Click here to read JCRC-NY’s comments on the proposed rules.
Intro 65, the nonpublic school security guards bill authored by CM David Greenfield, passed by the New York City Council in December, 2015 and signed by Mayor de Blasio in January, will fund security guards in private and parochial schools with more than 300 registered students. New York City is moving ahead with implementation, with the hope of having the program in place by the start of school in September.
If you anticipate that your nonpublic school will have an enrollment exceeding 299 students we strongly urge you to follow this link to the HHS Accelerator and complete the submissions before the end of June. After completing the HHS Accelerator, schools will be eligible to apply to participate in the reimbursement program.
The New York City Department of Citywide Administrative Services (DCAS) drafted proposed rules and will hold a public hearing on June 27, 2016 at 3:00 PM in the Auditorium at 125 Worth Street, New York, New York 10013. You must register if you wish to submit comments on the proposed rules. You can view the proposed rules here. Several organizations, including the JCRC-NY, are reviewing the rules and will make comments. If you’ve read the FAQ’s and still have questions contact us here.
DCAS’ FAQ’s follow. Of course, the rules, which will be finalized after the hearings, will be definitive. Here are the FAQ’s (slightly edited for clarity):
Who is administering the program?
- The Department of Citywide Administrative Services (DCAS) was designated as the administering agency by Mayor de Blasio on March 10, 2016.
When does the program begin?
- Reimbursement will be available for the 2016-2017 school year, starting from the date that an MOU (i.e., a contract) is signed. At this time, we anticipate that the contractual agreement will take the form of a Memorandum of Understanding (MOU) and that it will require registration with the Comptroller.
Do I need to sign a contract with the City to receive reimbursement?
- Yes, each school must enter into a signed MOU (i.e., a contract) with DCAS before any reimbursements will be provided. Upon registration of each school’s MOU, qualified nonpublic schools will be able to submit reimbursement requests on a quarterly basis.
Who is eligible to participate?
- A qualified nonpublic school is a nonprofit elementary or secondary school in New York City, other than a public school, that provides instruction in accordance with the education law, has been assigned a Basic Educational Data System (BEDS) code by the New York State Department of Education, or similar successor identifier, and is serving students in any combination of grades from pre-kindergarten through twelfth grade.
Will the program reimburse schools for an unlimited number of security guards?
- No. The program will provide reimbursement to qualified nonpublic schools for the allowable costs 0f retaining certain security guards based on the number of students enrolled at such school.
- Approved schools that enroll between 300 and 499 students shall be reimbursed for the cost of one (1) security guard;
- approved schools that enroll between 500 and 999 students shall be reimbursed for the cost of two (2) security guards; and
- approved schools shall be reimbursed for the cost of an additional security guard for each additional 500 students enrolled in such school.
How does a school apply?
- If a nonpublic school wants to participate in the program during the 2016-17 school year, the school will be required to complete an application. The forthcoming application will be administered by DCAS through the HHS Accelerator system. In order to access the application, a nonpublic school must first be prequalified in HHS Accelerator.
What is HHS Accelerator?
- HHS Accelerator is the City’s online system for health and human service procurements and financial management, which was launched to simplify and speed the contract process for Client and Community based Services providers. HHS Accelerator will reduce paper-based submissions in the financial management of the reimbursement program.
Does being prequalified in HHS Accelerator ensure participation in the program?
- No. Prequalification only ensures that your school meets the standards set forth by HHS Accelerator to utilize their system for this program and also apply to other relevant procurements in HHS Accelerator that your school may be interested in pursuing. A school will still need to complete an application for reimbursement at a later date. Once the application is available, those schools that have been prequalified to use HHS Accelerator will receive an email notification.
When will an application be available?
- DCAS is working to finalize the application as well as rules that offer participants further guidance. Once completed, schools will be notified by DCAS and HHS Accelerator that an application is available for completion. In response to such applications, DCAS will inform schools if they meet the definition of “qualifying nonpublic school” and the number of guards for which they are eligible to receive reimbursements.
How often can a school submit for reimbursement?
- Schools will submit their requests for reimbursements on a quarterly basis. DCAS will provide additional information on the reimbursement schedule prior to the start of the program.
How does a school submit invoices?
- All payments will be processed using HHS Accelerator. DCAS will provide additional information on payment processing prior to the start of the program.
What activities are eligible for reimbursement?
- A qualified nonpublic school may be reimbursed for allowable costs of a security guard used to provide security services when the school is open for school-related instruction or school-related events. Reimbursements shall be given for security guards who provide security services and no other services.
- Forthcoming rules will be promulgated by DCAS that will provide additional guidance on allowable costs and what activities are eligible for reimbursement.
What qualifies as a student for purposes of determining how many security guards a school is eligible to claim reimbursement?
- A student is deemed to refer only to full time students meaning they attend school for six hours and twenty minutes a day. Students to whom the city separately provides assistances that includes funding for security are not included in the reimbursement determination. Schools will be required, upon application to the program, to provide the total number of students enrolled in the school. Schools must revise their application if the total enrollment changes as of the date the school provides this information to the New York State Education Department Basic Educational Data System (BEDS) Report of Nonpublic Schools.
Can a school use any security guard vendor?
- No. DCAS will establish a list of qualified vendors. In order to receive reimbursements, schools will only be able to utilize firms that are on the qualified provider list. Once a list is available, DCAS will notify schools of its availability via email or letter.
What salary is expected to be paid to security guards under this program?
- Security guard wages equal to the prevailing wage and supplements are allowable costs for qualified nonpublic schools under this program. “Prevailing wage and supplements” means the rate of wage and supplemental benefits per hour paid in the City of New York to unarmed security guards as determined by the Comptroller of the City of New York in accordance with section 234 of the labor law. For more information on prevailing wage, visit the New York City Comptroller’s website at: http://comptroller.nyc.gov/prevailing-wage/wage-schedules/.
Emergency Planning for Private Schools Workshop
Tuesday, May 3, 2016
9:00 AM – 5:00 PM
(Registration begins at 8:30AM)
Manhattan Municipal Building
1 Centre St, New York, NY 10007
This workshop is intended to provide guidance on emergency planning for private schools. Participants will receive training in the basic fundamentals of emergency planning and how to develop their school’s Emergency Operations Plans (EOPs). They will hear from subject matter experts from the NYPD, FDNY, New York State Police and the US Department of Education on available tools to support school emergency planning efforts.
The first half of the workshop will be a presentation from the US Department of Education Readiness and Emergency Management for Schools Technical Assistance Team (REMS). This portion of the program will provide an overview of the recommended six step planning process to create a high-quality school emergency operations plan.
The second half of the day will feature presentations by:
- NYPD: They will discuss the Shield Program and other NYPD services available to schools.
- New York State Police: They will demonstrate their school emergency operations planning template.
- FDNY: They will cover fire safety and school evacuation plans.
Private school administrators and security personnel interested in creating, revising, or enhancing school emergency operations plans.
Registration for this event closes on Tuesday, April 26, 2016 at 5:00 pm Eastern Standard Time.
Cancellations must be received no later than three business days in advance.
NYCEM Academy provides reasonable accommodations. If you are in need of a disability accommodation, please send your request to firstname.lastname@example.org.
Jerusalem Post: Gunman opens fire outside Ozar Hatorah school before fleeing the scene on scooter; teacher and two of his children among dead, several wounded; Jewish official: This was an anti-Semitic attack.
JTA: A man riding a motorbike reportedly opened fire outside the Ozar Hatorah School, where students were waiting to enter the building at the start of the school day. The shooter then entered the building shooting at students and teachers. He then fled on his motorbike.
Haaretz: French prosecutor Michel Valet said Monday that those killed were a 30-year-old man and his 3-year-old and 6-year-old sons. He said another child, between 8 and 10 years old, was also killed, and a 17-year-old seriously wounded.
See also Jerusalem Post: “… a coalition of jihadist organizations have made a decision to attack Israeli and Jewish targets wherever they may be without distinction. “They attack whoever they can and wherever security is lax”.
- Access control. Until we know more, schools should consider asking students and staff to come inside the building rather than assembling outside. Our standard recommendation that no unauthorized person should be allowed to enter a Jewish institution (see our sample access control procedures here).
- Secure doors. Many organizations are thinking about their Nonprofit Security Grant applications. This tragic attack reminds us about the importance of high impact doors that can withstand an attack from a determined intruder.
- Lockdowns. Do you have a plan to “lockdown” your building and its occupants to keep them safe in the event on an active shooter? See the JCRC Active Shooter Page.
- Security awareness. Although there is no indication of any threat here in New York, it is a time for heightened awareness. Trust your instincts. If you see something…say something. Terrorist acts and other attacks are often preceded by active surveillance of a target location; learn how to detect hostile surveillance before an incident occurs. See tips from our partners at the John Jay College of Criminal Justice.