Educational Administration Quarterly
Vol. 37, No. 4 (October 2001) 571-599
Educational Administration Quarterly
Garn / BUREAUCRATIC TO MARKET ACCOUNTABILITY
Moving From Bureaucratic to Market
Accountability: The Problem of
Imperfect Information
Gregg Garn
Accountability is a complex idea frequently invoked as political rhetoric. Accordingly, a
theoretical framework that includes bureaucratic, performance, market, and professional models of accountability is necessary to analyze the accountability system created
for Arizona charter schools. Using a qualitative case study that relied on observations,
interviews, and document analysis, this case indicated that valid and reliable performance data are not an intrinsic element of a school choice program. Accordingly, mechanisms that capture and distribute accurate, accessible, and wide-ranging information
about schools of choice will assist consumers in making informed decisions when selecting among schools.
Throughout the 1980s and into the early 1990s, policy makers in Arizona
were not satisfied with the ineffective reform efforts of the traditional district-run school system. Interviews with leading legislators and the sheer volume of policies aimed at enhancing accountability in public schools confirmed that state policy makers were frustrated with the status quo. In 1994,
state legislators approved plans for an alternative model of public education
in the form of charter schools with innovative accountability mechanisms.
Tom Patterson, a sponsor of the charter legislation in the Arizona Senate,
articulated the central motivation for the charter reform:
That charter schools are in a way a test of an entirely different accountability
method which is decentralized, which depends, rather than on bureaucratic
Author’s Note: I would like to thank Robert Stout, Mike Langenbach, Casey Cobb, Katrina
Bulkley, the anonymous reviewers, and the editors of Educational Administration Quarterly for
their insightful comments in preparing the final manuscript.
© 2001 The University Council for Educational Administration
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rules and regulations, on first of all these being schools of choice. It’s accountability that comes from the parents and the consumers.1
Charter schools are nonsectarian, publicly funded schools free of most bureaucratic rules and regulations established through a written contract between a sponsor and an applicant. Through the charter school legislation, Arizona legislators intended to promote competition among public schools by
giving parents and students choices about which school to attend rather than
compelling them to attend the neighborhood district school. Advocates argued that charter schools would break up the district school monopoly—
parents would select the school that best met their children’s educational
needs. They reasoned that charter schools would be more sensitive to customer demands or they would risk losing students and the per-pupil allocations that followed each child. Moreover, losing too many students would result in closure. Charter school advocates predicted that, over time, charter
schools would be a lever to force change in district public schools. Parents,
voting with their feet, would force district public schools to improve, thus
creating a system of high-performing public schools. Leading policy makers
theorized that moving to a market-driven system would ensure greater levels
of accountability.
When putting this theory into practice, authors of the Arizona charter
school legislation included several key provisions to encourage the development of a charter school market. First, they established multiple charter
school authorizers: the State Board of Education (SBE), the State Board for
Charter Schools (SBCS), and the board of education for a public school district (Arizona Revised Statute [ARS] §15-183C, 2000). Second, they placed
no limit on the total number of charter schools that could open each year and
allowed multiple sites to spawn from a single charter (ARS §15-183C2,
2000). Third, they allowed any individual or group (private or public) to operate a charter school (ARS §15-183B, 2000). Fourth, they created a 15-year
contract between the charter school and the sponsor (ARS §15-183I, 2000).
Fifth, they exempted charter schools from the statutes and rules relating to
schools, governing boards, and school districts (ARS §15-183E5, 2000).
Sixth, they allowed charter school operators to own the property purchased
for the school (ARS §15-183U, 2000). Finally, they provided charter schools
with complete financial (ARS §15-185, 2000) and legal autonomy (ARS
§15-183D, 2000). These key provisions provided the freedom from bureaucratic regulations and the autonomy to innovate that appealed to many educational entrepreneurs.
According to the Arizona Department of Education Data, by the spring of
2001, 455 charter school sites were operating in the state (http://www.ade.
Garn / BUREAUCRATIC TO MARKET ACCOUNTABILITY
573
FIGURE 1: Arizona Charter School Density by County
state.az.us/charterschools/search/SiteList.asp), approximately 22% of the
national total (The Center for Education Reform, 2001). Overwhelmingly,
these charter schools are located in urban settings. (See Figure 1.)
Of Arizona charter schools, 66% are located in Maricopa and Pima counties, which include the Phoenix and Tucson metropolitan areas. Although the
state allocates $174 per student for transportation, charter schools are not
required to provide transportation to students. Many schools located in urban
areas provide students with city bus passes or organize parental carpools to
help with transporting children to and from schools. For the most part, parents have the sole responsibility for transporting their children to charter
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schools. However, our lack of understanding about the socioeconomic status
(SES) of parents who chose charter schools obfuscates our understanding of
families who may be constrained from selecting schools that best meet their
academic needs.
U.S. census bureau data on median family income and the percentage of
children in poverty are not especially useful because Arizona’s 15 counties
are extremely large. A 1999 study published by the U.S. Department of Education, titled The State of Charter Schools Third-Year Report, sheds some
light on the demographics of charter school parents. The report concludes
that Arizona charters enroll nearly the same percentage of White students
(56.1% in charters and 56.7% in district schools) and nearly the same percentage of students eligible for free and reduced lunches (39.4% in charters
and 40.1% in district schools) as public schools in the state (http://www.ed.
gov/pubs/charter3rdyear/C.html). However, the report did not examine if
White students and those who qualify for government-subsidized lunches
were concentrated in a few schools or distributed across all charter schools.
By all accounts, policy makers were successful in creating additional choices
for parents and students who live in densely populated counties.
Rarely does the rhetoric of politicians translate smoothly into practice,
and the establishment of charter schools in Arizona was no exception.
Although policy makers created a thriving charter school market, they
neglected to articulate the details of a new market-based accountability system. As a result, personnel at the SBE, the SBCS, the Arizona Department of
Education (ADE), and the auditor general’s office struggled to understand
their roles in the accountability system for charter schools. This role confusion by formal implementation agencies led to persistent information problems for consumers.
To analyze the accountability system for Arizona charter schools, I developed a heuristic framework to evaluate how schools were being held accountable. This framework included a typology of four distinct types of accountability distilled from the literature: bureaucratic, performance, market, and
professional. Moreover, this study examined how policy makers developed
various accountability mechanisms but failed to consider how the mechanisms would interact. The failure to consider the outcomes of the accountability mechanisms had consequences for parents attempting to hold charter
schools accountable.
After reviewing the accountability literature, this article addresses three
primary research questions:
1.
How did state agencies cope with the charter school reform from 1994 to
1998?
Garn / BUREAUCRATIC TO MARKET ACCOUNTABILITY
2.
3.
575
What types of accountability were present in the Arizona charter school
system?
What are the implications for consumers in a market-driven accountability
system?
METHOD
The research questions lent themselves to an exploratory and descriptive
qualitative case study methodology (Merriam, 1998; Stake, 1995; Yin, 1994)
that incorporated three research methods: document analysis, observations,
and focused interviews. The theoretical framework for this case focused on
the issue of charter school accountability. Reviewing the scholarly literature
indicated that there were many distinct models of accountability. Accordingly, while collecting and analyzing data, I was looking for evidence of various types of accountability. Sources included documents, observations, and
interviews with policy makers.
Documents obtained from interviews, site visits, meetings, library
searches, and public records were gathered and analyzed. Documents
reviewed for this study included newspaper articles from the Arizona Republic, the Phoenix Gazette, and the Arizona Business Gazette; the minutes of the
Committee on Education for the Arizona State Senate and the House of Representatives during the first and second regular sessions of the 43rd legislature; charter applications from schools that were approved and operating during the 1995-1996 and 1996-1997 school years; charter school report cards;
ADE site visit monitoring notes; and the Arizona charter school statute. With
the exception of the charter school applications, the legislative minutes, and
the site visit monitoring notes, all documents were available electronically.
This allowed me to explore thousands of pages of text quickly through targeted searches for documents that contained the key words charter school
and/or accountability in the title or text.
The documents served three important functions. First, they were used to
provide background for the interviews. Second, they guided observations of
important actors. Third, the documents were used to verify and strengthen
data from other sources as a confirmatory source after interviews and observations were conducted (Yin, 1994).
Stake (1995) maintained observations that focused on important issues of
a case that increase the researcher’s understanding. For this study, essential
actors were observed in four different contexts, including 3 meetings of the
SBE, 5 meetings of the SBCS, 10 meetings of the Committee on Education in
the Arizona State Senate, and 9 meetings of the Committee on Education in
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Educational Administration Quarterly
the Arizona House of Representatives. I targeted the aforementioned meetings specifically because they were the primary public venues that allowed
leading policy makers a public forum to discuss and defend their views on
charter school accountability. Elements from the physical setting, the participants, the activities and interactions, the frequency and duration, and more
subtle factors outlined by Merriam (1988, pp. 90-91) structured the observations. My role in the field was clearly toward the observer side of the participant-observer continuum (Gold, 1969).
In 1998, focused interviews were conducted with 24 individuals purposefully selected from the SBE, the SBCS, the ADE, the auditor general’s office,
and the Arizona state legislature using the snowball sampling technique
(Patton, 1990). Criteria for selecting legislators and bureaucrats alike were
that they were referenced by others as experts on the charter school policy.
Interestingly enough, legislators frequently mentioned the names of bureaucrats and vice versa. When interviewing the department of education and
auditor general’s office personnel, in addition to sponsoring board staff
members, techniques articulated by Spradley (1979) were employed. A different approach, based on the ideas described by Hertz and Imber (1995), was
utilized when interviewing political elites.
Interviews lasted from 30 to 90 minutes and followed a semistructured
protocol, which used targeted questions that focused on the central themes of
the study. However, the protocol was open-ended enough that the respondents were able to discuss issues they felt were particularly relevant to
accountability in charter schools (Lincoln & Guba, 1985). Sixteen of the
interviews were recorded on audiotape and transcribed verbatim. Eight interviews were conducted over the telephone and documented through extensive
notes. Within 2 weeks of the interview, participants received a copy of the
interview transcripts and/or notes. They were given the opportunity to clarify
and comment on the interview transcript.
Offered the choice of releasing or protecting their identity, legislators and
sponsoring board members were typically interested in getting credit for their
opinions and ideas. Others were less attracted to the publicity; consequently,
job titles replaced names to convey a respondent’s background and insight.
Miles and Huberman (1994, p. 10) defined the three components of data
analysis as data reduction, data display, and conclusion drawing/verification.
Through multiple readings of the data, information was coded and sorted into
four categories derived from the accountability framework. Other codes
emerged from the data as the study evolved and concepts established in the
anticipatory data reduction process were refined. To manage the large volume of information collected in this study I created a matrix with information
Garn / BUREAUCRATIC TO MARKET ACCOUNTABILITY
577
from all three sources (see Miles & Huberman, 1994, p. 11) to better understand the data.
The final aspect of analysis included conclusion drawing and verification.
My understandings were continually tested against the rest of the data and
verified or discarded. “The meanings emerging from the data have to be
tested for their plausibility, their sturdiness, their conformability—that is
their validity” (Miles & Huberman, 1994, p. 11). The conclusions presented
in this study were verified using alternative data sources. Each of the three
data sources was used to check the interpretations and conclusions. As a final
check of reliability and credibility, three researchers familiar with the Arizona charter school context and political environment reviewed the manuscript. All three confirmed the plausibility of the conclusions.
This research faced two important limitations. Although this case provides a detailed account of Arizona, time and expense prohibited a multistate
comparison. Accordingly, theoretical questions rather than a concern for representativeness drove the data collection process (Miles & Huberman, 1994).
A second limitation is the lack of interviews with consumers (i.e., parents and
students) to understand their perception of amount and quality of charter
school information. The ADE, the state sponsoring boards, and charter
school directors were unwilling to release identifying information of students enrolled in charter schools despite repeated requests.
AN ACCOUNTABILITY TYPOLOGY
Few people argue against increasing accountability in public education.
Consequently, proponents of the charter school reform (among others) frequently use accountability as an effective rallying cry. Although accountability is a term used extensively in the popular press and educational reform literature, it has multiple meanings. However, few people recognize the
complexity associated with this concept, and most use the term assuming that
it has a single accepted definition—their definition.
Browder (1975, as cited in Kirst, 1990) completed an extensive review of
the accountability literature and concluded:
1.
2.
There are no commonly agreed upon definitions. The range is from simply
holding someone responsible for doing something to highly detailed technical specifications.
As a concept, accountability needs refinement. Confusion abounds among
such terms as general accountability, institutional accountability, and technological accountability. There is no common framework to organize the vast
array of frameworks.
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3.
Accountability has become highly politicized. Various groups who can be
held accountable attack the concept and pounce on malfunctions in order to
discredit it. (p. 6)
The relevant literature is replete with discrete definitions of accountability
(see Darling-Hammond, 1988, 1989; Gintis, 1995; Glass, 1972; Hansen,
1993; Levin, 1974; Macpherson, 1996; Newmann, King, & Rigdon, 1997;
Richards, 1988). Each of these authors offers definitions of accountability
that differ in slight but meaningful ways. Accordingly, more precise accountability models have evolved. Levin (1974) identified four strands of accountability: (a) performance reporting, (b) technical process, (c) political process,
and (d) institutional process (p. 364). Kogan (1986, as cited in House, 1993)
presented three models of educational accountability: (a) state or public control, (b) professional control, and (c) consumer control (p. 35). Darling-Hammond (1988) articulated five forms of accountability: (a) political,
(b) legal, (c) bureaucratic, (d) professional, and (e) market (p. 61). Kirst
(1990) distinguished six types of educational accountability: (a) performance reporting, (b) monitoring and compliance with standards or regulations, (c) incentive systems, (d) reliance on the market, (e) changing the locus
of control, and (f) changing professional roles (pp. 7-10).
For this study, a typology including bureaucratic, performance, market,
and professional accountability models was created from the educational research literature. In turn, four types of accountability were deployed to analyze the Arizona charter school program.
1.
2.
3.
4.
Bureaucratic accountability is based on procedural compliance with established standards and regulations evaluated by local, state, or federal bureaucrats analyzing compliance reports and/or monitoring at the school site (see
Cuban, 1988; Darling-Hammond, 1988; Kirst, 1990).
Performance accountability is based on data from various indicators that may
be used to stimulate action, monitor compliance, and include rewards or sanctions (Levin, 1974; Rivera, 1994).
Market accountability is based on student/parental choice among schools.
Good schools demonstrate accountability by attracting students and maintaining enrollment. Bad schools are held accountable by parents who leave.
Market accountability is predicated on the assumption that consumers have
access to product information. Market accountability is measured by consumer participation and could be recognized through waiting lists or attendance records that indicate increases or decreases in student enrollment
(Chubb & Moe, 1988, 1990b; Darling-Hammond, 1988; Kirst, 1990).
Professional accountability is based on the demonstration of educators to
their peers that they have the appropriate knowledge, values, and skills to ensure competence and serve the public interest (Darling-Hammond, 1988;
Firestone & Bader, 1992; Rivera, 1994).
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Creating a System
Bureaucratic, performance, market, and professional accountability have
particular strengths and weaknesses in producing various outcomes. Kirst
(1990), Darling-Hammond (1989), and House (1993) theorized that various
models must be integrated into an accountability system to counteract the
limitations of each type. Kirp (1982) further argued that different forms of accountability were frequently in conflict with one another when present within
the same accountability system:
Professionalism, legalism, bureaucratization, and politicization pull and tug
against one another. . . . Problems arise when one or another framework becomes too powerful—for instance, when legalism engulfs in procedural snarls
questions that may either be unresolveable or better resolved less formally,
when professionals deprive parents of effective voice in decisions concerning
their children, or when bureaucratic rules undermine the exercise of wise professional discretion. Policy remedies take the form of redressing the balance
among these frameworks. (p. 173)
However, because the American public school system has historically relied
on bureaucratic accountability mechanisms, our lack of experience makes it
difficult to anticipate the interactions of professional, performance, and market mechanisms. Our knowledge of market mechanisms as they apply to education is especially weak and rooted more in economic theory than empirical
data. Boyd and Lugg (1998) provided a comprehensive analysis of the evidence that informs our understanding of market-based school choice programs. They argued, “Depending on how they are designed and regulated,
choice policies can either promote desirable reforms or cause serious problems” (p. 2). They went on to quote Glenn’s (1989) conclusions from an international analysis of school choice programs:
The experience of other nations yields no conclusive evidence that parent
choice has a decisive effect, either positive or negative, on the quality of schooling. Evidence is extensive, however, that choice may have either a positive or
negative effect upon equity, depending on how the process is structured and
what incentives are included for ethnic and class integration. (cited in Boyd &
Lugg, 1998, p. 2)
Yet policy makers are rarely impeded by a lack of compelling empirical evidence.
Although thoughtfully designed accountability frameworks ensure that
the various accountability mechanisms required of schools complement
rather than detract from each other, legislators often fail to map out the
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Educational Administration Quarterly
potential interactions of various accountability models. Frequently this is
viewed as a detail for implementers.
POLICY MAKING AS TRIAGE
In this case, formal implementers faced significant obstacles when attempting to design a coherent accountability system for charter schools. The
Arizona state legislature approved charter school legislation on June 17,
1994. During the 90 days before the statute took effect, the ADE was inundated by charter applications. Only 11 months after the legislation was approved, the first charter school began instructing children. Struggling to cope
with the time pressures and the large number of applicants, ADE staff developed a triage mentality—deal with the most critical problem first, and then go
on to the next most serious issue.
When the ink was not even dry on the legislation that allowed charter schools to
take place . . . there were people waiting with applications to have charter
schools. . . . It was many people. So they never had the opportunity to set these
systems up, and we haven’t had a breather to be able to do it. Wouldn’t it be
wonderful if we could just stop and use this year for planning and getting it all
together, and then start chartering again? But I don’t think that’s going to happen either. . . . It would be wonderful, but we’ll never have that luxury.2
In addition to planning on the fly, a personnel shortage created an additional obstacle. The charter statute assigned two state sponsoring boards, the
SBE and the SBCS, responsibilities for approval and oversight of charter
schools. Policy makers limited funding for administrators to staff both of the
state boards, in part to discourage a new bureaucracy from developing.
So, there are two things that happened in the legislation. . . . One, there was no
planning time for the Department to develop the program; and, two, there was
no appropriation tied to the bill for the legislation. And here I have people lining up saying, “I’m all ready to open up my charter school now.” What are you
3
going to do?
The lack of appropriations for administrators provided a significant challenge to both sponsoring boards when attempting to meet their approval and
oversight obligations. Overwhelmed with responsibilities and lacking staff,
the ADE personnel were compelled to share basic approval and oversight responsibilities with the sponsoring boards during the first application cycle
(without additional funding).
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However, the ADE was unable to offer consistent assistance to the state
sponsoring boards due to a concurrent downsizing. Elected superintendent of
public instruction in November 1994 (2 months after the charter legislation
went into effect), Lisa Graham-Keegan quickly followed through on her
pledge to cut the bureaucracy at the department of education. The year before
Keegan took office, the ADE had 460 full-time staff members; by 1996, she
had reduced that number to 231 (personal communication, ADE, payroll division, April 1998).
As I recall, one person and a secretary that first year were trying to handle all of
that, all of the application proceedings and getting them answered, getting
them to board members. . . . And I remember it was overwhelming. . . . And so
by early fall we were scrambling to get stuff in place and get the procedures together and get the applications written up and those kinds of things.4
While the ADE was taking on additional responsibilities for charter
schools, the reduction in staff stymied the development of a proactive policy
for charter school accountability. Consequently, contacts with charter schools
evolved based on addressing immediate problems, rather than anticipating
future ones. The executive director of the SBE, summarized the situation:
We have never been able to get out of the reaction stage, you know, we have
never been able to think. We never had time to think far enough ahead to what is
the next step that is going to come. . . . So every time we have been so involved
with a particular stage of development, that we have done no long-term planning or anticipating for what we have to do later.
Reactive planning, a lack of funding for administrative staff, and a concurrent
downsizing at the ADE combined to hinder the development of a
well-planned accountability system for charter schools by formal implementers.
FORMAL IMPLEMENTATION AGENCIES
However chaotic the birth of the Arizona charter school policy may seem,
the result was concordant with the spirit of the legislation: Charter schools
were accountable to parents and students, not bureaucrats. The following
three sections illustrate the difficulties faced by formal implementation agencies when moving toward a market-based accountability system. The experiences of the state sponsoring boards, the ADE, and the auditor general’s
office, all state agencies that were given statutory responsibilities in charter
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school accountability, were examined. Because of the contextual factors documented in the previous section, all three entities relied heavily on consumer
choice as the primary form of accountability.
State Sponsoring Boards
The charter statute endowed the SBE and the SBCS with general responsibilities for charter schools, including the power to approve new charter
schools, sanction existing charter schools for minor infractions, and revoke
the contract for poorly performing charter schools. Through 1998, the
state-level sponsoring boards relied on market accountability mechanisms,
by design and default.
The charter statute allowed the governor to appoint members to the SBCS.
Accordingly, Governor Fife J. Symington, a strong proponent of school
choice (he advocated voucher plans in the 1991-1994 legislative sessions)
selected seven individuals who strongly supported the idea of school choice.
Furthermore, all members of the SBE were appointed by pro school-choice
governors and were generally supportive of market accountability (Garn,
1999). By design, these board members focused on parental choice as the primary form of accountability.
Due to minimal staffing provisions (Bulkley, 1999), both state charter
school authorizing agencies focused their energies on approving new
schools, entrusting the monitoring responsibilities to parents. Internal documents, along with interviews of board members and administrative staff, confirmed that more time was devoted to the approval process than to any other
area. In contrast, once the charter school opened, school contact with the
sponsoring agency was nominal.
After the charter school was up and running, the SBE and the SBCS required charter schools to complete an annual written report detailing outcomes achieved and progress toward the goals specified in the charter contract. But there was no prescribed format for this report, and it was up to the
charter school operator to determine what information to include in this
self-evaluation.
Actually, by law they [charter school directors] are required to do that [submit
an annual written report to their sponsor]. They [the board members] don’t
evaluate it in any way. I think since this is the first year we have . . . asked for
that report. The report is basically there for the board to look at. . . . The [written] report is basically almost like the [oral] presentation where it’s information you want to tell us, but it also talks budgets and finances. . . . But we don’t
nail them with anything.5
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The information in the annual written report was neither evaluated nor verified for accuracy by administrative staff or board members. The SBCS required charter school operators to make an oral report to the board in addition
to the written report.
Part of it [oral presentation]—is this is the time to showcase your school. Get
up here and tell us good things that are going on at your school. It also allows us
to drop in questions. Some of them are softball questions that are just interesting, that we’d like to know. . . . For most schools, it’s the best time and for most
board members it’s the best time.6
In addition to the annual written and oral reports, an informal goal for the
administrative staff of both state boards was to visit the schools on a yearly
basis. The visits were unstructured, informal, and aimed at showing off the
successful aspects of the operation, much like the annual reports. During the
1997-1998 school year, the SBCS staff and board members followed through
with this unwritten policy; however, the SBE was unable to implement a similar plan as the school year ended.
Observations of the board meetings indicated that formal complaints filed
against a charter school were addressed in the oral presentation. Conversely,
the annual written reports and the site visits allowed the charter school directors broad discretion over the information they provided to the state sponsoring boards. Moreover, board members did not evaluate the information that
was provided in any systematic manner. A primary legislative intent of the
charter statute was to encourage consumer-driven accountability mechanisms. The two state sponsoring boards faithfully executed the spirit of the
legislation, but the lack of administrative staff reinforced the underlying philosophy that parental monitoring was favorable to bureaucratic monitoring.
In sum, parental choice proved to be the primary accountability tool
employed by the state sponsoring boards.
ADE
ADE staff reported that they had a great deal of difficulty attempting to
comply with the spirit of the charter school statute. The legislation explicitly
reduced the bureaucratic reporting requirements for charter schools by providing a blanket waiver from the rules and regulations by which district
schools must abide (ARS §15-183E5, 2000). This confounded ADE bureaucrats who attempted to devise accountability mechanisms in an environment
that discouraged bureaucratic monitoring and reporting.
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Educational Administration Quarterly
“State departments of education also have traditionally been involved in
overseeing the implementation of education policies and programs . . . often
[they] receive requests from legislative policy committees to conduct monitoring or evaluation studies” (Wohlstetter, 1991, p. 32). Because charter
schools were primarily accountable to the sponsoring boards and parents, the
ADE staff members reported that their primary function was to inform the
boards of achievements or problems in charter schools. The sponsoring
boards were then expected to reward or sanction charter schools appropriately. One attempt to identify the achievements and shortcomings of charter
schools was a monitoring program implemented during the 1996-1997
school year. A former associate superintendent at ADE discussed the motivation for the monitoring program:
We would hear horror stories or parents would call in with these unbelievable
tales of stuff, and nobody really knew what was happening, nobody knew if the
schools were delivering what they said they would. Were they complying with
their charter or not? Nobody really knew. There were some concerns on the part
of three or four of us that we just decided that somebody needs to be paying attention to this and somebody needs to be getting at least very basic information
so that if anybody wants to know, we can at least say, “Well, at least we have
done a minimal amount of checking and here’s what we found, here’s what we
know at this point.” Somebody needs to know what is going on out there.7
Two ADE staff members worked full-time on the monitoring project and
coordinated the effort.
We elicited support from about 50 people . . . in total. Most of the ADE, in various divisions, and some were external, either charter school people, or public
[district] school people, or University people, or whatever volunteered.
We did not do a programmatic audit in that we did not look at quality or the process of education, or the programs that they were actually implementing. What
we were monitoring were those things that have either legal or statutory compliance or charter compliance, meaning that they were doing things that either
weren’t in their charter, or they weren’t doing things that were in their charter.
So, we looked for the compliance in state and federal statutes.8
When the monitoring teams completed the site visit, all the artifacts collected during the visitation were stored in a file folder for each charter school.
Evaluators formally documented the site visits, either writing directly on the
monitoring instrument or separate notepads. As the ADE staff member
explained,
Garn / BUREAUCRATIC TO MARKET ACCOUNTABILITY
585
The plan was that the secretaries would be typing the reports and putting them
on file. . . . In the meantime, there were secretaries that left and came and went
and came and went. And the bottom line is that the reports, the majority of the
reports, unless they were the ones that were in severe trouble or that needed to
have records that were going to go to a hearing or whatever, then I personally
typed those . . . otherwise all the notes were left in file folders.9
In sum, only a fraction of the monitoring notes were typed up, the information from the reports was very rarely passed along, and neither the state sponsoring agencies nor the charter schools received meaningful information
about the monitoring visits. When eventually made public, most of the reports were still in the form of handwritten notes. The last page of the site visit
protocol included a summary sheet that allowed the monitoring team to summarize comments on charter and statutory compliance and to determine if a
follow-up was necessary. The summary sheets were blank or missing from 20
of the 32 monitoring visit reports analyzed for this study. Of the 12 that did
have comments in the summary area, 9 required follow-ups for noncompliance with either their charter or relevant statutes. It is important to note that
the state sponsoring boards never asked for or received that critical information.
After only 1 year, Superintendent of Public Instruction Graham-Keegan
discontinued the department’s involvement in the charter school monitoring
program. Both state boards attempted to take over the monitoring responsibilities in the 1997-1998 school year. With limited administrative staff and a
steadily increasing number of charter school sites (455 by 2000-2001 school
year), it remained unclear how monitoring by the state sponsoring boards
would be accomplished.
The monitoring effort by ADE was unique in that different divisions cooperated in the effort. Generally, divisions within the ADE developed independent strategies for dealing with charter schools. Two examples illustrate
the consequences. ARS §15-183E7 (2000) required charter schools to comply with all statutes relating to the education of children with disabilities in
the same manner as district schools. This compelled the Exceptional Student
Services staff members within the ADE to establish some oversight mechanisms to ensure compliance with federal and state laws. During the
1995-1996 school year, Exceptional Student Services staff members responded to specific complaints but lacked a systematic program to monitor
compliance among charter schools. The following school year an outreach
program was initiated and a sample of 25 charter and district schools were
monitored for compliance with special education rules and regulations.
Charter schools from the sample were subjected to a group evaluation
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whereby a team of staff members visited the charter school, evaluated the
program for disabled students, and provided technical assistance when it was
required. Exceptional Student Services staff documented their findings in a
Corrective Action Plan. However, interviews with Exceptional Student Services staff and the SBCS administrative staff confirmed that information
from the Corrective Action Plans was not forwarded to the state sponsoring
boards:
That information could be provided to us. . . . We have started asking for [reports] because that has not been the case. We wondered, “Why do you keep
this?” and “Where does it go?” So, we’ve said this could be a part of our monitoring. Special Ed[ucation] is a very important part of the charter. And these
people [Special Education consultants] are obviously overwhelmed with all
the schools they have to go to, but we need to know the information. If we don’t
know the information, how do we determine whether or not the school is in
compliance? I mean I’m sure if it was a real imperative issue they would come
to us, but we want to see the report.10
Academic Support Services, another division within the ADE, experienced problems similar to the Exceptional Student Services division. Staff in
the Academic Support Services division monitored charter schools that received federal funding for programs targeted to special needs students with a
high degree of at-risk factors, including financial deprivation and language
barriers. Federal programs within this unit included Indian Education, Early
Childhood Development, Titles I and VI, Bilingual Education, and the Dwight
D. Eisenhower program.
Numbers are checked against other departments within the Academic Support
Division. If lots of variance is identified then more extensive follow-up is done;
we contact the school immediately and sometimes go out into the school. We
can catch most of the problems with those checks. To the best of my knowledge, this information has not been passed on to the sponsor. I think in the future it will be a good idea to write a two-page letter to the sponsor and summarize our findings. (personal communication, ADE, Title VI administrative
staff, March 17, 1998)
Much like the Special Education monitoring visits, these schools were examined for procedural compliance. Similar to the Special Education staff,
Academic Support personnel reported that the information collected was not
sent to the state sponsoring boards. ADE personnel failed to create a functional system for collecting and transferring information to the state sponsoring boards. Accordingly, the de facto accountability mechanism was parental
Garn / BUREAUCRATIC TO MARKET ACCOUNTABILITY
587
choice. Nonetheless, board members and parents who were ultimately responsible for holding charter schools accountable were deprived of important information about charter school quality.
Auditor General
The auditor general’s office was the final state agency to play a formal role
in charter school accountability. Like the other state-level entities, the auditor
general’s office absorbed the additional responsibilities for charter schools
into its existing budget allocation. Unlike the department of education, this
office did establish a formal line of communication with the sponsoring agencies. However, policy actions of the SBCS and subsequent statutory amendments led to a decreased role for this agency.
When first conceived, ARS §15-183E6 (2000) required charter schools to
follow the same financial reporting system as district schools—the Uniform
System of Financial Records (USFR). This statute authorized the auditor
general to conduct financial, program, or compliance audits to ensure that
charter schools were following the USFR correctly. This statute formally
brought the auditor general into the accountability system for charter
schools. Subsequently, legislators amended ARS §15-183E6 (2000) and
allowed charter schools to follow a modified financial reporting system the
Uniform System of Financial Records for Charter Schools (USFRCS).
A 1997 amendment by the state legislature, known as the Single Audit
Act, placed an additional burden on staff at the auditor general’s office.
The governing board of a charter school is required to comply with the Single
Audit Act, plus [it] must contract for an annual financial and compliance audit,
with financial transactions subject to the Single Audit Act. . . . There was no
provision in the charter school statute for our office or CPAs [Certified Public
Accountants] to do audits. That was added later—[in] the [Single] Audit requirements.11
Before the Single Audit Act, most charter schools were covered by legislation that required all nonprofit organizations to conduct yearly audits.
For-profit charters were exempt from any external auditing requirements.
The Single Audit Act required all charter schools (including the for-profit
charter schools) that expend more than $300,000 to complete a Federal Compliance Audit as well as a Financial Statement Audit. These audits combined
were referred to as a Single Audit. Charter schools that did not exceed
$300,000 in expenditures were still required to complete the Financial Statement Audit; however, they were exempt from the Federal Compliance Audit.
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Auditor general’s office staffers analyzed the results of the audit opinion
rather than performing the formal audit. After the director of a charter school
selected a CPA firm and the contract was approved, ARS §15-271D (2000)
required the auditor general to inform any charter school failing to meet the
requirements, as prescribed by the USFRCS, that it had 90 days to correct the
deficiencies. For the auditor general to make such a determination, external
auditors completed a USFRCS compliance questionnaire along with a legal
compliance questionnaire. When the audit was completed, the auditor general’s office performed a working-paper review of the audit to check the quality of the CPA’s work as well as to ensure that the charter school was financially sound. If the independent examination identified problems, the charter
school operator received a letter from the auditor general explaining the specific requirements and placing the 90-day deadline to resolve any deficiencies. A copy of the letter was also sent to the sponsoring board. After 90 days,
staff from the auditor general’s office followed up to make sure that the necessary corrections had been completed and documented their findings in a
second letter that informed the charter school and the sponsoring board of the
charter school’s compliance status.
The mechanisms developed by the auditor general’s office exemplified
performance accountability. Auditors reviewed data from financial and compliance audits that were then used by sponsoring agencies to stimulate action.
The executive director of the SBE described the process:
They [auditor general’s office] send us [the school’s sponsor] a letter that says
they have found a school to be not in compliance with the USFRCS and . . . the
state board determines that they are not in compliance with the USFRCS and
they must request a hearing before the board. And if they don’t request a hearing, the superintendent [of public instruction] is allowed to withhold their
funds. So 100% of the time people will request a hearing. . . . So, we pretty
much assume there is compliance unless we hear contrary to that. And that is
the same with district schools.12
In other words, financial indicators stimulated action. Depending on the
progress made toward addressing the problems, the sponsoring board could
grant an extension or withhold funds. However, it is important to note that the
state sponsoring board, not the auditor general’s office, had enforcement
power over the charter schools.
In the 1997-1998 school year, the SBCS granted 22 charter schools waivers from the USFRCS. The charter school legislation was specific that the
auditor general was required to notify charter school staff if they did not comply with the USFRCS. If the charter school did not have to follow the
Garn / BUREAUCRATIC TO MARKET ACCOUNTABILITY
589
USFRCS accounting form, the auditor general lost jurisdiction, and the
SBCS assumed responsibility for financial oversight. In a special summer
session, legislators made the waiver from the USFRCS permanent and once
again amended the financial requirements prescribing that “on or after July 7,
1999, a state sponsored charter school’s compliance with the USFRCS will
be determined by its sponsor” (Haggerty & Sauv, 1999).
Whether the administrative staff for the sponsoring boards had the training or the board members had the time or expertise to monitor the financial
health of charter schools was unclear. It was apparent, however, that they did
not have the same level of skills as the professionals who routinely performed
this kind of work in the auditor general’s office.
Whether it was a lack of will or capacity or combination of both, formal
implementors from the auditor general’s office, department of education, and
sponsoring agencies failed to design and implement a multifaceted accountability system for charter schools. The following section applies the theoretical framework to analyze the specific forms of accountability in the policy.
ACCOUNTABILITY TYPOLOGY
When devising an accountability system, Kirst (1990), House (1993), and
Kirp (1982) all warn policy makers to compensate for the weaknesses of individual accountability types by balancing among the frameworks in a
proactive accountability policy. This case reveals that Arizona policy makers
relied predominantly on market mechanisms and minimized the use of professional, bureaucratic, and performance mechanisms.
Professional Accountability
The Arizona charter school policy disregarded professional accountability. There were no procedures to ensure competence through teacher or charter school accreditation. The Arizona charter school legislation did not
require charter school teachers to have state certification, a degree in education from an accredited school, or even a college degree. Policy makers purposely wrote this provision into the charter school legislation to encourage
individuals with nontraditional backgrounds to become involved with these
schools. Legislators argued that certification requirements discouraged individuals with a background outside of education from teaching. Therefore,
professional accountability mechanisms did not play a significant role in the
accountability system created for Arizona charter schools.
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Bureaucratic Accountability
Policy makers were clear about their disdain for bureaucratic accountability mechanisms and attempted to limit the role of this model in the accountability framework. Lisa Graham-Keegan, an articulate supporter of the charter reform who left her position as chair of the House Education Committee
to become superintendent of Public Instruction, commented: “I hope this will
begin to demonstrate you don’t need all the bureaucratic overlay we now have
in public schools. . . . What they [charter schools] are getting is freedom from
regulation in return for greater accountability” (Mattern, 1994, p. A1). Divisions within the ADE attempted to monitor compliance with standards for
special education, financial reporting, and federally funded programs. However, they were unable to develop and implement bureaucratic accountability
mechanisms that effectively transferred information to the state sponsoring
boards. The SBE and the SBCS had statutory authority to level punishments
for noncompliance with rules and regulations. Yet without staff to carry out
this task and with board members who disfavored bureaucratic accountability, market accountability mechanisms became the default instrument for
charter school evaluation. “How do we know [if they are in compliance]? By
parents calling and saying that they are doing something that they’re not supposed to do, because we have no staff to go out.”13 A former SBE and SBCS
board member confirmed the lack of bureaucratic accountability mechanisms implemented by the two state sponsoring agencies:
As I recall it [the annual report] is kind of like a self-report deal. I don’t know
that there is a prescribed format, and so they are going to report what they want
you to hear. . . . So right now the only evaluation that is happening is their own
self-reporting through report cards, and through their annual report to the
board.14
The auditor general’s office also lacked the will and capacity to institute
bureaucratic accountability mechanisms. Accordingly, policy makers were
able to limit most of the bureaucratic rules and regulations for charter schools
that traditional district public schools must endure.
Performance Accountability
Performance accountability was present but underutilized in the accountability framework devised for Arizona charter schools. The auditor general’s
office was the only government agency that was able to implement effective
performance mechanisms. Reviewing data from independent financial auditors allowed this office to get a more accurate understanding of the financial
Garn / BUREAUCRATIC TO MARKET ACCOUNTABILITY
591
stability of a given school. However, exemptions granted by the SBCS and
subsequent statutory amendments limited the use of performance accountability significantly.
Test scores, however fallible (see Shepard, 1991), were one source of
information about school performance that was available. Parents and sponsoring board members could get some insight into charter school quality
based on standardized test scores. However, changes in testing policy
reduced the usefulness of test scores. Arizona first administered the Iowa Test
of Basic Skills in 1995-1996, but switched to the Stanford Nine during the
2nd year of the charter reform. This change in testing policy disrupted the
collection of trend data and rendered impossible the assessment of school
improvement or decline.
A final potential source of performance information about charter schools
was a school report card required of all public schools. The report cards were
supposed to include information about a broad array of school performance
indicators. However, because the report cards were overwhelmingly incomplete, they were only useful as a sound bite for policy makers rather than for a
parent trying to evaluate charter school performance. Many public schools
(charter and district) failed to fully complete and return the report card data
because there were no sanctions or rewards attached to this request. In addition, the incomplete report card information was available through the ADE
web site (Nowicki, 1998). This posed a vital problem for a large percentage
of parents who did not have access to the Internet. Consequently, performance reporting was evolving slowly and was more symbolic than practical
in the first several years of the Arizona charter school program.
Market Accountability
It’s [the charter reform] been one of those things that I think we had a pretty
clear idea of what kind of principles we wanted it based on, and particularly
what kind of accountability we wanted for schools. . . . And we were astonishingly successful.15
Market accountability mechanisms were the foremost model in the accountability system for Arizona charter schools. Creating a framework with
limited bureaucratic oversight, few (if any) professional standards, and
slowly evolving performance reporting standards ensured that consumers
were the most important component in the accountability system for charter
schools. If parents enrolled their children, this was a clear indication of satisfied consumers. Conversely, if enrollment declined, parents were holding
charter schools accountable for their dissatisfaction with the educational
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product produced by the school. Senator John Huppenthal, a leading advocate for the charter school reform, stated,
Well, I mean right now it’s basically 100% of the equation. You know, there’s
different kinds of accountability—there’s product quality and there’s financial
accountability. So, on the financial accountability, the parents play no role.
Some parents are on boards that play a little bit of role. But they play 100% of
the role in determining on the academic side, the cognitive development, and
the affective development, parents are 100% of the equation right now; but
with zero percent on the financial side.16
An interview with the superintendent of public instruction confirmed that
the monitoring responsibilities for parents of children enrolled in charter
schools were greater than their counterparts with children enrolled in district
schools:
The reality is that parents need to know about the risk factors, and know that
they are putting their students into start-up businesses. Maybe parental monitoring is more reliable than the district monitoring system that is currently in
place, nobody ever thinks about it that way. As a parent, you can’t relax anywhere, either in the district or the charter schools. But there is definitely a
higher degree of risk with the charters because they are essentially start-up
businesses, and parents need to acknowledge that risk. Parents need to know
who is running the school and the philosophy and is it fiscally sound. What the
standards are, and they should just pull out the state standards and see how they
have added on. They need to go directly to the school and meet people. They
can’t just read this on the report card piece of paper. Parents need to ask a lot of
questions.17
Data from multiple sources confirm that parental choice was the principal accountability mechanism. However, by marginalizing all other forms of accountability, parents and students selected schools with imperfect information.
CONCLUSIONS
This case study was structured by three research questions: (a) How did
state agencies cope with the Arizona charter school reform? (b) What types
of accountability were present in the charter school system? and (c) What
were the implications of the market-based accountability system for consumers? This case illustrated that personnel at the SBE, SBCS, ADE, and auditor
general’s office found it problematical to adapt to the changes required by the
charter school legislation. The state sponsoring boards focused their limited
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593
resources on approving new schools; however, monitoring charter schools
that were serving students was a responsibility deferred to parents and other
state agencies. Personnel at the ADE had a difficult time attempting to comply with the intent of the charter statute because bureaucratic monitoring was
discouraged. Bureaucrats working at that agency did not have the resources
to collect and distribute information about charter schools to consumers.
Despite a lack of funding and personnel, staff at the attorney general’s office
were able to deal with the new demands imposed by the charter school legislation. Personnel in that agency developed financial auditing procedures and
passed that information on to the sponsoring boards.
This case also demonstrated that market accountability was the leading
paradigm in the Arizona charter school program. Data from interviews, observations, and document analysis confirmed that by limiting oversight from
bureaucrats in state agencies, requiring minimal professional requirements,
and failing to develop uniform and comprehensive performance reporting
mechanisms, policy makers caused market mechanisms to become the primary accountability model. However, even the staunchest charter school advocates, including the chairman of the Senate education committee, Senator
John Huppenthal, recognized the information problem:
To make that purchase decision something that means something, they have to
have maximum information, so the things that I focused on that we don’t have
yet are academic productivity and quality ratings and, to a lesser extent, student
quality ratings and teacher job satisfaction. If you know those things, I think
you know a tremendous amount about the quality of the school. Right now, we
don’t have any of that data. So right now, in terms of any kind of data that’s
available on schools, almost all of the data that we have now in my mind is
worthless, so right now we have no way of keeping score. None of the methods
right now, none of the data we have right now coming in has a whole lot of value
for someone making a purchase decision.18
The implications for consumers who participate in a market-based accountability system are important to consider.
IMPLICATIONS
Thoughtful critics and advocates of educational choice programs emphasize the importance of reliable product information. Levin (1997) contends
that “in order to make informed choices, parents need information on alternatives” (p. 14). Chubb and Moe (1990a) would “require” consumers to visit a
“Parent Information Center” to assist in the selection of a school (p. 10). The
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case of Arizona charter schools reveals that trustworthy performance information is not an intrinsic element of a consumer-driven educational system.
Policy makers must develop policies that ensure consumers have access to
accurate information about schools. Performance-reporting requirements
would complement market-based (or bureaucratic) accountability mechanisms. However, collecting and distributing the productivity, satisfaction,
and quality information to consumers without increasing bureaucratic
reporting requirements for charter school directors remains an oxymoronic
objective.
Although key political leaders in Arizona agreed that consumers of choice
schools assumed more responsibility (for selecting and monitoring schools),
they failed to implement a mechanism for capturing and distributing uniform
and dependable performance data that would encourage more informed consumer choices. School report cards, required of all public schools in Arizona,
were intended to address this information problem; however, they were
wholly inadequate. During the boundaries of this case (1994-1998), compliance with the report card mandate was sporadic. Accordingly, the implications for consumers selecting among schools in a choice program revolve
around three issues: the breadth, accuracy, and accessibility of school
information.
It is important that consumers are able to consider a wide range of information about choice schools. In the form of report cards, Arizona charter and
district schools were expected to provide information on several broad areas
including school organization, philosophy, and academic goals. In addition,
report cards solicited information about the number of school days, average
daily instruction time, school honors, instructional programs offered, standardized test scores, grades served, enrollment, school site council composition and duties, school and parent responsibilities, staff information (i.e.,
number of administrators, teachers, and teacher aides), transportation policy,
resources available at the school site, school safety, food programs, attendance rate, mobility rate, retention rate, and dropout rate. Policy makers
might consider expanding the report cards to include information on faculty
and staff certification and experience, school accreditation, the school’s governance structure, admissions policy, discipline policy, curricular focus, testing policy, after-school activities, and utilization of technology to further aid
consumer choice. In sum, there was no single reliable measure of school performance or quality. Thus, providing consumers with information about
many aspects of the charter schools allows them the opportunity to better
evaluate the educational product produced at one school compared to others.
With a broad scope of information, individuals may select different criteria
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for comparing school quality. This in turn allows consumers to select the
school that best fits their needs and interests.
Ensuring accuracy is a second prerequisite of performance reporting to
consider. Simply relying on self-report data may be inadequate when parents
are making such a critical choice. Akerlof (1970), in a seminal article on the
quality and uncertainty associated with the theory of markets, argued that
sellers have little incentive to offer accurate or expanded information about
their product. Using the automobile market as an example, he stated:
There are many markets in which buyers use some market statistic to judge the
quality of prospective purchases. . . . There is an incentive for sellers to market
poor quality merchandise, since the returns for good quality accrue mainly to
the entire group whose statistic is affected rather than the individual seller. As a
result there tends to be a reduction in the average quality of goods and also in
the size of the market. It should also be perceived that in these markets social
and private returns differ, and therefore, in some cases, governmental intervention may increase the welfare of all parties. (p. 488)
Akerlof (1970) also reasoned that the effects of quality uncertainty can be reversed by guarantees, brand names, or licensing practices—“one natural result . . . is that the risk is borne by the seller rather than by the buyer” (p. 499).
In the absence of guarantees, parents and students assumed full risk when selecting among Arizona charter schools. To minimize this risk, limited government intervention may be warranted in the Arizona charter school program.
There are several options for increasing the quality of information about
Arizona charter schools. First, staff at the aforementioned state agencies
could shift roles and audit or review externally audited information about
choice schools, much like the role taken by the auditor general’s office with
regard to financial reporting requirements. In line with market ideology, one
could also expect to see private individuals or groups providing report card
compliance support to charter schools. If school officials were unwilling to
spend time collecting and reporting the information, they could subcontract
with external groups to fulfill these requirements. These information accountants would collect and organize information about school performance.
Finally, the issue of accessibility to the school performance information
must be considered. Simply posting the report card information on the state
department of education web site is insufficient. Consumers without access
to the Internet are severely disadvantaged. Mailing school performance
information to interested parents from the state department of education or
other information clearinghouses would be a logical first step. Additionally,
allowing parents to acquire standardized and reliable information when
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visiting a school (district or charter), utilizing public libraries and other public facilities to distribute information, and other outreach steps could be taken
to promote more equity in information accessibility.
If consumers are expected to reward good schools by enrolling and sanction bad schools by leaving, they must have quality performance information
to make such decisions. To minimize the risk for parents and students who
participate in the charter school program, Arizona policy makers may have a
compelling reason to implement a performance reporting system that ensures
consumers have access to broad and accurate information about charter and
district public schools. For example, a consumer buying a car or selecting a
school would receive more accurate safety, quality, and performance data
from an independent evaluator than from a salesperson or enrollment officer.
Without access to information about school performance that is valid, reliable, and wide ranging, consumers will use whatever information is available
when selecting a school. A radio or television commercial, a slick marketing
brochure, or a conversation with a friend may be enough to buy a car, but can
we afford to settle for the same standard when selecting a school? In the case
of Arizona charter schools, thousands of educational consumers selected
charter schools with limited safety, quality, and performance information.
NOTES
1. Recorded interview with Tom Patterson, Phoenix, AZ (March 16, 1998).
2. Recorded interview with Arizona Department of Education administrative staff, Phoenix, AZ (February 27, 1998).
3. Recorded interview with the executive director, State Board of Education, Phoenix, AZ
(February 27, 1998).
4. Recorded interview with the former associate superintendent, Arizona Department of
Education, Tempe, AZ (May 12, 1998).
5. Recorded interview with State Board for Charter Schools administrative staff, Phoenix,
AZ (March 11, 1998).
6. Recorded interview with the former executive director, State Board for Charter Schools,
Phoenix, AZ (March 9, 1998).
7. Recorded interview with the former associate superintendent, Arizona Department of
Education, Tempe, AZ (May 12, 1998).
8. Recorded interview with Arizona Department of Education administrative staff, Phoenix, AZ (March 11, 1998).
9. Recorded interview with Arizona Department of Education administrative staff, Phoenix, AZ (March 11, 1998).
10. Recorded interview with the State Board for Charter Schools administrative staff, Phoenix, AZ (March 11, 1998).
11. Recorded interview with auditor general’s office staff, Phoenix, AZ (February 11, 1998).
Garn / BUREAUCRATIC TO MARKET ACCOUNTABILITY
597
12. Recorded interview with the executive director of the State Board of Education, Phoenix,
AZ (February 27, 1998).
13. Recorded interview State Board of Education administrative staff, Phoenix, AZ (February 27, 1998).
14. Recorded interview with the former State Board of Education and State Board for Charter Schools board member, Tempe, AZ (May 12, 1998).
15. Recorded interview with Senator Tom Patterson, Phoenix, AZ (March 16, 1998).
16. Recorded interview with Senator John Huppenthal, Phoenix, AZ (March 23, 1998).
17. Recorded interview with Lisa Graham Keegan (April 21, 1998).
18. Recorded interview with Senator John Huppenthal, Phoenix, AZ (March 23, 1998).
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