Provide Public Comment on Proposed Charter School Funding Regulation (Maryland Register, February 20, 2026)

On February 20, 2026, a draft regulation establishing a charter school funding formula was published in the Maryland Register as COMAR 13A.02.10 – Maryland Public Charter School Program. This regulation represents a critical step in creating Maryland’s first transparent and consistent funding formula for public charter schools, and it is now open for public comment through March 23, 2026 (30 days after publication).

How to Submit Your Comments

Please submit your comments by March 23, 2026, through one of the following channels (as listed in the Maryland Register):

  • Mail: Carol Beck, Director, Office of School Innovations
    Maryland State Department of Education
    200 West Baltimore Street, Baltimore, MD 21201

  • Phone (for info only): 410-767-3678

Suggested Points to Include in Your Feedback

When submitting comments, we recommend including:

  1. Support for adopting a transparent funding formula for public charter schools.

  2. Concerns about the lack of a total withholding cap and how multiple deductions could reduce core instructional funding.

  3. Request for clear implementation guidance from MSDE to ensure consistent calculations across LEAs.

  4. Recommendations for fair, accessible buyback services and strong protections for special education services.

  5. Reminders that facilities funding remains unresolved and that a higher share of dollars must follow students.

Why Your Voice Matters

We are hopeful that this regulation will ultimately support the passage of a clear funding formula that can be implemented for the 2026–2027 school year.

Establishing clarity and predictability in funding is long overdue and essential for school planning.

At the same time, there are important areas where we believe the regulation can be strengthened:

  • Total Withholding Cap - The proposed draft allows multiple deductions (administrative fees, adult education, special education adjustments, retiree healthcare benefits, etc.). We believe there should be a clear cap stating that total withholdings may not exceed 8% of the per pupil allocation (PPA). Without a cap, schools risk losing too much funding through layered deductions, limiting their ability to effectively serve students.

  • Urgency and Timely Implementation - Because the intent is to implement this formula beginning in the 2026–2027 school year, it is critical that this regulation be finalized as soon as possible. Schools and districts must build budgets, negotiate agreements, and plan staffing months in advance. Any delay in finalizing the regulation will create uncertainty and disrupt responsible planning. 

  • Clear Implementation Guidance from MSDE - This will be the first year that LEAs implement a formal statewide funding formula for charter schools. We strongly encourage the Maryland State Department of Education to provide concrete, detailed guidance and oversight to ensure consistent calculations and compliance across all districts.

  • Support for Every District - Every district with a charter school will need assistance calculating funding correctly — whether they are maximizing withholdings or not. Standardized tools, oversight, and transparency will be essential to ensure equity statewide.

  • Buyback Service Menus - Districts should be required to provide clear, accurate, fair, and timely menus of buyback services so schools can make informed decisions about purchasing central services.

  • Special Education Agreements - Supports must be equitable, and agreements reached between LEAs and charter schools regarding special education services must be honored, supported, and free from retaliatory practices.

  • Facilities Funding Gap - This regulation does not address facilities funding for public charter schools. Because charter schools continue to receive no direct facilities funding, it is especially important that a higher percentage of funding follow students to ensure schools can operate effectively.

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Action Needed: Update & Advocacy Resources on the 8% Special Education Cap