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Policy

Public Comments & Testimony

Public Comments & Testimony

Advocates for Children of New York (AFC) has our finger on the pulse of important education issues and education policy trends that affect children in New York City and New York State. We are on the forefront of pushing to improve education policy, so that all children have access to a quality education.

Below are AFC’s most recent public comments and testimonies. Please see our archive for comments and testimonies from 2012-2020.

Note: The following resources are in PDF format and will open in a new window. To view PDF files, download the following free software: Get Adobe® Reader®.

2023

AFC Testifies at City Council Hearing on Immigrant Students, November 29, 2023
AFC testified before the New York City Council Committee on Education and Committee on Immigration to discuss newcomer immigrant students in New York City public schools, and highlight concerns and recommendations based on our work on the ground providing assistance to many newcomer immigrant families in shelter on education-related issues.

AFC Testifies on Intro. 0003-2022, October 25, 2023
AFC testified before the New York City Council Committees on Education and Public Safety in support of Int. No. 0003-2022, which would regulate the NYPD’s response to students in emotional crisis within public schools.

AFC Writes to Mayor Adams Regarding Planned Education Budget Cuts, October 16, 2023
AFC sent a letter to Mayor Adams emphasizing, in advance of education budget cuts being planned for November, that the City’s obligation to uphold students’ legal rights remains unchanged. As the budget process moves forward, the City must ensure that its choices do not impede its ability to uphold students’ rights and comply with federal and state law, including special education law.

AFC Testifies on Intro. 542, October 13, 2023
AFC testified before the New York City Council Committee on Education, Committee on General Welfare, and the Committee on Criminal Justice regarding educational p rogramming in detention facilities and Intro 542, which requires DOE, ACS and DOC to report on educational programming for students in court-ordered settings.

AFC Submits Comments on IDEA Part B, October 13, 2023
AFC submitted comments to the U.S. Department of Education on New York State’s compliance with respect to transition planning for students with disabilities. 

AFC Joins 150+ Organizations Calling on Elected Leaders to Save Key Education Programs, September 21, 2023
More than 150 organizations called on elected leaders to sustain critical education programs currently supported by temporary federal COVID-19 stimulus funding set to run dry in June 2024.

AFC Testifies on Intro. 941, September 21, 2023
AFC testified before the New York City Council Committee on Women and Gender Equity regarding Int. No. 941-2023, and the importance of early childhood education and care in New York City.

AFC Submits Comments on Proposed Amendments to Chancellor’s Regulation A-412, August 24,2023
AFC submitted comments on the proposed amendments to Chancellor’s Regulation A-412 (CR A-412) to better protect students from unnecessary and traumatizing police involvement, and provide clear guidance to school staff and School Safety Division (SSD)/NYPD officers to promote safe, respectful, and supportive learning environments for students.

AFC Submits Comments on Proposed Amendments to Section 200.5, August 14,2023
AFC submitted com
ments regarding the New York State Education Department (NYSED) proposal to amend section 200.5 of the Regulations of the Commissioner regarding extensions in special education due process hearings and related procedures. 

AFC Testifies on Intro. 0857 and 0121, June 21, 2023
AFC testified before the New York City Council Committee on Education in support of Intro. 857, to expand the NYC Department of Education’s data reporting requirements to include metrics on students in foster care, and Intro. 121, to require the DOE to report annually on therapeutic crisis intervention training in schools.

AFC Testifies on Promise NYC and Access to Child Care for Immigrants, June 13, 2023
AFC testified before the New York City Council Committee on Immigration and Committee on Women and Gender Equity regarding early childhood education, calling on the City to extend funding for Promise NYC in the Fiscal Year 2024 budget.

AFC Joins 16 Organization to Oppose the Amended Version of the Solutions Not Suspensions Bill, June 8, 2023
AFC joined 16 organizations to call on lawmakers to oppose the amended version of S.1040-A. The proposed bill fails to make necessary changes to current law to reduce the disparate impact of punitive school discipline policies upon students of color. 

AFC Testifies on the FY24 Executive Budget, May 24, 2023
AFC testified before the New York City Council Committee on Finance about the importance of rejecting proposed cuts to the education budget and investing to meet the needs of students. 

AFC Testifies on Discipline and Suspension Policies, May 12, 2023
AFC testified before the New York State Senate Committees on Education and New York City Education in strong support of the Judith Kaye Solutions Not Suspensions (SNS) Act (A. 5691/S. 1040).

AFC Submits Comments on Proposed Changes on Special Education Hearings, May 8, 2023
AFC submitted comments to NYSED on proposed changes to the state regulations on special education impartial hearings.

AFC Submits Written Testimony on Intro No. 868, March 29, 2023
AFC submitted written testimony to the City Council Committe on Education regarding Intro No. 868, which would require the Department of Education (DOE) to report on the number of students attending District 75 schools and the criteria used to determine the location of District 75 schools. 

AFC Testifies on the FY24 Preliminary Budget, March 24, 2023
AFC testified before the City Council Committee on Mental Health, Disabilities and Addiction and the Committee on Health on the need for school-based social-emotional, behavioral, and mental health services, and for extending funding for the Mental Health Continuum, which will expire in June. 

AFC Testifies on the FY24 Preliminary Education Budget, March 15, 2023
AFC testified before the City Council Committee on Education regarding the FY 24 preliminary budget, urging the City to extend funding for education initiatives left out of the preliminary budget and invest in initiatives to support the students with the greatest needs.

AFC Testifies on Early Childhood Education Programs, March 13, 2023
AFC testified before New York City Council Committee Hearing on General Welfare Preliminary FY24 Budget, regarding the need to extend funding for Promise NYC, a crucial initiative that increases access to early childhood programs for children who are undocumented. Without action by the City, funding for this initiave will expire in June, leaving hundreds of children at risk of being turned away from their program.

AFC Testifies on Early Intervention, February 28, 2023
AFC testified before the Joint Legislative Public Hearing on the 2023-2024 Executive Budget Health Proposal regarding the need for a rate increase for Early Intervention (EI) in the 2023-2024 budget. The Executive Budget proposal does not include any increase or cost-of-living adjustment for EI providers, whose rates today are lower than they were 20 years ago, or take any other steps to help address the State’s systemic failure to provide young children with timely access to their legally mandated EI services.

AFC Testifies on Early Childhood Education, February 15, 2023
AFC testified before the New York City Council Committee on Education on access to early childhood education programs, including for children with disabilities, children in temporary housing, and children who are undocumented. The City is currently relying on $88 million in federal COVID-19 stimulus funding this year to fund preschool special education initiatives—funding that will be expiring in the fall of 2024 and needs to be sustained.

AFC Testifies on the 2023-2024 State Education Budget Proposal, February 8, 2023
AFC testified at the New York State Joint Legislative Hearing on the 2023-2024 Elementary and Secondary Education Budget proposal, supporting the historic increase in Foundation Aid and urging legislators to work with the Governor to modify the budget proposal including by increasing funding for preschool special education programs, support for English Language Learners, and school-based behavioral and mental health supports.

AFC Testifies on DOE’s New Admissions Processes and Establishing a Bullying Prevention Task Force, January 25, 2023
AFC testified before the New York City Council on Education regarding barriers to admissions for students from historically marginalized communities, and supporting the creation of a bullying prevention task force by strengthening Int. 0338-2022 to add parents and students with lived experience of bullying as required members of the task force and paid stipends for their time.

2022

AFC Testifies on Needed Support for Migrant Students and Families, December 20, 2022
AFC testified before the New York City Council about the need to better support immigrant students and families amidst the recent influx of migrant families, including by increasing access to bilingual staff and programs, ensuring students get needed special education services, bolstering Transfer High School programs for older immigrant youth, and improving language access and communication with families.

AFC Testifies on NYC School Bus Transportation Services, November 21, 2022
AFC testified before the New York City Council Committee on Oversight and Investigation and the Committee on Education regarding persistent, long-standing issues with NYC school bus transportation services.

AFC Submits Comments to Proposed Early Intervention Program Regulations, November 18, 2022
AFC submitted comments in response to the proposed changes to the New York State Early Intervention Program regulations, and concerns about proposed amendments that do not comport with legal requirements and would be harmful to children and families.

AFC Testifies on the DOE’s COVID-19 Relief Spending, November 16, 2022
AFC testified before the New York City Council Committee on Education about the need for the DOE to address delays in launching key programs funded by federal COVID-19 relief funds and for city, state, and federal elected leaders to begin planning to sustain long-overdue initiatives funded with this short-term funding.

AFC Testifies on Accessing Mental Health Services for NYC Youth, November 9, 2022
AFC testified before the New York City Council Committee on Mental Health, Disabilities & Addiction and Committee on Youth Services to discuss the youth mental health crisis and urgent need for a comprehensive system to ensure that our young people have access to and receive behavioral and mental health supports in schools.

AFC Submits Testimony on the DOE’s Federal COVID-19 Relief Spending, November 7, 2022
AFC submitted testimony to the New York City Council Committee on Oversight and Investigations and Committee on Finance regarding the DOE’s COVID-19 relief spending, asking the DOE to address delays in spending for important supports for students and urging city, state, and federal elected leaders to begin planning to sustain long-overdue initiatives funded by COVID-19 funding.

AFC Testifies on Summer Rising/Summer Youth Employment ProgramOctober 25, 2022
AFC testified before the City Council Committee on Youth Services about the need to ensure that the City’s summer programming provides needed support for all students, including students with disabilities, English Language Learners, and students who are homeless.

AFC Testifies on Early Childhood Programs, October 19, 2022
AFC testified before the City Council Committee on Education regarding our concern about the 800 preschoolers with significant disabilities who were waiting for seats in their legally mandated preschool special education classes as of June 2022.

AFC Testifies on Meeting the Needs of All Students with Disabilities, September 21, 2022
AFC testified before the City Council Committee on Education about the serious obstacles that students with disabilities and their families continue to experience every day on the ground. 

The ARISE Coalition Testifies on Meeting the Needs of All Students with Disabilities, September 21, 2022
The ARISE Coalition (which is coordianated by AFC) testified before the City Council Committee on Education about persistent problems with special education services and the treatment families encounter when they advocate for their students’ rights, and shared recommendations around: special education service delivery; special education recovery services; and the provision of appropriate literacy supports for all students, including those with dyslexia and other struggling readers.

AFC Testifies on School Budget Cuts, August 22, 2022
AFC testified before the City Council Committee on Education about the impact of the school budget cuts, calling on the City to restore funding for school budgets and also continue key investments targeted to students with the greatest needs.

AFC Submits Comments on Section 504, August 22, 2022
AFC submitted comments to the U.S. Department of Education’s Office for Civil Rights recommending changes to the federal regulations implementing Section 504 of the Rehabilitation Act.

AFC Submits Comments on Home Instruction, July 28, 2022
AFC submitted comments to the State Education Department supporting changes to regulations to increase the minimum number of hours of home instruction and establish a new process for requesting home instruction, as well as suggesting further changes.

AFC Testifies on FY23 DOE School Budget CutsJune 24, 2022
AFC testified before the City Council Committee on Education and Committee on Oversight and Investigations regarding our deep concerns about school budget cuts.

AFC Submit Comments on the Disability Classification “Emotional Disturbance”, May 31, 2022
AFC submitted comments in response to the New York State Education Department’s proposed amendments to sections 200.1 and 200.4 of the Regulations of the Commissioner of Education relating to the disability classification “Emotional Disturbance.”

AFC Testifies on FY23 Executive BudgetMay 25, 2022
AFC testified before the City Council Committee on Finance regarding the FY 23 Executive Budget, urging the City to invest in targeted initiatives to support English Language Learners, students with disabilities, students who are homeless or in foster care, and students with mental health needs.

The ARISE Coalition Testifies on FY23 Education BudgetMay 25, 2022
The ARISE Coalition (which is coordinated by AFC) testified before the City Council Committee on Education regarding the FY 23 education budget, urging the City to ensure the allocation of COVID-19 relief funding intended to support students with disabilities, and provide pay parity for preschool special education teachers at community-based organizations.

AFC Testifies on the Educational Needs of Students in Foster CareApril 20, 2022
AFC testified before the City Council Committee on Education regarding the educational needs of students in foster care.  We are urging the City to fully staff a small DOE team focused on students in foster care and guarantee bus service so students don’t have to transfer schools when placed in foster care. 

AFC Testifies on FY23 Preliminary Education BudgetMarch 21, 2022
AFC testified before the City Council Committee on Education regarding the FY 23 preliminary budget, urging the City to reject proposed cuts to education, including the DOE hiring freeze, and invest in initiatives to support the students with the greatest needs.

The ARISE Coalition Testifies on FY23 Preliminary Education BudgetMarch 21, 2022
The ARISE Coalition (which is coordinated by AFC) testified before the City Council Committee on Education regarding the FY 23 preliminary budget, urging the City to invest in supports and interventions for students with disabilities, including literacy education, recovery services, and salary parity for preschool special education teachers.

AFC Testifies on FY23 Preliminary Education BudgetMarch 21, 2022
AFC testified before the City Council Committee on Hospitals' regarding the FY 23 preliminary budget, urging the City to invest in a comprehensive system to ensure students have access to behavioral and mental health supports in schools. 

AFC Testifies on Mental and Behavioral Health Supports for StudentsMarch 9, 2022
AFC testified before the City Council Committee on Mental Health, Disabilities and Addiction and the Committee on Health on the need to invest in a comprehensive, integrated system of mental health and behavioral health supports for students.

AFC Testifies on Summer 2022 Programming Readiness, March 4, 2022
AFC testified before the City Council Committee on Youth Services about the need to ensure the City’s summer programming provides the support needed to truly serve all students.

The ARISE Coalition Testifies on Summer 2022 Programming Readiness, March 4, 2022
The ARISE Coalition (which is coordinated by AFC) testified before the City Council Committee on Youth Services about the need to ensure the City’s summer programming provides the support needed to truly serve all students, including students with disabilities.

AFC Testifies on the Impact of COVID-19 on English Language Learners, February 28, 2022
AFC testified before the City Council Committee on Education on the need to better support English Language Learners and immigrant students and families.

AFC Testifies on Plans to Address New York City's Mental Health Crisis, February 25, 2022
AFC testified before the New York City Council Committee on Mental Health, Disabilities and Addiction on the youth mental health crisis and the urgent need for a comprehensive system to ensure that our young people have access to and receive behavioral and mental health supports in schools.

AFC Testifies on 2022-2023 State Budget Proposal, February 8, 2022
AFC submitted testimony for the New York State Joint Legislative Public Hearing on the 2022-2023 Executive Budget Health Proposal urging the State to increase payment rates for Early Intervention (EI) providers to help more infants and toddlers receive timely evaluations and services.

2021

AFC Joins 100+ Organizations to Urge Governor Hochul to Sign A8013 / S6515-A, November 30, 2021
AFC joined more than 100 organizations in sending a letter urging Governor Hochul to sign into law A. 8013 (Benedetto) / S. 6516-A (Mannion), a bill passed unanimously by the Senate and Assembly to ensure that preschool special education programs, as well as state-approved non-public schools for school-age students with significant disabilities, receive the same increase in payment rates as school districts.

AFC Testifies on Meeting the Needs of Students with Disabilities in the COVID Era, November 18, 2021
AFC testified before the City Council Committee on Education on meeting the needs of students with disabilities during the COVID era, including the need to for a non-adversarial system for providing make-up services.

AFC Submits Comments to NYSED on NYC's Impartial Hearing Office, November 5, 2021
AFC submitted comments to the New York State Education Department about the need for urgent action to address systemic delays and barriers in the special education impartial hearing system in New York City.

AFC Submits Written Testimony in Support of Intro 1829-2019, October 27, 2021
AFC submitted written testimony to the City Council Committee on General Welfare in strong support of Intro. 1829-2019, which would preclude the Department of Homeless Services from requiring parents to bring their children to shelter intake appointments and help ensure students do not have to miss school when their families apply for shelter.

AFC Testifies on Academic Recovery Plan, October 27, 2021
AFC testified before the City Council Committee on Education on the continued work needed to strengthen the DOE’s academic recovery plans this year. 

The ARISE Coalition Testifies on Academic Recovery Plan, October 27, 2021
The ARISE Coalition (which is coordinated by AFC) testified before the City Council Committee on Education on concerns over the plan's rollout of the recovery services for students with disabilities, as well as literacy supports.

AFC Testifies on the DOE's Use of Foundation Aid and Federal COVID-19 Relief Funding, October 5, 2021
AFC testified before the New York State Senate Education Committee on the DOE’s use of increased state and federal education funding; specifically, how the funding is being used to meet the needs of students with disabilities, English Language Learners, and students experiencing homelessness. 

AFC Testifies on Reducing the Responsibilities of the NYPD, September 27, 2021
AFC testified before the City Council Committee on Public Safety, joining the call from students, parents, and educators for police-free schools and urging the City to eliminate the reliance on the New York City Police Department to address the needs of students in our schools.

AFC Testifies on School Reopening Protocols and Mental Health Supports, September 1, 2021
AFC testified before the City Council Committee on Education on the City's plan to hire 250 new School Safety Agents (“SSAs”), rather than invest in the social-emotional and mental health supports our students so profoundly need. 

AFC Joins 100+ Organizations to Urge Governor Cuomo to Sign A8013 / S6515-A, August 8, 2021
AFC joined more than 100 organizations in sending a letter urging the Governor to sign into law A. 8013 (Benedetto) / S. 6516-A (Mannion), a bill passed unanimously by the Senate and Assembly to ensure that preschool special education programs, as well as state-approved non-public schools for school-age students with significant disabilities, receive the same increase in payment rates as school districts.

AFC Comments on Proposed Amendments to Chancellor's Regulations, July 28, 2021
AFC submitted comments on the DOE’s proposed changes to the Chancellor’s Regulation about Section 504 accommodations for students with disabilities.

AFC Comments on Nondiscriminatory Administration of School Discipline, July 23, 2021
AFC submitted public comments to the U.S. Department of Education on the exclusionary, punitive school discipline and police policies and practices faced by New York City public school students, the disproportionate impact these policies and practices have on Black and Brown students and students with disabilities, and promising alternative practices.

AFC Joins Organizations Urging DOE to Hire Shelter-Based Community Coordinators, June 25,2021
AFC joined 25 organizations calling on the DOE to hire 150 shelter-based Community Coordinators to help students living in shelter reconnect with school and participate in supplemental programming.

90+ Organizations Call on Mayor de Blasio to Meet the Need for Preschool Special Education Classes, June 23, 2021
AFC joined 90+ organizations to call on Mayor de Blasio to address the shortage of preschool special education classes and provide salary parity to teachers of preschool special education classes at community-based organizations (CBOs) this year.

AFC Joins Sign-On Letter Calling on DOE to Invest in Supports for Students in Foster Care, June 2, 2021
AFC joined 35 child welfare and education organizations calling on the DOE to invest in support for students in foster care, with a DOE office focused full-time on students in foster care and guaranteed school bus transportation for students in foster care. 

AFC Testifies on the New York City FY 2022 Executive Budget, May 25, 2021
AFC testified before the City Council Committee on Finance on the Executive Budget, outlining our priorities for the historic influx of education funding from the state and federal governments.

The ARISE Coalition Testifies on the New York City FY 2022 Executive Budget, May 25, 2021
The ARISE Coalition (which is coordinated by AFC) testified before the City Council Committee on Finance on the Executive Budget, outlining our priorities for the historic influx of education funding from the state and federal governments.

AFC Testifies on Educational Programming in Jails and Juvenile Detention, April 26, 2021
AFC submitted written testimony for the City Council Committees on Education, General Welfare, and Criminal Justice in support of Intro. No. 1224, and provided recommendations to ensure equity, transparency, monitoring, and accountability of education provided to children and youth in court-ordered settings.

AFC Testifies on Youth in Shelter and the School System, April 16, 2021
AFC testified before the City Council Committees on Education and General Welfare about the importance of having an intentional, targeted plan to support students in shelter as the City decides how to use its historic influx of education funding.

100 Organizations Urge Mayor de Blasio to Meet the Need for Preschool Special Education Classes, March 23, 2021
AFC joined more than 100 organizations in a letter to Mayor de Blasio emphasizing that 3-K and Pre-K will never be “for all” until the City addresses the continuing shortage of seats in preschool special education classes.

AFC Testifies on the New York City FY 2022 Preliminary Education Budget, March 23, 2021
AFC testified before the City Council Committee on Education on the preliminary budget, outlining our priorities for an ambitious education initiative to direct the largest one-time federal investment in education in our nation’s history.

The ARISE Coalition Testifies on the New York City FY 2022 Preliminary Education Budget, March 23, 2021
The ARISE Coalition (which is coordinated by AFC) testified before the City Council Committee on Education on the need for compensatory services and increased literacy supports as part of the FY 22 budget to help address the needs of students with disabilities.

AFC Testifies on the NYC Police Reform & Reinvention Collaborative Draft Plan, March 16, 2021
AFC testified before the Public Safety Committee at a hearing on the Mayor’s New York City Police Reform and Reinvention Collaborative Draft Plan and the FY 2022 Preliminary Budget.

AFC Submits Comments on Proposed Changes to Chancellor's Regulation A-701, March 5, 2021
AFC submitted comments on proposed changes to Chancellor’s Regulation A-701 regarding school health services.

AFC Testifies on 2021-2022 State Budget Proposal, February 25, 2021
AFC 
submitted testimony for the New York State Joint Legislative Public Hearing on the 2021-2022 Executive Budget Health Proposal urging the Legislature to reject proposals to cut state funding for the Early Intervention (EI) program by limiting the services children can receive and, instead, invest more in EI by asking private health insurance companies to pay their fair share.

AFC Testifies on Proposed School Safety Bill Package, February 18, 2021
AFC testified before the New York City Council Committee on Education in support of proposed legislation regulating the New York City Police Department’s response to students in emotional crisis within public schools, significantly limiting the use of handcuffs on students in emotional crisis.

AFC Testifies on the 2021-2022 State Education Budget Proposal, January 28, 2021
AFC testified at the New York State Joint Legislative Hearing on the 2021-2022 Elementary and Secondary Education Budget proposal, urging legislators to increase, and not cut, state education funding and ensure schools can use their full COVID-19 relief funding to reopen schools and help students catch up.

The ARISE Coalition Testifies on the Impact of COVID-19 on Student Learning and Academic Achievement, January 20, 2021
The ARISE Coalition (which is coordinated by AFC) testified before the City Council Committee on Education about the impact of COVID-19 on learning for students with disabilities.

AFC Testifies on the Impact of COVID-19 on Student Learning and Academic Achievement, January 20, 2021
AFC testified before the City Council Committee on Education about the impact of COVID-19 on student learning, outlining essential principles and critical elements that must be included in a comprehensive COVID-19 education recovery effort.

AFC Submits Comments Regarding Proposed Joint ACS-DOE Policy, January 15, 2021
AFC submitted comments to the draft ACS-DOE joint policy on the reporting and investigating of educational neglect.

Sign-On Letter Regarding Vacant Positions in the Office of Students in Temporary Housing, January 11, 2021
AFC joined more than 30 organizations in calling on the DOE to fill the more than 20 currently vacant positions dedicated to supporting students who are homeless.