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Policy & Initiatives

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 2012-2016.

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®.

2018

AFC Comments on Graduation Participation for Students with Disabilities Receiving Non-Diploma Credentials, December 3, 2018
AFC submitted public comment to the New York State Education Department on a proposed amendment to the regulation about the right of students with disabilities receiving SACC and CDOS credentials to participate in graduation ceremonies and activities. We urged NYSED to require schools to inform families that these students have the right to stay in school through age 21 or until they earn a diploma, regardless of their participation in graduation activities.

AFC Testifies on Busing for Students with Disabilities, November 29, 2018
AFC testified before the New York City Council Committees on Education, Sanitation and Solid Waste Management, and Transportation about the experiences of students with disabilities on school buses during the recent snowstorm and the importance of passing legislation to provide parents with access to real-time GPS data for their children’s school buses.

AFC Testifies on Reentry Programs for Formerly Incarcerated Youth, November 13, 2018
AFC testified before the New York City Council Committees on Juvenile Justice and Youth Services on the educational reentry programming needs of New York City’s formerly incarcerated youth.

AFC Calls for Busing for Students in Foster Care, November 2, 2018
Advocates for Children, along with more than 30 other organizations, sent a letter to Mayor Bill de Blasio calling on him to provide busing for kindergarten through sixth grade students in foster care. For students who have been separated from their families, school has the potential to be an important stabilizing factor in their life, but the City currently guarantees bus service only to students in foster care who receive special education transportation.

AFC Testifies on Mental Health in Schools, October 23, 2018
AFC testified before the New York State Assembly Standing Committee on Education regarding the current state of health, mental health, and physical education programs, services, and instruction in New York State’s schools.

AFC Testifies on School Transportation, October 16, 2018
AFC testified before the City Council Committee on Education about the importance of improving the school transportation system, especially for students with disabilities, students in foster care, and students in temporary housing, and in support of a bill to provide real-time GPS bus location data to parents.  

AFC Writes Chancellor Carranza Regarding Busing Problems, September 27, 2018
AFC sent a letter to Chancellor Carranza regarding start-of-school problems with busing. The letter shared a number of cases that are illustrative of what families, especially families of students with disabilities, routinely experience. 

AFC Testifies on School Emergency Preparedness and Safety, September 20, 2018
AFC testified before the New York City Council Committee on Public Safety and Committee on Education regarding a proposal to establish a school emergency preparedness task force and a resolution calling for one guidance counselor and social worker for every 250 students and at least one guidance counselor and social worker per school.

The ARISE Coalition Calls for Increased Funding for School Accessibility, September 12, 2018
The ARISE Coalition (which is coordinated by AFC) and Parents for Inclusive Education (PIE) sent a letter to Mayor Bill de Blasio asking that the City include a major investment in the FY 2020-2024 School Construction Authority Five-Year Capital Plan to make at least one-third of schools accessible to students, parents, and teachers with physical disabilities.

AFC Comments on State Early Intervention Program Regulations, August 31, 2018
AFC submitted comments in response to the New York State Department of Health’s proposed changes to the state Early Intervention Program regulations.

AFC Submits Comments on the Implementation of New York’s Approved ESSA Plan, August 17, 2018
Advocates for Children of New York submitted comments to the New York State Education Department on proposed amendments to the regulations regarding New York’s Every Student Succeeds Act (ESSA) accountability system. Our comments discuss the proposed definition of “out-of-school suspension rate” as well as the State's method for calculating chronic absenteeism.

AFC Submits Comments on Proposed Amendments to Regulations about the Dignity for All Students Act, July 21, 2018
AFC submitted comments to the New York State Education Department in support of proposed amendments to regulations about the Dignity for All Students Act (DASA). 

AFC Testifies on Early Childhood Education Programs, June 27, 2018
AFC testified before the City Council Committee on Education and Committee on General Welfare about how 3-K, Pre-K, and EarlyLearn can better serve students who are homeless, Dual Language Learners, and students with disabilities. Read our client’s testimony about how her four-year-old son has been waiting months for a seat in a preschool special education class due to the DOE’s shortage.

AFC Testifies on the Fiscal Year 2019 Executive Budget, May 24, 2018
AFC testified before the City Council Committee on Finance on the importance of increasing funding for several education priorities, including school social workers for students living in shelter, school accessibility for students with physical disabilities, and evidence-based practices to improve school climate.

AFC Testifies on Preventing and Addressing Bullying, April 26, 2018
AFC testified before the New York City Council Committee on Youth Services regarding a proposal to establish an anti-bullying hotline and an anti-bullying mobile device application. AFC urges the City to invest in building positive, inclusive school climates by implementing anti-bullying training and funding whole-school evidence-based approaches.

AFC Comments on School Accessibility, April 25, 2018
AFC spoke before the DOE’s Panel for Educational Policy about the need to increase funding to make more schools accessible to students, families, and teachers with physical disabilities.

AFC Testifies on NYC's Support for Immigrant Parents of Children Ages 0-5, April 24, 2018
AFC testified before the City Council Immigration Committee about the importance of addressing barriers that immigrant families face in accessing preschool special education evaluations and other early childhood education programs. 

AFC Comments on Child Care Programs, April 18, 2018
AFC submitted comments to the New York City Board of Health on proposed regulations regarding child care, with a focus on children who are homeless and children with developmental delays or disabilities.

AFC Testifies on the School Building Challenge, April 18, 2018
AFC testified before the City Council Committees on Education, Finance, and Land Use about the need to increase resources to make more NYC schools accessible to students, families, and staff with physical disabilities.

AFC Testifies on the Preliminary FY19 Expense Budget, March 23, 2018
AFC Testifies on the Preliminary FY19 Capital Budget, March 26, 2018
AFC testified before the New York City Council Committee on Education regarding the Fiscal Year 2019 Preliminary Budget, calling for increased funding for support for students in temporary housing, busing for students in foster care, school climate initiatives, and improving school accessibility.

AFC Testifies on the Continuum of NYC’s Juvenile Justice System, February 28, 2018
AFC testified before the New York City Council Committee on Juvenile Justice on the educational needs of New York City’s court-involved youth while in juvenile detention and placement, and after their release from these settings.

AFC Testifies on Community and Renewal Schools, February 27, 2018
AFC testified before the City Council Committee on Education at a hearing on community schools, renewal schools, and a special education reporting bill.

AFC Comments on Proposed Changes to Chancellor’s Regulation A-101, February 13, 2018
AFC submitted comments on the DOE’s proposed changes to Chancellor’s Regulation A-101 regarding school transfers, admissions, and enrollment.

AFC Submits Testimony on Early Intervention, February 12, 2018
AFC submitted testimony for the New York State Joint Legislative Public Hearing on the 2018-2019 Health Budget proposal, urging legislators to increase the reimbursement rate for Early Intervention providers and to reject a budget proposal to restructure the Early Intervention screening and evaluation process.

AFC Testifies on the New York State Executive Budget Proposal, January 31, 2018
AFC testified at the New York State Joint Legislative Public Hearing on the 2018-2019 Elementary and Secondary Education Budget proposal, urging legislators to increase investments in education initiatives such as positive approaches to discipline, prekindergarten, and support for English Language Learners and to reject harmful special education proposals. 

2017

AFC Testifies on Diversity in New York City Schools, December 7, 2017
AFC testified before the New York City Council Committee on Education on diversity and inclusion in City schools.

AFC Testifies on School Safety and Efforts to Improve School Climate, November 21, 2017
AFC testified before the New York City Council Committee on Public Safety regarding the NYPD's role in school discipline and matters of mental health. We are calling for a realignment of City resources to reflect the critical need to appropriately support students’ social-emotional needs and address the striking racial disparities in police interventions.

AFC Testifies on Preventing and Addressing Bullying, October 30, 2017
AFC testified before the City Council Education Committee offering several recommendations to prevent and address bullying behavior, including expanding whole-school trainings that improve school climate, better utilizing existing data, better utilizing Field Support Center personnel, increasing awareness of anti-bullying resources, and improving reporting.

AFC Submits Testimony on School Infrastructure and Facilities, October 19, 2017
AFC submitted written testimony to the New York State Assembly Committee on Education about the need to increase the number of accessible school options for students, teachers, and family members with mobility, hearing, and vision needs.

AFC Testifies on Support for Students in Temporary Housing, October 11, 2017
AFC testified before the City Council Committee on Education and Committee on General Welfare about support for students who are homeless.  We are calling on the City to ensure there is high-level leadership on this issue, expand the number of DOE social workers for these students, and devote additional resources to address the significant challenges faced by the rising number of students who are homeless.

AFC Comments on Federal Civil Rights Regulations, September 19, 2017
AFC submitted comments to the United States Department of Education urging the Department to maintain regulations and non-regulatory guidance that delineate protections for students, especially students who have historically been marginalized or discriminated against.

AFC Testifies on Gender Sexuality Alliances, September 14, 2017
AFC testified before the City Council Education Committee in support of Gender Sexuality Alliances (GSAs) in schools and recommending that every school post the contact information for its Respect For All Liaison on the school's website.

AFC Comments on Early Intervention Program Regulations, August 27, 2017
AFC submitted comments in response to the New York State Department of Health’s proposed changes to the state Early Intervention Program regulations.

AFC Comments on Charter School Teacher Certification, August 24, 2017
AFC submitted comments on SUNY’s proposed regulations regarding charter school teacher certification. While we believe there is important work to be done across the State to strengthen teacher certification pathways, address shortages of qualified teachers in certain areas, and ensure there is an excellent teacher in every classroom, we are concerned that the proposed regulations would run counter to these goals and would violate state law.

AFC Comments on Civil Rights Data Collection, August 21, 2017
AFC submitted comments urging the U.S. Department of Education to maintain the current Civil Rights Data Collection (CRDC) by preserving the existing questions, requiring all schools and districts to report the data, and continuing to make the CRDC accessible to the public.

AFC Comments on Child Care for Children Living in Shelters, July 25, 2017
AFC testified before the New York City Board of Health on proposed regulations regarding child care programs in homeless shelters.  

AFC Comments on the Extension of Mayoral Control, June 19, 2017
AFC sent a letter to the New York State Assembly and Senate, urging them to approve a long-term extension of mayoral control as a stand-alone bill that is not tied to other changes in education policy.

AFC Comments on School Planning and Overcrowding, June 15, 2017
AFC submitted public comments to the City Council Working Group on School Planning, Siting, and Overcrowding, urging the Council to consider the needs of students with disabilities, as well as students, families, and school staff members who need accessible school buildings. 

AFC Comments on New York State's Draft ESSA Plan, June 14, 2017
AFC submitted public comments to the New York State Education Department on the State's draft Every Student Succeeds Act (ESSA) plan.

AFC Testifies on the Fiscal Year 2018 Executive Budget for New York City, May 25, 2017
AFC testified about the Fiscal Year 2018 city budget proposal, urging the Administration and City Council to increase funding for DOE social workers for students living in homeless shelters, Restorative Practices and other alternatives to school suspensions, and school accessibility.

AFC Testifies on the DOE's Policies Related to Interactions with Federal Immigration Authorities, April 26, 2017
AFC testified before the New York City Council Committees on Immigration, Public Safety, and Education, urging the DOE to issue guidance to address the collection of sensitive immigration information and to address the very likely situation of immigrant parents being picked up by ICE during the day, while their children are at school. 

AFC Testifies on the 2017-18 Preliminary Budget for New York City, March 21, 2017
AFC testified before the New York City Council Committee on Education on the fiscal year 2018 Preliminary Budget. We urge the Administration to include increased funding for DOE social workers for students living in homeless shelters. In addition, we request that the budget include additional resources to expand restorative practices and pilot a mental health support continuum in 20 high-needs schools. 

AFC Submits Testimony on Policing in Schools, March 20, 2017
AFC submitted testimony to the New York Advisory Committee to the U.S. Commission on Civil Rights on the policies and practices of the New York City Police Department (NYPD). Our testimony focuses on how arrests, summonses, and handcuffing of students in New York City disproportionately impacts students who are Black or who have disabilities and makes recommendations to address these significant issues.

AFC Testifies on the Impact of Immigration Enforcement on Students and Families in NYC Schools, March 15, 2017
AFC testified before the New York City Council Committee on Immigration regarding the city’s plans for addressing federal immigration authorities’ requests for access to school buildings and student records.

AFC Testifies on the Preliminary Capital Education Budget, March 8, 2017
AFC testified before the New York City Council Committees on Education and Finance regarding the need for the City to invest increased funding to make additional schools accessible for students, families, and teachers with accessibility needs.

AFC Testifies on School Planning and Siting for New Capacity, February 28, 2017
AFC testified before the New York City Council Committees on Education and Finance in support of proposed legislation that would require the Department of Education to report information on school applications, offers of admission, enrollment, and school seats available. Our testimony urges the Council to ensure there are accessible school options across the City for students, teachers, and family members with mobility, hearing, and vision needs.

AFC Testifies on the 2017-18 State Education Budget Proposal, February 14, 2017
AFC testified at the New York State Joint Legislative Public Hearing on the 2017-18 Elementary and Secondary Education Budget proposal, urging legislators to invest in education initiatives such as improved access to Career and Technical Education (CTE) programs for students with disabilities and English Language Learners, the development of performance-based assessments, positive approaches to discipline, and prekindergarten.

AFC Submits Testimony on Child Care Funding, February 8, 2017
AFC submitted testimony for the New York State Joint Legislative Public Hearing on the 2017-18 Human Services Budget proposal, urging legislators to increase investments in child care so that more children from low-income backgrounds can access early childhood education programs.

AFC Testifies on the Draft NYC Discipline Code, January 25, 2017
AFC testified before the NYC Department of Education Office of Safety and Youth Development on the draft citywide discipline code, urging the DOE to continue to reform our school disciplinary system to help students stay in school and reduce the disproportionately high rates of suspension experienced by black students and students with disabilities.

AFC Submits Comments Regarding Proposed Amendments to Chancellor’s Regulation A-101, January 13, 2017
AFC submitted comments regarding the DOE’s proposed changes to Chancellor’s Regulation A-101, including changes to school selection and enrollment for students in foster care and students in temporary housing.