Another Education Finance Tool

Yesterday, I wrote about a short video made by Shannon Meeks from Putnam City. Today I want to point you towards a data tool created by the Oklahoma Policy Institute:

It’s well known that state aid funding in Oklahoma has struggled in recent years — since 2008 we’ve cut per student state aid by 24.2 percent after inflation, the largest drop in the U.S. Cuts to state aid affect all school districts in the state, but not all districts are affected equally. Because state aid to local districts is based on a formula that takes into account the needs of students and the local resources of districts to fund themselves, the amount per student that’s funded by the state varies widely between districts. In the 2015-2016 school year, aid went from a low of $16 to a high of $7,740 per student.

The map below is from their website. Before discussing the nuances of school finance, I want to make a couple of generalizations first.

Source: Oklahoma Policy Institute

One is that southeast Oklahoma tends to get more state aid per pupil than northwest Oklahoma. Poverty and property values are the main reasons why. The other observation is that school districts in northwest Oklahoma tend to cover more land. This part of the state is more sparsely populated, but it’s also flatter. There are some long bus routes, but they tend to be pretty straight.

I point these two things out because we must always understand that there is not one singular picture of a school district in Oklahoma. For that matter, there’s not one singular picture of a school in my district.

If you want to look at the figures more closely, or if you want to see how certain school districts compare to one another, you should visit the interactive map. You may even want to download the data file.

These are real numbers. Any discussion of issues such as vouchers, consolidation, and charter schools should include these figures.

Oh, that reminds me. Here’s the OPI caveat about charters:

[Note: The map does not include charter schools, which tend to receive higher state aid because they have no local revenues. Charter school state aid can be found in the full data set.]

Knowledge is power, people.

State Aid for Schools (ft. Charters)

Sometimes, I get random questions from the long-time listener, first-time caller kind of person who wants to know why I’m so down on charter schools.

I’m not. I have probably written fewer than 10 posts (out of nearly 700) that even address charters. When I do, I don’t focus on their funding. I don’t call out their effectiveness. I merely point out that charter schools are no more effective, according to accountability models that I reject anyway, than traditional public schools.

My position has always been that if you teach kids, I hope you do a good job. When it comes to funding and accountability, you didn’t set up the rules, and neither did I. I have friends who work in charter schools, and I have had graduate students who teach in them.

Charters can have narrow purposes. They can have parental involvement agreements that scare off some families. Still, they are public-ish schools serving public school kids.

They way they receive funding, however, has always been hard for me to explain. That’s why I’m glad I’m not the only person in this state who can explain things.

The video below, which is 11 minutes long and worth every second, provides a better, and more user friendly, explanation of state aid than I have ever seen. It also touches upon how state per pupil funding allocations give charter schools an advantage.

I’ll limit my remarks and let you watch and enjoy the video.

They Come Bearing Gifts

If you’re headed to Oklahoma City next week for the third and final Vision 2020 Conference (whoever wins the election will probably rename it), you may have received an invitation to an open house being held off-site for a new statewide service entity, the Oklahoma Public School Resource Center. Before you succumb to their promises of help to your beleaguered school district, however, here’s a little background information.

Last September, if you’ll recall, the State Chamber of Commerce applied for a Walton Family Foundation grant. While the creation of the OPSRC is separate from that effort, it does involve a lot of the same people. At the time, here’s how the Chamber described the purpose of their application:

This grant request will provide funds in the amount of $300,000 over three years for the Oklahoma State Chamber to establish a new 501 (c) 3 education reform advocacy organization under its auspices that is geographically diverse and ambitious in its aims to advocate for an aggressive change agenda within Oklahoma’s K-12 education system. The first year’s grant is for $100,000 to be evaluated and renewed based on fulfilled outputs and outcomes, as specified below.

The new organization under the umbrella of the State Chamber will seek to educate key stakeholders and policy makers in Oklahoma City, Tulsa and statewide on the need for additional reforms that emphasize protecting and expanding school choice, embracing innovative models, data-driven accountability for schools and school leaders, transparency from school districts, addressing the performance of chronically low-performing schools, and an unwavering commitment to improved student achievement. An annual report will measure progress on outputs and outcomes, with quarterly updates to keep WFF informed along the way.

The Oklahoma State Chamber will seek out additional philanthropic and business community support and funding to ensure the new reform advocacy organization achieves financial sustainability. WFF expects to be joined in supporting the effort by other anchor funders within Oklahoma. The State Chamber will seek support from the Inasmuch and George Kaiser Family Foundations, as well as funding commitments from the Bill and Melinda Gates Foundation and the Arnold Foundation, among others.

The first six months will be spent establishing non-profit status, appointing a board and hiring an executive director. As the new entity hires and executive director and executes its own business plan, the Oklahoma State Chamber will continue to provide staff, office space and other resources for the new entity, and will bring its reputation and strong credibility both at the State Capitol and in the business community.

For more on the State Chamber’s ongoing educational pursuits, see this Tulsa World piece.

I’ve written multiple times about how being a non-profit is not the same as being a charity. Technically, ACT and The College Board are non-profits. So is Measured Progress – our state’s currently in-limbo testing company. Non-profit corporations make money – in some cases a lot of money – without having to pay taxes for it.

The OPSRC is trying to recruit members (they aim for charter school members and rural school districts) but they have recently sent invitations to every school superintendent to come visit them in their new offices during Vision2020 because they are the “most helpful educator support organization you never heard of.”

The application also said that the Chamber was looking for a “super star” from the national reform movement.  Again, though it’s a different organization, OPSRC’s “rock star” executive director is Brent Bushey, who arrived in Oklahoma last year. Aside from being a former Teach for America teacher, he has shallow experience in public education. (I know – I had you at TFA). A glance at his LinkedIn resume reveals a career mostly in IT. Actually, if you Google “Brent Bushey Walton Family Foundation,” the first hit is Damon Gardenhire’s LinkedIn profile. Seriously – it’s not even Bushey’s own LinkedIn page. How does that happen? I Googled myself last night (for fun) and the results were all about me (real me, not blogger me).

Gardenhire, if you’ll recall, used to work for Superintendent Barresi – first unofficially, then officially. When he left for the WFF, here were his comments about Oklahoma school administrators in an email acquired by the Tulsa World.

Just keep in mind that the local supts will keep doing this on every reform until choice is introduced into the system. Until then, they will continue to play these kinds of games. Only choice can be the fulcrum to make them truly responsive. A big part of why I took the Walton gig was because I see real promise for bringing positive pressure to bear that will help cause a tipping point with enough (superintendents) that the ugly voices like Keith Ballard will begin to be small and puny.

As the OPSRC website shows, the Walton Family Foundation is not the only funding source for our new friend in Oklahoma. If my information is correct though (and it usually is), WFF provides the vast majority of money for this venture. Having the involvement of other organizations gives the Center in-state credibility. Without Walton money, the Center would cease to exist. As a member of the tangled web, Bushey’s marching order this past legislative session was to get Senate Bill 573 (which would have opened up all school districts in Oklahoma for profiteering charters school companies) passed. It failed, but will surely resurface next year.

The real danger of OPSRC is they are currently recruiting members – mostly rural school districts. Their model is that charter schools and districts join them and receive services related to finance, legal, technology and communication. These, of course are services that districts already receive from a variety of other acronyms – groups that don’t aim to turn public schools into a revenue stream.  It’s what they previously have done in Arkansas – with strings attached.

The mission of the Arkansas Public School Resource Center is to support the improvement of public education by providing technical support and advocacy services on behalf of public schools with a special emphasis on charter schools and rural districts.

APSRC’s values reflect what the organization expects of itself through the services provided to members and the values of the charter schools and rural districts serving the students of Arkansas.

Members of APSRC sign a commitment to the following values:

• Accountability
• Collaboration
• Choice
• Diversity
• Innovation
• Integrity
• Quality
• Sustainability

If you sign on with the OPSRC, you get the WWF. You get Gardenhire. You get the honor of working with people dedicated to silencing the “ugly voices” and selling school choice throughout Oklahoma. Choice sounds harmless enough, but it is code for vouchers and charters – and not the kind of charter schools we see in Oklahoma City and Tulsa, either. The Foundation, and by proxy, the Center, want to open the door for profiteering charter school companies to take over schools in urban, suburban, and rural areas. That’s always been the end game of the reform movement.

One other thing I want to add is that a group I treasure, the Oklahoma Policy Institute, published a guest post from Sarah Julian, the Director of Communications for the OPSRC, yesterday. What Julian wrote is consistent with OPI’s submission policies, but I want whatever overlap there is between my readers and theirs to fully understand what’s happening here. When someone offers you a smile and a piece of candy, it might be wise to get your Stranger Danger alerts ready.

Willfully entangling your school district with the OSPRC is more or less hopping into bed with the Walton Family Foundation – a group that wants to replace us all with charter schools (until robots become a viable option). It’s not paranoia if it’s true. If you want information about how to get charter school startup money from the WWF, visit their website. This is their priority. This is why they’re here.

Proceed with caution.

No on SB 573 (Charter School Expansion): Call Now!

In 2010, when candidate Janet Barresi entered the Kingdom and spoke to the Protectors (I kid – because it’s easy), one comment struck me more than all others. She stated that it would be a happy day when all public schools performed so well that we wouldn’t need charter schools.

After taking office, she quickly worked with legislators to establish policies designed specifically to create lists of winners and losers. Specifically, the tandem of accountability systems of the A-F Report Cards and the No Child Left Behind waiver created dueling and convoluted scales that ensure a certain percentage of schools are always in need of improvement. In short, there is no world in which candidate Barresi’s vision could ever be achieved. The bureaucrats have ensured this.

For lovers of small government, any new law, agency, or procedure must clearly be matched to an unfulfilled need. This is the litmus test that SB 573 clearly fails and why every one of us who care about high-quality public education and the principles of local control need to remember as we contact our legislators. Email them tonight and call them in the morning. Ask them how much they want out-of-state charter school chains in their own communities.

I read Rep. Denney’s editorial today. I was unmoved. Show me the communities ringing the bell for this. Show me that we’re not just running another ALEC measure up the flagpole. Unfortunately, no such evidence exists.

I read all 48 pages of the engrossed bill. (I read a lot, but not much off my wish list lately.) My biggest concern is with the section that begins on page 13:

SECTION 6. NEW LAW A new section of law to be codified in the Oklahoma Statutes as Section 3-132.6 of Title 70, unless there is created a duplication in numbering, reads as follows: A. The Commission may give priority to applicants that have demonstrated a record of operating at least one (1) school or similar program that demonstrates academic success and organizational viability and serves student populations similar to those the proposed school seeks to serve. B. In assessing a program’s potential for quality replication, the Commission shall consider the following factors before approving a new site or distinct school: 1. Evidence of a strong and reliable record of academic success based primarily on student performance data as well as on other viable indicators, including financial and operational success; 2. A sound, detailed and well-supported growth plan; 3. Evidence of the ability to transfer successful practices to a potentially different context that includes reproducing critical cultural, organizational and instructional characteristics; 4. Any management organization involved in a potential replication is fully vetted and its academic, financial and operational records are found to be satisfactory; 5. Evidence the program seeking to be replicated has the capacity to do so successfully without diminishing or putting at risk its current operations; and 6. A financial structure that ensures that funds attributable to each district school within a network and required by law to be utilized by a school remain with and are used to benefit that

I’m all for replicating best practice. That’s why we have professional development. That’s why we have 60 REAC3H coaches, right? It’s why Jeb Bush and Mary Fallin visited KIPP in Oklahoma City, right? (By the way, when was the last time he was in a traditional public school?) The problem is that every community, every school, and even every classroom has something unique that limits the possibility of replication. Sometimes, what makes one setting great can’t transfer to another.

This is why so many of us rail against the standardization of everything in public education. When we remove the ability of schools and communities to thrive upon what makes them special, we do that even moreso to students. Since the passage of the ACE law, how many high schoolers have their choices of electives severely limited? We’re focused on making every child as college and career ready as the next – no more, no less. And this is wrong.

This bill does nothing to give schools academic flexibility. If a district wants to focus on agriculture or technology, nothing in existing statutes or regulations would keep them from developing coursework to do so. Over the last several years, we’ve even seen language immersion programs pop up in elementary schools around the state, in districts like Jenks (Mandarin) and Norman (French). School districts think outside the box when afforded the opportunity, and all of this comes without the corruption and intrusion of the Carpe Diems of the world.

Remember, the narrative is that we have failing schools and need to fix them at any cost. We have manufactured evidence to support that sketchy tale. With this legislation – and word is that Mary Fallin is lobbying hard for its passage – carpetbaggers who care more about their profits than our kids will have a foot in the door.

Email your legislators…right now. Remind them that even with a lottery in place, charter schools find ways to exclude children. Remind them that charter school performance trails overall public education performance. Warn them of what happens when states open the floodgates to charters everywhere. Call them in the morning. Don’t let them off the call without telling you how they plan to vote.

If need be, remind them you have a vote too.

***

You can find contact information for legislators here.

Charter Schools Expansion: No on SB 573

If you think a statewide commission should be able to authorize the establishment of charter schools anywhere in the state – including your school district, you should love SB 573, which is due to be heard on the floor of the House this week. Since most of us prefer local control of our schools, I thought I should share the alert I received from CCOSA yesterday.

Legislative Action Alert – SB 573 STATEWIDE CHARTER SCHOOL SB 573 by Senator Clark Jolley (R-Edmond) and Rep. Lee Denney (R-Cushing) creates a statewide Public Charter School Commission and grants the Commission authority to authorize and oversee theestablishment of charter schools in any school district in the state.  This bill circumvents the authority of the locally elected board from exercising local control of the education of the children in your community.   This bill is eligible for a House floor vote once it is placed on the agenda which could be anytime.  Title is on the bill.  Please contact your Representative immediately and ask them to vote NO on SB 573!

This is probably part of the reason why Superintendent Barresi asked for a 300 percent increase to the Charter School Incentive fund in her budget request last fall. She has publicly stated on multiple occasions that she is embarrassed we have so few charters. She has not commented, that I know of, on the fact that as a whole, their test scores are less impressive than the state as a whole.

I also haven’t heard anything from any of our state leaders about the fact that opening the door to national for-profit charter school corporations (such as Carpe Diem) will send our tax dollars out of state. Nor have I heard them discuss the problematic track record of such schools, in terms of both accounting and accountability.

Even the candidate for state superintendent with the most charter school experience opposes this expansion. She issued a statement to that effect yesterday (which I can only seem to find on her Facebook page).

I do not believe the purpose of this bill is to help Oklahoma children. I fear its purpose is to expand a national agenda to privatize schools for profit. Our children should not be used as profit centers. Inspiring and motivating children to their highest potential cannot be accomplished with a factory model of education.

Therein lies the rub. The charter school movement, going back to the 1990s in Minnesota and Arizona, sought to bring innovation to instruction by casting off the markers of assembly-line education. Where new ideas were effective, they were cloned – less effectively. The problem is that you can’t mass produce quality. You can hope to replicate average, but excellence springs from the qualities in a person, school, or community that make them unique.

Today’s charter school movement – the corporate education reform movement altogether, in fact – seeks to standardize all things.

We want schools that are accountable to local stakeholders, not out-of-state shareholders. We want schools that are a reflection of our communities. And we want teachers that know and care about our children. That’s why we should all call our legislators and oppose this bill.

Charter School Grades (2013)

A year ago, when this blog was still flying mostly under the radar, I posted the A-F grades of the state’s charter schools. This year, in the wake of Superintendent Barresi saying that she’s “embarrassed” we don’t have more charters and that she’ll “be damned” if we’re going to lose another generation of kids, It’s worth examining them again. Rather than listing grades for each, however, I’ll just show you the trends.

Charter Schools
A	6	23.1%
B	6	23.1%
C	3	11.5%
D	3	11.5%
F	6	23.1%
NA	2	7.7%

All Schools
A	354	19.8%
B	499	28.0%
C	472	26.4%
D	263	14.7%
F	163	9.1%
NA	34	1.9%

Overall, charter schools had a lower percentage of schools with an A or B and a higher percentage of schools with a D or F. With the small sample size (26 schools), it’s really not that different, statistically.

I’ve seen some commentary over the weekend about Harding Charter Prep (of which Barresi was one of the founders) getting a 107 on their report card for an A+ grade. They take pride in the fact that they will take anybody who applies. All that matters is a winning a lottery for admission. While that may be true, details about their student population say a lot about who applies.

Statistic*	Harding Charter	Oklahoma City PS
Free/Reduced Lunch %	42.2%	87.9%
Minority Student %	55.4%	79.9%
Mobility %	0.0%	12.9%
Special Ed %	4.1%	12.1%
Average # of Absences	4.1	10.4

The truth is that HCP does not serve a comparable student population to that of OKCPS as a whole. These data show the benefit of having highly engaged parents. As I did in my post last night, I have listed factors here that impact student achievement. Not having classes in which 1 in 8 students is on an IEP makes a difference. Not having to deal with a lot of absenteeism or students changing schools makes a difference. Having half the poverty level as the whole district makes a difference.

On the other hand, since Harding’s population is chosen at random, let’s get the word out to a wider swath of students. Apply. Attend. Thrive!

*Based on 2011-12 published numbers

Senate Bill 1001 – Parent Trigger

The Oklahoma Senate this week voted 30-12 in favor of SB 1001 – the Parent Trigger Bill. If When this clears the House and the governor signs it into law, it will allow parents in certain circumstances to take control of the school and even demand principals lose their jobs. According to the bill’s Oklahoma author (because I refuse to pretend the bill was really written here), a school receiving a D or F grade for two straight years could be converted to a charter school if a majority of the parents agree.

The Tulsa World explains one problem with the proposed law:

Holt’s bill assumes a set of facts not in evidence – that charter schools, each an academic kingdom unto its own, always are superior to any public schools. “They are not,” points out Sen. Tom Ivester, D-Sayre. “They are statistically right in line with public schools.”

This is true. Oklahoma’s charter schools had lower grades than other state schools, overall. And this conversation doesn’t even begin to address the problem that Oklahoma’s accountability system is fatally flawed.

As written, SB 1001 will not allow parents to petition for change at an existing charter school. Think about this. If a school really belongs to the parents, why can’t they change charter operators? Or change back to a public school. For a glimpse into the road we’re heading down, let’s go to … you guessed it … Florida! When one Sarasota County school tried to fire its charter company, the company countersued. This dispute is ongoing and will be worth following.

It’s always good to be reminded that the profit/non-profit label doesn’t matter. Other than locally-elected school boards, the people who want to run your school for you are more interested in the fiscal bottom line than the students.

It’s also good to remember that parents didn’t ask for this law. In fact, parents will be holding a rally Monday at the Capitol, and one thing on the agenda is to speak against this bill. It is important to remind the party in control of our state that creating a solution to a non-existent problem is the very definition of government over-reach. If smaller government is really important to them, this isn’t it.

*****

To be more fully informed, I recommend reading the entire bill.

National School Choice Week

Prepare to see the PR machines in overdrive. School Choice Week is being celebrated around the country as state legislatures prepare to begin their annual work. In Oklahoma, this means 600 bills that relate to education in some way or another. I would try to provide a digest of them, but I try to keep my blog between 500 and 800 words. Most of these bills are likely to be consolidated or fall to the side completely.

The mythology of school choice goes something like this: students are too often trapped in struggling schools with no alternatives. If the state would only make their money portable, then any private school in the state would take those kids. Short of that, we can just reinvent public schools as charters. Or pull the parent trigger and make schools charters. Or allow any student who feels unsafe to transfer to any other school.

Last year, Superintendent Barresi issued a press release to mark this momentous occasion. In part, it read:

I am a huge advocate of a parent’s right to choose the education that best suits the needs of their children,” Barresi said. “In a free country, with so many exceptional school offerings, there is no reason a child’s education should be bound by his parent’s income level or his geographical location.

This is all empty rhetoric. For school choice to be the great equalizer, you have to have some guarantee that the school you choose would choose you back. Private schools don’t have to. Charter schools technically do, but as I’ve mentioned before, they can insert codicils into their policies that make it extremely difficult for special needs students or children needing remediation to attend. While Oklahoma charter schools still tend to be locally-sprung entities, there are national charter school chains making huge profits.

Nor are the results from private schools and charter schools comparable with those from public schools. In fact, with the private schools, there are no results. They don’t take the same tests. In our data-driven school climates, you would think there might be a push to find out if the potential recipients of vouchers are worth the cash. And charter schools actually did worse overall than the state on the A-F Report Cards.

If we pass a full-on voucher law, does that mean Casady and Holland Hall are just going to change their standards and let anybody in? Does it mean they’re going to expand to offer programs to twice as many students? Of course not. We don’t have private schools – elite or otherwise – in all parts of the state either. Vouchers would be a good boost for families already choosing private schools. In some locations, they would also be a small boost in revenue for schools trying to stay in business. They will not, however, increase equity in public education.

Readers of this blog tend to be independent thinkers. As you hear the various talking points this week, try to find the subtext. Whom will this proposal benefit? What part of the narrative is self-serving or incomplete?

The good news is that I’ll have blog material all week long.

Report Card Grades of Oklahoma Charter Schools

I used the SDE’s new toy to search for the results of our state’s charter schools. Here’s what the search turned up:

District	School	Grade
CHEROKEE IMMERSION CHARTER SCHOOL	CHEROKEE IMMERSION CHARTER SCHOOL	C
GRAHAM	EPIC ONE ON ONE CHARTER SCHOOL	D
OKLAHOMA CITY	INDEPENDENCE CHARTER MS	B
OKLAHOMA CITY	JUSTICE A.W. SEEWORTH ACADEMY	D
OKLAHOMA CITY	HUPFELD ACAD./WESTERN VILLAGE	C
OKLAHOMA CITY	ASTEC CHARTER MS	C
OKLAHOMA CITY	ASTEC CHARTER HS	B
OKLAHOMA CITY	DOVE SCIENCE ACADEMY (OKC)	A
OKLAHOMA CITY	SANTA FE SOUTH HS	C
OKLAHOMA CITY	HARDING CHARTER PREPARATORY HS	A
OKLAHOMA CITY	MARCUS GARVEY LEADERSHIP CS	D
OKLAHOMA CITY	HARDING FINE ARTS ACADEMY	B
OKLAHOMA CITY	SANTA FE SOUTH MS	C
OKLAHOMA CITY	KIPP REACH COLLEGE PREPARATORY	A
OKLAHOMA CITY	DOVE SCIENCE ACADEMY ES (OKC)	B
CHOCTAW-NICOMA PARK	OKLAHOMA VIRTUAL CHARTER ACADEMY	C
SANTA FE SOUTH ES (CHARTER)	SANTA FE SOUTH ES (CHARTER)	D
TULSA	TULSA SCHL OF ARTS & SCIENCES	A
TULSA	KIPP TULSA ACAD. COLLEGE PREP.	B
DEBORAH BROWN (CHARTER)	DEBORAH BROWN COMMUNITY SCHOOL	B

Overall, these scores are not as good as the state as a whole. If I missed any charter schools, it’s because they just didn’t turn up in the search.

Charter Schools Facilities Funding

Last week, legislators held a joint House/Senate interim study on charter school funding. Specifically, they talked about how the high cost of facilities held back the expansion of charters in this state. The AP has a good write up of the meeting here.

Two of the speakers invited to the meeting gave presentations to which I will link. The first, Chris Brewster, is the superintendent of Santa Fe Charter School and president of the Oklahoma Charter Schools Association. The second, Jim Griffin, is president of the Colorado League of Charter schools and an advocate for charter schools with the National Alliance for Public Charter Schools.

Brewster’s presentation focuses on the funding disparity between charter schools in Oklahoma and their traditional counterparts. He mentiones statutes prohibiting charter schools from issuing bonds, levying taxes, and carrying debts. Since these are the revenue sources of public schools needing to build facilities (note: see every suburban school district in Oklahoma), charter schools must turn to private donors to help them acquire facilities.

Griffin’s presentation paints the national picture relative to charter school facilities funding. The key finding is that charter schools spend an average of 14% of their operating revenue on facilities. However, for charters using district-owned space, that drops considerably – to 2%. He concludes by suggesting policy tools that have been adopted in other states: access to vacant public space; access to local property tax revenue; state grant programs; financing conduits; and credit tools.

One fact that emerges from this study is that charters and traditional public schools do not operate under the same set of rules. This is true with regard to class size restrictions, adherence to the teacher salary scale, student selection, and yes – funding for facilities. At the same time, there are school districts in this state that haven’t passed a bond issue in decades. For some, even if they did, the revenue that could be generated would not be enough to add to or significantly improve a campus. Try upgrading a WPA-vintage building in rural Oklahoma to meet all the technology standards required in the Oklahoma testing program – especially when you can’t even pass a bond issue to pay for the technology.

Overlay these issues against the coming push for a Parent Trigger law – a movement designed to enable parents to more or less sell their school to the highest bidder – and the need for a solution is even clearer. The answer will not come from within; we know Oklahoma will not innovate in terms of policy. The playbook isn’t clear at this time, but it will likely come from the shelves of the NAPCS.