What are STMA’s values?
Answer: Placing students front and center. When the school district works with parents or families we do our best to focus on what is best for students and placing students first. At STMA, we are committed to educating the whole students, with excellence in academics and activities. In a school district with significant limitations to state funding comparative to other districts, we have to make choices about the allocation of our district’s resources to maximize opportunities for students.
What is an Independent Provider Activity?
Answer: An independent provider activity (IPA) is an individual, group, or organization that provides an opportunity for school district students to participate in an extracurricular activity or event that is not otherwise offered or sponsored by the school district. The pathway to become an IPA is identified in District Policy 626 located here https://docs.google.com/document/d/1q9DR68W3-RKGfbOnkitYKePQwnhHT07GHf_0EamTHP4/edit (last visited 06-11-24).
Policy purpose of independent provider activities
Answer: The school district recognizes extracurricular activities can supplement learning and character growth of students. Further, the school district recognizes there are situations that can occur where, although there is demonstrated student interest in an activity or event, it is not possible or appropriate for the school district to sponsor or fund the activity due to staffing, facilities, budget, or other similar limitations. All such independent provider activities must otherwise meet the standards, mission, purpose, and policies of the school district.
What is the application process and timeline?
Answer: The application process requires district administration to conduct basic due diligence about an Independent Provider Activity (IPA) to determine whether the activity is appropriate for a school district, will follow district policies and expectations, and will not result in litigation or expense against the school district which takes away resources that the district can invest in students and the classroom. As a result, there are quite a few questions and the administration must be able to verify a sustainable level of student participation (generally a pattern of 3 years or more) before it can recommend an IPA for school board adoption. The application itself is a starting point, as each UPA will have distinct characteristics unique to the IPA that will require further inquiry. Administration reserves the right to establish an annual timeline for board approval. This is stated in District Policy 626 and typically the district would seek board approval of an IPA over the summer and moving into a school year.
What are the eligibility criteria outlined in District Policy 626?
Answer:
- There must be an educational component and public competition involved in the activity or event to qualify as a program under this policy. All members of the activity or event must be full-time students in grades 7-12 in the school district. The activity will be allowed to use the high school official logo, nickname, and school colors in competitions;
- The independent provider will provide to the district, through the Director of Activities, a certificate of liability insurance to provide for the safety of the student participants, naming the district as an additional insured party. District administration may set up additional coverage requirements as necessary;
- The independent provider must comply with the District’s background check policies. Any decisions on background checks, including which individuals are subject to a background check, is at the discretion of the Director of Administrative Services or Superintendent. The district will not cover the costs and any related incidental expenses to the background checks;
- All costs for the independent provider will be provided by the independent provider and/or participants. With availability and following district facility use policies, the independent provider may use district facilities for practices and/or games/contests at the discretion of the Director of Activities or Superintendent;
- Accessibility of the activity to all students;
- A verifiable record of participation suggesting the program and student participation is likely sustainable;
- No other school sponsored activity or event can provide a similar educational opportunity or experience;
- Extension of programming or opportunities to students who are not otherwise participating in other school sponsored activities or events;
- Financial implications to the District and/or student participants is not prohibitive and/or includes a plan for increasing accessibility due to financial limitations;
- Does not otherwise interfere with other legal obligations of the school district including, but not limited to, laws pertaining to public accommodation and Title IX; or
- Willingness and compliance with school district policies and significant administrative considerations.
No one criteria is typically determinative of a decision to adopt an IPA, but all of these criteria must be addressed in the application process.
What is the role of administration in this process?
Answer: Pursuant to district policy 626 and the expectations of the school board, district administration works collaboratively and is responsible for vetting an application to become an IPA eventually determining whether or not to provide a recommendation to the school board. We do this work on behalf of the school board so that board members have all of the information necessary to make a decision.
Is an Independent Provider Activity (IPA) a pathway if I want a small group of students to get a letter?
Answer: No. This process is for activities that want to provide an opportunity for students for the foreseeable future. Typically, such organizations are structured as a 501(c)3 and involve activity organizations that have been established for some period of time with sustainable participation numbers. This pathway has created terrific opportunities for student participants in trap shooting and bowling and the district is proud to be affiliated with these activities and to have students represent the district at competitive events and competitions.
What about just providing a letter to a student who is doing a worthy activity?
Answer: This may be a new and good idea and something the district is looking into in the near future. There are some administrative concerns about identifying a consistent way of awarding a letter and how to establish criteria that maintain the meaningfulness of a school letter, but the district recognizes expanding student opportunities and recognition is important and would need to adopt this by district policy.
How are district policies created or changed?
Answer: At STMA, the school board has appointed a Policy Review Committee that works as a group to vet all district policies on a regular basis and carefully consider the adoption by policy of new ideas. This committee is composed of students, parents, community members, school board members, teachers and administrators. Typically, all new policies move through this committee process unless adoption is time sensitive by law or otherwise recommended by administration.
What about Title IX?
Answer: Title IX is an important federal law that is very broad and encompasses a wide range of potential student conduct and policies including the accessibility of opportunities to all students, regardless of gender. Compliance with this policy is a fact specific inquiry that incorporates the application of multiple legal criteria depending on the context of the issue or institution. No one or singular activity or program determines compliance with Title IX, but the school district is responsible for vetting a program to ensure it can represent information to different stakeholders depending on the legal question presented. Title IX law is outlined in District Policy 522 and ls located here: https://docs.google.com/document/d/10F6gs8RciBUeSAHSReQaPEW8Eu9ApuLOzFziJPcdZ7o/edit (last visited 06-11-2024).
Regulatory guidance for Title IX requirements for K-12 educational institutions may be revised and updated by the applicable federal agency.
What other policies or laws are important for a school district when considering adopting an Independent Provider Activity?
Another important policy is District Policy 102, Equal Educational Opportunity, which is scheduled for adoption of amendments at its June 17th meeting including the language listed below.
See- https://docs.google.com/document/d/1ay7kpzoVCY493Cgz4zNyNRH2WG0dlmNomaF4xKhuSos/edit (last visited June 11, 2024)
The school district shall provide equal opportunity for members of each sex and to members of all races and ethnicities to participate in its athletic programs. In determining whether equal opportunity to participate in athletic programs is available for the purposes of this law, at least the following factors shall be considered to the extent that they are applicable to a given situation: whether the opportunity for males and females to participate in the athletic program reflects the demonstrated interest in athletics of the males and females in the student body of the educational institution; whether the opportunity for members of all races and ethnicities to participate in the athletic program reflects the demonstrated interest in athletics of members of all races and ethnicities in the student body of the educational institution; whether the variety and selection of sports and levels of competition effectively accommodate the demonstrated interests of members of each sex; whether the variety and selection of sports and levels of competition effectively accommodate the demonstrated interests of members of all races and ethnicities; the provision of equipment and supplies; scheduling of games and practice times; assignment of coaches; provision of locker rooms; practice and competitive facilities; and the provision of necessary funds for teams of one sex.
What expectation does the district have for applicants of Independent Provider Activities?
Answer: The district, and its administration team, is here to serve all of our stakeholders, especially students and parents. We work collaboratively with IPA coaches and parents to try to assist them in providing the necessary information in the context so that the school board has all of the necessary information to make a determination as to whether to adopt an IPA. It is a process. The IPA process is not designed for every situation nor is it designed to simply award students, who may otherwise be worthy or accomplished in a given sport or activity, a letter. STMA has a strong history of seeing great success with IPA programs, but not all programs will fit the criteria for an IPA. Throughout the process, applicants have to be willing and able to work cooperatively with administration as district resources must be spent on all matters impacting students and taxpayers. The district has enjoyed great student success with coaches and parents who have provided IPA leadership and worked with the district.