Compliance!
Generally speaking, I think socialist strategy around school finance should be revenue + accountability. Poor districts need provisions but they need to spend well. To that end, focusing on Philadelphia, I've been exploring non-reformist revenue policies and sniffing around the school district's castle--440 Broad Street--to understand why the district apparatus is the way it is.
Part of the accountability push, to me at least, requires understanding who's responsible for what so our targets and demands can be well-informed. That's why I've been looking up different offices and departments in SDP's administration. When I do this, I want to know two things. (1) what the state apparatus looks like (what are the positions in it and how do they relate to one another) and (2) who has state power in the apparatus (who are the people holding these positions, where do they come from, what's their story, etc.)
After a conversation with a reader who was a former administrator at 440 Broad, I got interested in the Office of Grant Compliance and Fiscal Services (OGCFS) because he said it's a crucial chokepoint for getting things done in the apparatus. I must have touched a nerve since district officials emailed me unsolicited to ask about my thread! Here's what I learned.
FUGGin Vogons?
When you get money from the government that you don't have to pay back, you need to make sure it's spent on what it's intended, by law, to be spent on. To make sure that this is happening, school districts have to prove they're complying with all the rules. How does the government know if a district is compliant? Forms. Grant compliance forms.
And that's what the OCFS does: "Sustain & increase District funding, promote management accountability, & ensure compliance with rules and regulations, the OGCFS supports best practices, facilitates grant financial reporting, and independently monitors all grant activity."
Looking at all the forms and matrices the office provides, I thought pretty quickly (and maybe uncharitably) of the Vogons. They're a species in A Hitchhiker's Guide to the Galaxy known for their obsession with paperwork. I counted 138 forms people are in charge of administering at OGCFS. Reading the complex six-page matrix for who administers which of these forms under what conditions is intimidating.
From what I can tell, this largely covers federal grants. There's an extensive document called the Federal Uniform Grant Guidance (FUGG) out of the Office of Management and Budget, which comes along with guidelines from Pennsylvania's Department of Education since federal money is disbursed to states, who then disburse to districts. This would mean that the OGCFS is a bunch of FUGGin Vogons.
Afraid of the audit?
Just stepping back for a moment, this all feels a little strange. The OGCFS has a staff of 54 people and oversees compliance for $400 million. I know this because the head of the office, Joe D'Alessandro (on whom more below) reports as much in his LinkedIn. But that's a very small percentage of the total district budget, which is around $3.4 billion. That's about 10%. Why do we need 54 people to oversee a tenth of the budget?
One reason might be a big audit the federal government did of SDP in 2010. They found that the district was...not in compliance.
We determined that PSD did not have adequate fiscal controls in place to account for the Federal grant funds that were expended during the audit period. We also found that expenditures, totaling $138,376,068, 2 from grant funds were either unallowable or inadequately supported.
SDP ultimately had to give back $10.5 million, not a huge amount but also not an insignificant sum for Philly. But the fear and loathing resulting from this audit compounds with every dollar found to be out of compliance, I imagine, so a bitter taste was left. That's when they called up Joe D'Alessandro.
Not that D'Alessandro
Joseph D'Alessandro spent the first half of his career in Illinois, serving that state government in some fiscal capacity from 1989-2003. Starting at the Governor's budget office, he spent the most time as the Chief Fiscal Officer of the state agriculture department, 1997-2003. In 2003, he started as a budget analyst in Philadelphia. I don't know why he made the move exactly, since as CFO at Illinois's Dept. of Agriculture he oversaw 600 employees. One clue is that Paul Vallas, the former CEO of Chicago Public Schools, was appointed superintendent in Philly the year before. I haven't found an explicit connection between the two men, but it's easy to imagine Vallas got a recommendation and brought D'Alessandro in.
D'Alessandro is apparently not related to the similarly named and well-regarded hoagie shop in Roxborough, Philadelphia.
This non-hoagie D'Alessandro rose to the top position in Philly Schools grant compliance in 2012, a couple years after that big audit. He's been at 440 Broad for 18 years now and I can't find that much about him. I have a few things I can report, one of which is public record and looks a little funny and the others are just stuff I've heard, positive and negative.
BruMan Group?
In the contact info section of his LinkedIn, D'Alessandro lists a website called Bruman.com. This link sends you to a private law firm called Bruman & Manasevit, PLLC. The firm calls itself the BruMan Group. They're very interesting. Based in DC, they're lawyers who work on education grant funding issues. They've got offices all over the country and a pretty big list of lawyers working for them. BruMan Group weirdly sounds like Blue Man Group. They def have an ear for puns. Just look at one of the senior partner's 2016 powerpoint on ESSA, the law that decentralized No Child Left Behind. He titled it "ESSA 'Bout Time!" Good one, Leigh.
BruMan does stuff like sue the Department of Education to release records relating to programs, policies, and other protocols, like these cases from 2013 and 2017. They also work with state and local educational institutions on all kinds of funding stuff.
There are two connections I found between D'Alessandro and BruMan Group. The first is a presentation he gave last year at a "Fall Forum" on how to manage federal grants in the pandemic. He was on the CARES Funding Implementation Panel. Then, in the 2020 list of SDP's expenditures, there are payments to BruMan totaling $14,365.39. I imagine the district paid them for legal services, probably getting advice on how to manage all the new federal grants coming in like ARPA, CARES, etc.
My question is: why would he list BruMan as his contact info website rather than the SDP? He's obviously proud of his affiliation with the firm. Seems odd, but also maybe nothing. This gets us to the stuff I've heard about him
Hmmmm
Indeed, this is why a district office emailed me: to assure me that BruMan is a top national law firm dealing with grant compliance and that D'Alessandro's presentation is nothing other than the result of his prowess in this arena. An official tells me that D'Alessandro was actually recognized nationally for his work on this topic in the wake of the audit in 2019. This is a positive piece of hearsay. I can't find that national recognition.
Further, I'm told that D'Alessandro was able to use an esoteric clause in the law to retrieve about half of the money taken by the audit--the only time that's ever been done. I can't find evidence of this, but it's sounds cool and maybe passed under people's radars.
The negative stuff comes from other people who've worked in the district. I've seen tweets reporting that his office has bad manners around 440 Broad, like pushiness, retaliation, and strange workplace practices. There were also concerns about racism from D'Alessandro, specifically treatment of women of color workers in his office. Again, I haven't found public record of this, but it sounds bad. I'm not a full-time reporter--just a researcher. If press wants to follow up, I'd be happy to send them what I have.
Use and abuse of history for District life
In general, I think it's important to know about this office, what it does, how it works, and who's in there. It gives a little bit more context to the district's machinations. I can imagine that there's fear throughout the building about another audit, leading to more paperwork, leading to more fear and slowness and confusion. In some ways, the story of this office is one of a bad inheritance: people messed up before and the district is trying to make sure that doesn't happen again.
But I always think about Nietzsche in a moment like this. He has an essay called On the Use and Abuse of History for Life that makes a good point. History can guide us in the present, but it can take over and actually obfuscate the best decisions now. We can get caught up in history, in fear or glory, and let that inform what we do today. I think maybe something like this is happening at 440 Broad.