The report’s argument rests on several assumptions that are not explained or justified. This is especially surprising given the report itself acknowledges that it is difficult to “paint with broad brush strokes as it applies to assessing the efforts of Michigan’s [charter school] authorizers to ensure accountability.” Nevertheless, it does just that.
For example, it declares, “Accountability and oversight of authorizers across the states, and especially in Michigan, has been lax.” The only evidence provided for this statement is that state officials only rarely exercise their power over authorizers and exert control over them. But no evidence is provided to support this assertion, either. Plus, even if true, the fact that state officials are not fixing problems with authorizers could also be evidence that there are few problems with authorizers. The report does not consider this possibility.
More broadly, while the report targets charter school authorizers for more oversight, it never actually presents evidence for this position. In fact, it states: “The research for this report did not produce evidence that the current authorizers were negligent in their activities.” The closest the report comes to providing this evidence is highlighting that this oversight is different than what is used for charter schools in other states and for other public schools in Michigan. But the fact that it is different is not sufficient grounds to suggest that public oversight of charter school authorizers needs to be reformed.
Another important assumption the report relies on but never justifies is that the particular type of oversight it recommends — giving more control to state bureaucrats and creating new state laws and regulations of charter schools — will improve public education in Michigan. The report fails to connect the dots on why this type of oversight is beneficial and why it will lead to improved educational outcomes.
Surprisingly, it discusses reasons to doubt this assumption. The report explains that charter schools “may be subject to more regulations than traditional public schools” and that “over-regulation stymies innovation,” which, according to the report, is charter schools’ key contribution to “increase educational productivity across the whole system.” It then identifies over-regulation as a possible explanation for why Michigan’s charter schools are, as the report sees them, not differentiated enough from conventional public schools.
This evidence suggesting the potential harmful impact of over-regulating should call into question the report’s assumption that more regulation of charter schools and their authorizers will lead to better educational outcomes. Even though the report tries to draw a distinction between different types of oversight — accountability based on outcomes and regulations based on inputs — the policy recommendations it suggests are primarily regulatory in nature: adopting administrative rules, creating new statutory requirements, mandating accreditation for authorizers, tweaking financial reporting requirements.
Perhaps the strongest evidence provided in the report that more oversight of Michigan charter schools is needed is the state’s “declining status among the states in education achievement.” It says Michigan should mimic the oversight mechanisms for charter school authorizers used in states that have higher average scores on national standardized tests.
But, again, no evidence is offered to suggest that differences in charter school oversight among the states is responsible for or even related to differences in average test scores. In fact, it is highly unlikely from a statistical perspective that the varying performance of charter schools in the states has a large impact on average test scores. In most states, charter schools enroll less than 10% of public school students.
Over more than 50 pages, the report provides many valuable insights into how charter schools operate, but it fails to justify the core assumptions upon which its arguments are based. It does not provide evidence to suggest charter school regulation is lacking — only that it is different. It does not provide evidence that its recommendations will lead to better educational outcomes. The report’s authors instead simply assume these things to be true, which leaves their policy recommendations without any backing.
 “Improving Oversight of Michigan Charter Schools and Their Authorizers,” (Citizens Research Council of Michigan, Feb. 2020), 50, https://perma.cc/9DHA-3DFB.
 Ibid., 54.
 Ibid., ix.
 Ibid., 50-51.
 Ibid., 51.
 Ibid., 52-57.
 Ibid., 50.
 “Table 216.90: Public elementary and secondary charter schools and enrollment, and charter schools and enrollment as a percentage of total public schools and total enrollment in public schools, by state: Selected years, 2000-01 through 2016-17” (National Center for Education Statistics, Dec. 2018), https://perma.cc/PS3B-754K.