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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 2012-2017.

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®.

2022

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.