CCIU Board meeting. This discussion
centered on the XXXXXXX student residency case.
10. Dr. O’Brien also received e-mails from Jeff Hellrung and Keith
Knauss centering on the XXXXXXX student residency case.
11. Dr. Sanville requested that someone from the Intermediate Unit
should contact each Unionville-Chadds Ford Board member
and Mr. Jack Merrick to make sure we gave each Board
member a chance to be heard on the XXXXXXX Residency case.
Dr. O’Brien agreed to do this and did so. All of these interviews
were conducted by telephone.
12. Dr. O’Brien shared all the information with the CCIU’s Mr. Iain
Strachan. Both Mr. Strachan and Dr. O’Brien independently
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reviewed all the documentation given to us by Dr. Manzone and
Dr. Sanville. All of the information gathered was shared with
Iain Strachan for his independent review.
13. Dr. O’Brien and Ms. Ososkie reviewed independently gathered
attendance and residency information. Dr. O’Brien compared
Unionville-Chadds Ford policies and procedures with the other
school district information. The policies and procedures
collected for the twelve school districts of Chester County are
attached in Appendix A.
14. UCFSD provided previous and current copies of the school
district’s residency policies and procedures. These are included
in Appendix A and Appendix C, respectively.
15. When the UCFSD Board adopted new policies and procedures
during the spring of 2014, a copy was sent to the reviewer.
These new policies are included in Appendix C.
16. UCFSD provided cost data for residency cases over the past few
years.
17. Dr. O’Brien and Ms. Corry contacted all the school districts
included in the review (all of Chester County – plus a few extra
school districts) to gather cost data from their respective school
districts. Dr. O’Brien sent each Superintendent involved a
personal e-mail seeking their assistance, with Dr. Sanville being
copied on these e-mails to other Superintendents.
18. The UCFSD administration and Dr. Manzone provided a
significant amount of tangential information.
19. Some tangential information was provided by Haddonfield
School District; Springfield School District; Upper Darby School
District; Wallingford-Swarthmore School District and Lower
Merion School District.
20. Dr. O’Brien conducted phone interviews with all UCFSD Board
Members.
21. Dr. O’Brien conducted a phone interview with Mr. Jack Merrick
(UCFSD Solicitor).
22. Dr. O’Brien took notes during the phone interviews, and these
notes are included in the Documents Referenced section –
under Interview Questions.
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23. A Preliminary draft of this Residency report was developed,
written, and reviewed by Iain Strachan and Joe O'Brien.
24. A follow-up meeting was set with Dr. Manzone to seek any
clarification needed. A similar interview (almost exactly the
same as the interviews conducted with the UCFSD Board
members) was conducted with Dr. Manzone. This interview was
conducted face-to-face between Dr. Manzone and Dr. O’Brien in
a meeting on June 19, 2014. (6/19/14). Dr. Manzone wanted to
reflect, and she sent her answers via e-mail as an attachment.
Dr. Manzone’s answers are included in the Documents
Referenced section – under Interview Questions.
25. A follow-up meeting was held June 30, 2014 with Dr. John
Sanville and Dr. O'Brien. The purpose of this meeting was to
seek any clarification needed, and for an initial review of the
drafted report.
26. All information gathered has been considered in light of the
four-fold purpose of this review listed on page two (2) of this
report.
27. The UCFSD Board was given an opportunity to further direct
any additional work it wished to have done – and they did ask
for a more detailed cost analysis. This additional work has been
completed as best we could in a tight time frame to meet our
target date of July 14, 2014.
28. This residency review report has been treated confidentially and
will only be shared with the UCFSD Board and Superintendent
Sanville.
29. Our CCIU recommendation would be to release the report to the
UCFSD public, but that must be a UCFSD Board decision.
30. If released, the CCIU would be willing to do the Press Release –
and answer any questions arising from the public and/or the
press.
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IV:
Key Findings:
The key findings will be presented under the general items listed below, as well
as the initial four charges given to the reviewer. These findings represent the
reviewer’s professional opinion, after doing a fairly (albeit limited in scope)
comprehensive review. The charge was specific to a large degree – and that
specificity allows for the following key findings in this review:
1. Every single person (whether an administrator or a present or
former Board member) acted in good faith – and with the best of
intentions. Every person was trying to act in what they (he/she)
perceived to be the best interest of the UCFSD and community.
2. The Unionville-Chadds Ford Board Policies are now in good order.
Dr. Sanville has introduced a new policy and new procedures that
improve the existing policies for UCFSD.
3. The Unionville-Chadds Ford administrative procedures need to be
standardized and consistently enforced from this point forward.
This did not happen in the past (before Dr. Manzone and Dr.
Sanville).
4. At this point in time, the issue of student residency is NOT
considered to be a major issue confronting the UCFSD – by the
Board, the administrative team, and the majority of the community.
However, for some people from the UCFSD community, this is a
major issue and they will seek vigilance.
5. For the record, it is the reviewer’s opinion that the issue of student
residency may become a growing issue for the UCFSD community –
as the reputation and performance of the school district grows ever
more positive (establishing Unionville-Chadds Ford as one of the
premier school districts in the region). This is especially true – in
light of the surrounding school districts with lower taxation rates,
and not nearly as attractive a school district. Thus, the school
district should be vigilant on this topic – now, before it becomes a
major topic. Our opinion is based upon the study of other school
districts in similar circumstances – (for example, Springfield School
District; Lower Merion School District; Upper Darby School District;
Haddonfield School District (New Jersey); and WallingfordSwarthmore School District)
6. The UCFSD Board should establish the philosophical foundation for
their policies, practices, and procedures – and the administrative
procedures should follow the UCFSD Board’s philosophical direction.
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i. This involves choosing between being helpful and
transparent to any person wishing to understand how to
prove residency and enroll their children. This approach
would show people the way to prove residency, and help
them to do so.
– or –
ii. Choosing to be very tough on student residency
requirements and insisting that the burden of proof of
residency lies with the family – and not the UCFSD. This
approach would require the family to complete a form
asking the family residency-related questions – then
basing the school district’s enrollment decision on the
information provided on the form. The decision would be
either a “yes” or “no” decision based on the answers
given by the family – with no coaching and/or other
information from school district staff members.
7. Whichever approach is taken (and other school districts use both
approaches routinely) should be a Board decision – and one that
would be periodically reviewed when policy reviews occur. Over
time, many school districts have “tightened up” their residency
procedures – and changed their policies and procedures accordingly.
8. Of particular note is the newly developed practice by the Board and
Superintendent Sanville to regularly review the status of all
residency cases (including any “suspected” residency issues). This
ensures UCFSD Board oversight – and demonstrates a serious
administrative commitment to managing Residency Issues as they
arise.
9. The costs associated with residency issues in UCFSD are not out of
line – and this reviewer believes the UCFSD Board and
administrative leaders have developed a reasonably cost-effective
system to deal with residency issues moving forward.
The following key findings (Numbers 10 through 15) relate to the specific
XXXXXX residency case, which we were asked to review. Here are our key
findings in this case:
10. A key theme centered on whether a deal had been made with the
family in question, and there was no deal made by Dr. Sanville
and/or the UCFSD Board with the family in question. Dr. Sanville
inherited this residency case from the previous administrative
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teams – and he was the first Superintendent to move on the family
in question. He was motivated to do so by the good intentions of Dr.
Manzone to bring this issue to the attention of the Board and
administration.
11. Dr. Sanville made no deal; however, it appears the family in
question was admitted under a different standard of residency.
•
•
•
In 2004 the superintendent set a different residency standard
for family XXXXX. Specifically, if they had a drivers license,
voter registration and a utility bill with a UCFSD address, they
could register students in UCFSD.
The family met that standard.
In 2012 Dr. Sanville set a new more rigorous residency
standard. Specifically, the district would follow the standard
set in the Cumberland Valley case. Dr. Sanville informed the
family that "if the children are sleeping at the XXXXX
residence [in the UCFSD district] the majority of the time —
defined as at least four days per week — then they will be
considered residents of the UCFSD."
12. Since 2012, UCFSD has continued to monitor this specific case to
ensure that the family is complying with the new standard. The
district has sent private investigators and their observations
confirm that the family is complying with the new standard. To
date, approximately 20 residency checks have been made to ensure
compliance.
13. It is apparent that the family in question did not properly reside in
the school district for a substantial period of time prior to Dr.
Sanville and Dr. Manzone spotlighting this case. They were allowed
to do so by previous administrative leaders – as detailed in number
nine (9) above.
14. Based upon the current UCFSD policies and procedures, the XXXXX
family is complying with all current requirements, and the students
are entitled to attend UCFSD schools
15. While Dr. Manzone’s intentions were good, her actions in following
the family were very inappropriate, bordering on dangerous, and way
beyond the normal scope of a Board member’s role. She took these
actions to check the situation out and bring proof that the family
had a primary residence outside the UCFSD boundaries – but that is
not a Board member’s role.
16. Indeed, the determination of who exactly should be investigating
residency issues needs to be resolved by the Board as it moves
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forward. This reviewer does have some recommendations to make in
this regard.
VI:
Commendations
There were many positive actions taken on behalf of improving UCFSD – and this
reviewer notes the following commendations:
A. Every person acted in good faith – and took steps they believed to be in
the best interests of UCFSD.
B. Dr. Manzone was acting in good faith on community complaints about
illegal students enrolled in UCFSD schools.
C. Dr. Manzone worked with Dr. Sanville to raise this issue to the forefront
of administrative work.
D. Dr. Sanville was asked to take on this case during his initial months as
a new Superintendent – and he accepted the challenge.
E. Dr. Sanville aggressively moved to challenge the family in question, and
ended up dis-enrolling the students from the Unionville-Chadds Ford
School District.
F. Dr. Sanville correctly involved the Unionville-Chadds Ford Board
solicitor, Mr. Jack Merrick, in his decisions. According to Mr. Merrick,
this did not always happen in the past.
G. The solicitor conducted a detailed and thorough legal review – and
identified the key cases speaking to the issues. He guided the Board to
adopt a new and better set of policies on this issue.
H. The appropriate and cost effective use of the private investigatory firm
was the right move by the Board and administration. Since the UCFSD
cost of services is over $18,700 per student per year, the amount
expended to verify residency is well worth it to a school district. Such an
action verifies the residency of current cases – and also serves to deter
other such cases from arising.
I. UCFSD is spending an appropriate amount of money and time on
student residency issues, as per the chart included in Appendix B.
J. UCFSD spent about $30,800 on student residency issues over a threeyear period – averaging around $10,300 a year. The three-year cost
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range from the fifteen (15) school districts responding (including UCFSD)
runs from a low of $3,000 to a high of $390,000.
K. The one-year cost for UCFSD would be $10,300. The fifteen (15) school
districts’ data ranges from a low of $1,000 per year to a high of
$130,000 a year.
L. The average cost for these school districts would be approximately
$74,900 for three years – or - $23,900 per year. This data places
UCFSD’s $10,300 annual costs below the average – about 43% below
the average of all school districts’ annual costs.
M. The UCFSD Board has undertaken a comprehensive review of their
residency policies and procedures – making sound changes to the
existing policies and procedures – and even implementing whole new
policies to supersede the old policies.
N. These new policies and procedures are now in place – and do represent
considerable improvement to a long-standing issue.
O. The Unionville-Chadds Ford Board has attempted to engage Chester
County Intermediate Unit in an objective review of the whole student
residency issue – and a particular objective review of this single family’s
case.
VII:
Recommendations
There are a few key recommendations the reviewer would make to the
UCFSD Board. These are:
1) The existing policy is sound, and the procedures should be
reviewed every two years to make sure they are working.
2) The existing policy and accompanying administrative
procedures should be consistently followed until such time as a
future UCFSD Board wishes to see them changed.
3) The Board must consider, discuss, and decide the philosophical
approach they wish to take to the issue of student residency –
whether it be a “tough” or a “helpful” approach. (Both
approaches are legal – and should simply follow the policies
now in place. However, the procedures used by the
administrator in charge would be different – depending upon
which philosophical approach taken.)
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4) Board Members should urge any community or school district
members with residency concerns or questions to funnel all such
issues to a single point of contact in central office.
5) This administrative residency review point-of-contact should
NOT be the Superintendent – who has a fundamental mission to
be helpful and student centered. We recommend this position be
the Business Manager, who has a fundamental mission to
protect and conserve the resources of the school district.
6) No other school district related person (other than the
designated Unionville-Chadds Ford Residency Officer) should be
actively involved in investigating suspected abuses.
VIII:
Conclusion
In Conclusion, this Residency Review did the following:
1 Provided an analysis of current UCFSD practices related to student
residency. As appropriate, compared UCFSD practices to that of other
districts. This analysis includes commendations and recommendations
as appropriate.
• Accomplished as charged
• UCFSD practices and policies are in line with other quality
school districts in the area
2 Reviewed the XXXXXXX residency case. Provided an evaluation of
the district’s handling of this case. Included are commendations and
recommendations as appropriate.
• Accomplished as charged
• See key findings, commendations, and recommendations
3 Analyzed current UCFSD’s residency practices and procedures for
relative cost effectiveness. Compared UCFSD’s costs to other school
districts.
• Accomplished as charged
• See Comparative Residency Costs in Appendix B
• The UCFSD residency costs are reasonable and much lower
than the average amount spent by other school districts
4 Reviewed policies and guidelines that govern student residency.
Determined that UCFSD’s policies and practices do conform to industry
standards.
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IX: About The Study
This review involved over 17 interviews between March 26 and July 1, 2014
with staff, Dr. Manzone and Board members. These interviews were done by
Joseph J. O'Brien, Ed.D., Executive Director of the Chester County
Intermediate Unit.
This review includes a comprehensive review of what other Chester County
school districts are doing in this area – along with selected out of county
school districts that have similar issues with student residency. The
following school districts were approached:
Ø Springfield School District
Ø Wallingford-Swarthmore School District
Ø Upper Darby School District
Ø Lower Merion School District
Ø Haddonfield School District
Please note that not all the school districts participated in this review. Where
it seemed appropriate to the reviewer, Dr. O’Brien did make an informed
estimate of the data. This was especially true of the comparative cost data.
All estimated information is coded and identified. Individual school district
data will not be shared publicly.
The following CCIU administrative leaders, project staff members, and
confidential Administrative Assistant have assisted in this review:
Ø Joe O'Brien, Executive Director, Chester County Intermediate Unit
§ Developed Interview Questions and Process of the Review;
Conducted all Interviews; Contacted some of the school
districts’ Superintendents to explain the need for their
information; Analyzed the other school district’s
information; Wrote the report; present the final report to
Unionville-Chadds Ford School District Board.
Ø Iain Strachan, Director of Human Resources, Chester County
Intermediate Unit
§ Developed Interview Questions and Process of the Review;
Analyzed other school district information; assisted in
editing and revising the report; helped present the final
report to the Unionville-Chadds Ford Board.
Ø Jessica Corry, Communications Specialist, Chester County
Intermediate Unit
§ Contacted all school districts for cost data; developed the
cost comparison chart as shown; reviewed all information
and assisted in all the compilation work; Compiled the
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school district data – and worked with Joe O'Brien to
develop the format of the final report.
Ø Stacy Ososkie, Communications Specialist, Chester County
Intermediate Unit
§ Contacted all school districts involved to secure
information; reviewed all published residency and
attendance information available on each school district’s
website; Compiled the school district data – which will be
included as an attachment to the final report.
Ø Janice Heagy, Administrative Assistant to Executive Director of
Chester County Intermediate Unit
§ Assisted in the preparation of the report; did all copying
and processing of the information received; coordinated
interview schedules; and provided general support and
assistance as a superior Administrative Assistant.
Additionally, numerous policies, procedures, regulations, position
descriptions, and other documents were examined from Unionville-Chadds
Ford and approximately fifteen (15) other Pennsylvania and New Jersey
school districts. We believe that the totality of the information we have
examined will eventually give a complete and accurate picture of the student
residency process of the district.
All Board Members and Superintendent Sanville will receive a hard copy of
this final Residency Review, including all of the reports and appendices –
except for supplemental information, which will be made available under the
section titled “Documents Referenced.”
Please note that the information presented has been summarized from the
interviews – and no specific attribution is made to any single person. All were
promised anonymity, and the reviewer has tried very hard to honor that
request as much as possible. (Both Dr. Manzone and Dr. Sanville understand
that they will be identified.)
Finally, I wish to thank all of the Unionville-Chadds Ford School District staff
members and the Chester County Intermediate Unit staff members who helped
compile this report.
Respectfully Submitted,
Joseph J. O'Brien, Ed.D.
Executive Director
Chester County Intermediate Unit
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INDEPENDENT REVIEW
COMPARATIVE
RESIDENCY COSTS
19
3
$9,420 (2013-14)
$8,699 (2013-14)
$18,119 (2013-14)
$18,119
$37,805
Seriousness of Issue
20
1
$39,326
$39,326
$117,978**
Seriousness of Issue
4
** Data extrapolated from 2013-14 costs
1
21
1
2
Seriousness of Issue
1 (not serious)
to
4 (very serious)
22
3
INDEPENDENT REVIEW
NEW UCFSD POLICY
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No. 200
UNIONVILLECHADDS FORD
SCHOOL DISTRICT
SECTION:
PUPILS
TITLE:
ENROLLMENT OF STUDENTS
ADOPTED:
MAY 19, 2014
REVISED:
200. ENROLLMENT OF STUDENTS
1. Authority
SC 1301, 1302
22 Pa. Code
Sec. 11.11, 11.41
The district shall enroll eligible school age students in accordance with Board policy
and applicable laws and regulations.
2. Definitions
SC 1304, 1326
Beginners are students entering the lowest grade of the primary school above the
kindergarten level.
SC 1302
22 Pa. Code
Sec. 11.11
District of residence shall be defined as the school district in which a student’s
parents reside. When the parents reside in different school districts due to
separation, divorce, or other reasons, the child may attend school in the district of
residents of the parent with whom the child lives for a majority of the time, unless a
court order or court approved custody agreement specifies otherwise. If the parents
have joint custody and a child’s time is evenly divided, the parents may choose
which of the two school districts the child will enroll for the school year. If the
parents maintain two residences, one within a district, one outside the District, the
district of residence shall be the residence where the child spends the majority of the
time when school is in session (that is, excluding winter, spring, and summer
vacations). “Majority of the time” shall be construed as at least four nights a week.
These rules shall also apply to guardians of students.
Federal installations are considered a part of the school district or districts in which
they are situate and the children residing on such installations shall be counted as
resident pupils of the school district.
22 Pa. Code
Sec. 11.11
An emancipated minor shall be defined as a student under the age of twenty-one (21)
who has established a domicile apart from the continued control and support of a
parent/guardian or who is living with a spouse.
42 U.S.C.
Sec. 11434a
Pol. 251
Homeless students shall be defined as children and youths who lack a fixed, regular
and adequate nighttime residence. Homeless students include children and youths
sharing the housing of other persons due to loss of housing, economic hardship or a
similar reason; living in emergency, transitional or domestic violence shelters;
awaiting foster care placement; and any other children and youths meeting the
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Page 1 of 8
200. ENROLLMENT OF STUDENTS - Pg. 2
definition of homeless in federal law.
SC 1301
22 Pa. Code
Sec. 11.12
School age shall be defined as the period from the earliest admission age for the
district's kindergarten program until graduation from high school or the end of the
school term in which the student reaches the age of twenty-one (21) years,
whichever occurs first.
42 U.S.C.
Sec. 11434a
Unaccompanied youth shall be defined as any youth who is not in the physical
custody of a parent/guardian. This includes youth who have run away from home,
been thrown out of their home, been abandoned by their parents/guardians or
separated from their parents/guardians for any other reason.
3. Guidelines
Admission Age Requirements
Kindergarten –
22 Pa. Code
Sec. 11.14
The Board establishes the district’s entry age for kindergarten as not less than five
(5) years before the first day of September.
First Grade –
SC 1304
22 Pa. Code
Sec. 11.15
The Board establishes the district’s entry age for beginners as not less than six (6)
years before the first day of September.
SC 1304, 1326
Beginners shall be admitted to school during the first two (2) weeks of the annual
school term and thereafter at the district’s discretion. A child who is eight (8) years
of age shall be admitted to school at any time during the school year.
Early Admission –
22 Pa. Code
Sec. 11.16
The Board may admit as a beginner a child who is five (5) years old and
demonstrates readiness for entry by the first day of the school term, upon the written
request of the parent/guardian, recommendation of the district psychologist, and
approval of the Superintendent.
22 Pa. Code
Sec. 11.16
The Board is not required to admit as a beginner any child whose age is less than the
district's established admission age for beginners.
Enrollment Requirements Of Resident Students
SC 1301, 1302
22 Pa. Code
Sec. 11.11, 12.1
School age children shall be entitled to attend the schools of their district of
residence.
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200. ENROLLMENT OF STUDENTS - Pg. 3
22 Pa. Code
Sec. 11.11
The district shall normally enroll eligible school age students the next business day,
but no later than five (5) business days after application.
SC 1301, 1302,
1303a
22 Pa. Code
Sec. 11.11
Except when a child is homeless, the district shall not enroll a student until the
parent/guardian has supplied:
Pol. 203
2. Immunizations required by law - Acceptable documentation includes: either the
child’s immunization record, a written statement from the former school district
or from a medical office that the required immunizations have been
administered, or that a required series is in process, or verbal assurances from the
former school district or a medical office that the required immunizations have
been completed, with records to follow.
1. Proof of the child’s age - Acceptable documentation includes: birth certificate,
notarized copy of a birth certificate, baptismal certificate, copy of the record of
baptism – notarized or duly certified and showing the date of birth, statement
from the parents or another relative indicating the date of birth, a valid passport,
or a prior school record indicating the date of birth.
3. Proof of residency - Acceptable documentation includes: a deed, a lease, current
utility bill, current credit card bill, property tax bill, vehicle registration, driver’s
license, or DOT identification card. The district may require that more than one
(1) form of residency confirmation be provided. In verifying residency, the
district shall require only such information as is deemed reasonable in light of a
family’s circumstances.
SC 1304-A
Pol. 216.1
SC 1317.2
22 Pa. Code
Sec. 11.11
Pol. 138
4. Parental Registration Statement - A sworn statement or affirmation attesting to
whether the student has been or presently is suspended or expelled for offenses
involving drugs, alcohol, or weapons; willful infliction of injury to another
person; or any act of violence committed on school property must be provided
for a student to be admitted to any school entity.
However, the district shall not deny or delay a student’s enrollment based upon
information contained in the student’s certified disciplinary record or Parental
Registration Statement, but may provide alternative education services to
students who have committed weapons offenses, in accordance with applicable
law.
5. Home Language Survey - The district shall administer a home language survey
to all students enrolling in the district’s schools for the first time. Enrollment
may not be delayed in order to administer the Home Language Survey.
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Pol. 216, 216.1
Upon enrollment, the district shall contact a transfer student’s former school and
request a certified copy of the student’s education records and, if applicable, the
student’s discipline records. The district shall enroll eligible students within five (5)
business days of application regardless of receipt of records from previous districts.
In addition to the required information listed above, the district may ask for the
following information: (a) picture identification; (b) health or physical examination
records; (c) academic records; (d) attendance records; (e) Individualized Education
Program; and (f) other special education records. Enrollment may not be conditioned
upon or delayed until these documents are provided.
The district shall not request or require any of the following for enrollment or
residency determinations: (a) a social security number; (b) the reason for the child’s
placement if not living with natural parents; (c) child’s or parent’s visa; (d) agency
records; or (except for the limited circumstances below) (e) a court order or records
relating to a dependency proceeding.
Homeless And Unaccompanied Students
Pol. 251
In the case of homeless or unaccompanied students, traditional concepts of residence
and domicile do not apply. The district shall immediately enroll identified homeless
students, even if the student or parent/guardian is unable to produce the required
documents, in accordance with Board policy and applicable law.
Emancipated Minors
22 Pa. Code
Sec. 11.11
The school district in which an emancipated student is living is his/her district of
residence. Emancipated minors may enroll without any additional assistance from a
parent/guardian, upon submission of required documentation. Emancipation of a
minor is a question of fact, which is not presumed and is not solely dependent upon
the employment status of the minor. The burden of establishing emancipation is on
the student seeking emancipated status.
Immigration Status
22 Pa. Code
Sec. 11.11
The district shall not inquire as to the immigration status of a student as part of the
enrollment process. A child’s right to be admitted to school may not be conditioned
on the child’s immigration status.
Custody Agreements
22 Pa. Code
Sec. 11.11
A school age student is entitled to be enrolled in the schools of the district where
his/her parent(s) or legal guardian(s) resides, upon submission of required
documents.
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200. ENROLLMENT OF STUDENTS - Pg. 5
If the parent enrolling a student is relying on a court order or custody agreement as
the basis for enrollment, the district may require submission of the court order or
custody agreement.
Enrollment And Placement Of Twins And Higher Order Multiple Siblings
SC 1310.1
Pol. 206
Twins or higher order multiple siblings shall be enrolled in the district in the same
manner as all other students. Placement of twins or higher order multiple siblings in
particular classrooms within the district shall be determined in accordance with
applicable law and Board policy.
Pre-adoptive And Adoptive Students
SC 1302
Students living with pre-adoptive parents who are receiving adoption assistance
subsidies, pre-adoptive foster payments, Supplemental Security Income (SSI), or
Transitional Assistance for Needy Families (TANF), are entitled to attend public
school within the district. Students living in pre-adoptive or adoptive situations are
considered residents or the district and are entitled to all free school privileges
accorded to resident students.
Students Of Military Personnel
SC 1302
When residents are military personnel who are deployed and their children are living
with relatives within the district, the students are entitled to attend school in the
district. The students should be enrolled following the same guidelines as
nonresident guardianship situations. See Students Living With Resident Adult Other
Than Parent below for registration guidelines.
When a child lives outside of Pennsylvania as a result of one (1) or both parents
being called or ordered to active military duty, other than active duty training, the
child shall continue to be considered a resident of the school district that was the
child's district of residence immediately prior to the parent being stationed outside of
Pennsylvania, provided that the parent maintains the residence.
Students And Families With Limited English Proficiency
Pol. 138
Students and families with limited English proficiency will be provided translation
and interpretation services to the extent needed to help the family understand the
enrollment process and enroll the students properly.
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200. ENROLLMENT OF STUDENTS - Pg. 6
Address Confidentiality Program (ACP)
Some families may enroll a student using an ACP card which lists a post office box
as their address. This is their legal address and school districts shall not require
additional information regarding their residence. School records from the student’s
former school will be forwarded through the ACP. If there are questions about the
family’s eligibility for enrollment, contact the ACP at 1-800-563-6399.
Enrollment Requirements Of Nonresident Students
The Board may permit the admission of nonresident students in accordance with law
and Board policy.
SC 1302
22 Pa. Code
Sec. 11.19
Before any eligible nonresident student may be accepted as a student in district
schools, the Board requires that appropriate documentation verifying the student’s
eligibility be submitted. The Board reserves the right to verify claims supporting
nonresident enrollment and to remove from school attendance a nonresident student
whose claim is invalid.
SC 1316, 2561
Pol. 607
Tuition rates shall be determined annually in accordance with law. Tuition shall be
charged monthly, in advance of attendance.
The Board shall not be responsible for transportation to or from school for any
nonresident student residing outside school district boundaries. Transportation shall
be the responsibility of the student’s parents/guardians.
Nonresident Children Residing With A District Resident –
When a student lives with a district resident who is supporting the student without
personal compensation (gratis), the student can enroll in a district school if the
resident makes application and provides the required documentation.
SC 1302
22 Pa. Code
Sec. 11.19
The Board shall require that appropriate legal documentation showing dependency
or guardianship or a sworn statement of full residential support be filed with the
district before an eligible nonresident student may be accepted as a student in
district schools. The Board may require a resident to submit additional, reasonable
information to substantiate a sworn statement, in accordance with guidelines issued
by the Department of Education.
SC 1302
Pol. 906
If information contained in the sworn statement of residential support is found to be
false, the student shall be removed from school after notice is given of an
opportunity to appeal the student’s removal, in accordance with Board policy. The
district reserves the right to pursue prosecution of any person who knowingly
provides false information in the sworn statement for the purpose of enrolling a child
in a district school for which the child is not eligible.
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200. ENROLLMENT OF STUDENTS - Pg. 7
A resident’s receipt of payments, such as Supplemental Security Income (SSI),
Transitional Assistance for Needy Families (TANF), pre-adoptive support, child
support, maintenance on public or private health insurance, support from the U.S.
military or military personnel or other payments for or on account of the student will
not be considered personal compensation or gain.
Students Placed In Resident’s Home/Foster Care
SC 1305
Any child placed in the home of a district resident by a court or government agency
shall be admitted to district schools and shall receive the same benefits and be
subject to the same responsibilities as resident students.
Nonresident students placed in foster care are entitled to the same educational
privileges as students residing in the district.
In addition, this includes students awaiting foster care placement; although, the
district will contact the Chester County Department of Children, Youth and Families
to determine if students meet the qualifications of a student awaiting foster care
placement.
Students As Residents Of Institutions
SC 1306, 1307,
1308, 1309,
1310, 2561,
2562
22 Pa. Code
Sec. 11.18
A child who is living in or assigned to a facility or institution for the care or training
of children located within this district is not a legal resident of the district by such
placement; but s/he shall be admitted to district schools, and a charge shall be made
for tuition in accordance with statute.
SC 1306.2, 1318
A juvenile who is eligible for educational services and is confined to an adult local
correctional institution following conviction for a criminal offense shall receive
educational services from the school district in the same manner and extent as an
expelled student.
SC 1306.2
A juvenile who is eligible for educational services and is confined to an adult local
correctional institution following a charge for a criminal offense shall receive
educational services from the school district in the same manner and extent as a
student placed in an alternative education program for disruptive students.
Students Incarcerated In Adult Facilities
Students returning from a delinquency placement are entitled to an informal hearing
prior to being placed in an alternative education program. The purpose of the hearing
is to determine whether the student is currently fit to return to the regular classroom
or meets the definition of a disruptive student.
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200. ENROLLMENT OF STUDENTS - Pg. 8
Prospective And Former Residents
SC 1316
A student eligible for attendance whose parent/guardian has executed a contract to
buy, build or rent a residence in this district, which can be documented by signed
lease, signed purchase of sale or construction contract which sets the date of
occupancy no later than 120 calendar days from the date of registration may be
enrolled upon payment of tuition from the date of enrollment until residency is
established. If the 120 day requirement is met, the tuition paid will be refunded. In
no case is this allowance to extend beyond the then current school year.
Regularly enrolled students whose parents/guardians have moved out of the school
district during the school year will be permitted to complete the balance of that
school year as a tuition student. Once a student has begun his/her senior year, s/he
may complete their year tuition-free provided they maintain a positive discipline
record and attendance record.
In all cases, should a family not pay the tuition charges in advance, on a monthly
basis, the student(s) shall immediately be denied access to the school(s) and the
district of residency will be notified of said action.
Parents of students who claim admission on the basis of future residency shall be
required to demonstrate proof of the anticipated residency.
SC 1302
4. Delegation of
Responsibility
22 Pa. Code
Sec. 11.41
The Board reserves the right to verify such claims and to remove from school a
nonresident student whose claim is invalid.
The Superintendent or designee shall annually notify students, parents/guardians and
staff about the district’s policy on student enrollment and admissions by publishing
such policy in the student handbook, parent newsletters, district website and other
efficient methods.
References:
School Code – 24 P.S. Sec. 501, 502, 503, 1301, 1302, 1303a, 1304, 1304-A, 1305,
1306, 1306.2, 1307, 1308, 1309, 1310, 1310.1, 1316, 1317.2, 1318, 1326, 2503,
2561, 2562
State Board of Education Regulations – 22 Pa. Code Sec. 4.41, 11.11, 11.12, 11.41,
12.1, 14.101 et seq.
Board Policy – 113, 138, 203, 206, 216.1, 251, 607, 906
Pennsylvania Department of Education Basic Education Circular – Enrollment of
Students – January 22, 2009
Pennsylvania’s Education for Children and Youth Experiencing Homelessness
Program – State Plan
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INDEPENDENT REVIEW
CORRESPONDENCE
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FW: UCF residency review - Jess Corry
FW: UCF residency review
Joe O'Brien
Wed 7/9/2014 2:03 PM
To:Jess

Corry <[email protected]>;
1 attachment
Attach0.html;
From: John Sanville <[email protected]>
Date: Thursday, February 27, 2014 at 2:48 PM
To: Joe O'Brien <[email protected]>, Joe O'Brien <[email protected]>
Subject: UCF residency review
Joe,
We will have the binder of materials for your team tomorrow so that you may begin the UCF
residency review. This is an independent review organized by your team. However, may I be so bold
as to make suggestions that you may consider.
Specifically:
Interview Holly Manzone. We have provided her resignation letter and her letter to the
community that expresses concerns. I do not feel a thorough review can be conducted without
speaking with her. Cell # —
e-mail —
Interview UCFSD parent and resident
has made residency
complaints to the district and to the Attorney General. I believe the CCIU's investigation would
be well served by speaking with him. Cell # —
home # —
email
—
Speak with Board President, Vic Dupuis. Cell# —
Answer the question — Have you found any evidence of residency violations?
Thanks,
John
-John C. Sanville
Unionville - Chadds Ford School District
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FW: Update on Residency Practices Review for UCFSD - Jess Corry
FW: Update on Residency Practices Review for UCFSD
Joe O'Brien
Thu 7/10/2014 3:45 PM
To:Jess

Corry <[email protected]>;
1 attachment
Attach0.html;
From: John Sanville <[email protected]>
Date: Thursday, May 15, 2014 at 10:16 PM
To: Joe O'Brien <[email protected]>, Joe O'Brien <[email protected]>
Subject: Re: Update on Residency PracKces Review for UCFSD
Joe -- no heartburn on my end. One clarification though -- under III. 2. -- I believe that I indicated
that any independent legal review would be conducted through Jack Merrick and we didn't need you
to undertake that aspect. Let me know if that edit causes you heartburn. Cheers -- John
Sent from my iPad
On May 15, 2014, at 4:37 PM, Joe O'Brien <[email protected]> wrote:
Dear John and Unionville-Chadds Ford Board Colleagues,
This is an update on the Independent Review of UCFSD Residency Practices which we
have undertaken on your behalf. We started on this work in early March, 2014 (I am not
sure of the exact date) and we anticipate finishing the report by June, 2014. The bulk of
this work has been done over the past two weeks – as we finally received the residency
information from the school districts from which we requested information – and it took
a lot of time to get that data and to read through every residency policy received.
However, that part is behind us, and that is a large part of the residency review, so we
think we should be in good shape to hit our deadline
This progress report is a sequential listing of the actions taken thus far, the actions yet
to be done, and it is provided in the actual format of the final report.
I would ask all of you and John to please make sure you are comfortable with the
format, and comfortable that we are doing all the actions you wanted us to do.
If okay, I would be calling Unionville-Chadds Ford Board members and your
solicitor next week – asking everyone a standard set of questions, and giving
everyone a chance to tell me anything else you need me to know.
I am optimistic that we will hit our deadline of June 16th – unless new information
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FW: Update on Residency Practices Review for UCFSD - Jess Corry
emerges in the final weeks. I would be very happy to attend an executive session Board
meeting to present the final report personally.
Thank you for your cooperation – and for all you do for public education in Chester
County… It is always a pleasure dealing with you individually – and as a full Board!!
Enthusiastically,
Joe
Joseph J. O'Brien
Executive Director
Chester County Intermediate Unit
PS – John, I will work though you – so please send this out to your Board members and
solicitor… Thanks !
<UCFSD Resdidency Review.doc>
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Revised Residency Report - Set for Board Approval - Jess Corry
Revised Residency Report / Set for Board Approval
Joe O'Brien
Mon 6/30/2014 5:21 PM
To:John
Cc:Iain
Sanville <[email protected]>;
Strachan <[email protected]>; Janice Heagy <[email protected]>;
1 attachment
UCFSD Resdidency Review.doc;
Hi John,
Good meeting today…
As promised, here is the just revised Unionville-Chadds Ford Residency Review Report… attached
above!
Please review it yourself – and also share it with your Board Colleagues for their review.
I believe I am finished, but I want to make sure you and your Unionville-Chadds Ford Board of
School Directors agree:
Would you please ask the Board to respond to the following questions?
1. Would the Board like me to interview anyone else in this process? I interviewed
all Board members, Superintendent Sanville, Solicitor Merrick, and former Board
Member Manzone about the student case. Does the Board wish me to interview
anyone else? The parents of the students involved? Other parties, like
Anyone else at all.
2. Are there any other school districts you wish us to check on? We covered all
of Chester County – plus
(selected because they have each wrestled
with similar issues – and because I had working knowledge of these school
districts.)
3. Is there anything else at all the Board would like me to pursue?
Thanks for checking with your Board… After all, this review has been commissioned by them – and
it should meet their needs. (I am NOT looking for agreement – just a validation that I did what they
asked me to do.)
Once the Board says our work is done and it is all they wanted, then we will proceed to final
product – which should take only a few days to pull together.
My Chester County Intermediate Unit team will have
48 hard copies for the Board and you – and have
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Revised Residency Report - Set for Board Approval - Jess Corry
electronic copies available as well.
Thanks again – and be well, John!
Have a Nice Day !
Enthusiastically,
Joe
Joseph J. O'Brien
Executive Director
Chester County Intermediate Unit
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INDEPENDENT REVIEW
SPECIFIC RESIDENCY CASE
CHRONOLOGY OF EVENTS
DR. SANVILLE LETTERS TO XXXXX FAMILY
May 23, 2012
June 25, 2012
July 18, 2012
August 10, 2012
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INDEPENDENT REVIEW
UCFSD RESIDENCY COSTS
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INDEPENDENT REVIEW
INTERVIEW QUESTIONS
66
Interview Questions for Dr. Holly Manzone June 19, 2014 A- Joe O’Brien called each Board member and Unionville-Chadds Ford solicitor using the phone
numbers provided by Superintendent Sanville.
B- Joe O’Brien to explain Unionville-Chadds Ford assignment of this case to Chester County
Intermediate Unit to review and make commendations and recommendations.
Questions:
1. How long have you been associated with the Unionville-Chadds Ford school district?
How long were you a Board member?
2. Do you remember the student residency case that I have been asked to review?
What do you know about this case?
3. Do you know the family whose residency has been questioned?
In what capacity do you know the family?
Was there any prior incident with any member of this family?
3. Why did you, Dr. Manzone, leave the Board?
Did your resignation make the Board and/or the community more or less aware of the
student residency issue?
5. Do you remember being briefed about this case by the administration?
6. What do you think was done well in this case?
What do you think could have been done differently in this case?
7. In your opinion, is student residency a “hot issue” and/or a major concern for your school
district?
8. Are there many/some/or just a few other student residency cases of which you are aware?
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Interview Questions for Dr. Holly Manzone June 19, 2014 9. On a scale of 1 to 10 (with 1 being very low and 10 being extremely high), how large a
problem is the issue of student residency in Unionville-Chadds Ford school district?
10. What policy changes, if any, do you think the Board should make to their existing
policies and procedures?
11. Should the student residency process be an administrative function and responsibility
only, or do you think the Board should be involved?
If the Board should be involved, at what level?
12. Who should be involved in investigating student residency cases? How much should be
spent on these investigations?
13. Is there anything else you think we should know about this case in particular – or the global
issue of student residency in the Unionville-Chadds Ford school district in general?
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Interview Questions for Unionville-Chadds Ford Board Members
May 16, 2014
A. Joe O’Brien to call each Board member and Unionville-Chadds Ford solicitor using the phone
numbers provided by Superintendent Sanville.
B- Joe O’Brien to explain Unionville-Chadds Ford Board assignment of this case to Chester
County Intermediate Unit to review, and make commendations and recommendations.
Questions:
1. How long have you been associated with the Unionville-Chadds Ford school district?
a. How long have you been a Board member?
2. Do you remember the student residency case which I have been asked to review?
a. What do you know about the case?
3. Do you know the family whose residency has been questioned?
a. In what capacity do you know the family?
4. Were you aware of the case before Dr. Manzone left the Board?
a. Did her resignation make you more or less aware of the student residency
issue?
5. Do you remember being briefed about this case by the administration?
6. What do you think was done well in the case?
a. What do you think could have been done differently in this case?
7. In your opinion, is student residency a “hot issue” and/or a major concern for your school
district?
8. Are there many/some/or just a few other student residency cases of which you are aware?
9. On a scale of 1 to 10 (with 1 being very low and 10 being extremely high), how large a
problem is the issue of student residency in Unionville-Chadds Ford school district?
10. What policy changes, if any, do you think the Board should make to your existing
policies and procedures?
11. Should the student residency process be an administrative function and responsibility
only, or do you think the Board should be involved?
a. If the Board should be involved, at what level?
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Interview Questions for Unionville-Chadds Ford Board Members
May 16, 2014
12. Who should be involved in investigating student residency cases? How much should be
spent on these investigations?
13. Is there anything else you think we should know about this case in particular – or the
global issue of student residency in Unionville-Chadds Ford school district in general?
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INDEPENDENT REVIEW
DOCUMENTS
REFERENCED
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Documents Referenced
A. Suburban School District Residency Practices
B. 2014 Unionville-Chadds Ford School District Residency Review
Submitted by Superintendent John Sanville
1.
2.
3.
4.
5.
6.
7.
8.
9.
Charge of Review
Confidentiality Agreement
Policies No. 200, 201 and 202
Outline of Current Practices (Administrative Guidelines-202)
Residency Status Reports (2011-13)
Tuition Students (2013-14)
Billing Reports
Residency Issue – Chronology
Residency Issue – E-mails and Letters
C. Residency Investigation: Unionville Chadds-Ford School District
Documents Regarding the XXXXXX Residency Issue
Submitted by Dr. Holly Manzone
1. Background, Chronology and School Documents
1.
2.
3.
4.
5.
6.
7.
8.
9.
Manzone Letter of Resignation
Manzone Follow up to Resignation
Manzone Chronology of the Residence Issue
Sanville Chronology of Events
Sanville May 23, 2012 letter to XXXXXX family
Sanville June 25, 2012 letter to XXXXXX family
Sanville July 18, 2012 letter to XXXXXX family
Sanville August 10, 2012 letter to XXXXXX family
Sanville August 17, 2012 email to School Board declaring case closed,
family will reside in district
10. Sanville September 2, 2013 email to School Board
11. Merrick September 9, 2013 memo to School Board
12. Email exchange regarding requests for CFR investigative reports
(Sept/Oct 2013)
13. Manzone message to Merrick and his response on September 19, 2013
14. UCFSD RTK Submittal March 5, 2014
15. Sanville Affidavit March 12, 2014 including Residency Statement
2. School Policy and Pennsylvania Law Regarding Residency
1. UCFSD Policies 201 and 202
2. PA School Code 1302
3. Knauss Legal Research
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Documents Referenced
4. Cumberland Valley School District v. Thane
5. Paek v. Pen Argyl Area School District
6. Auditor General Special Investigation of Schuylkill Haven Area School
District
3. XXXXXX Residency
1.
2.
3.
4.
December 5, 2003 Mortgage with Occupancy Clause
March 16, 2011 Mortgage with Occupancy Clause
Photographs of Chadds Ford property
Photographs of Cochranville property
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