Help the Comptroller get the full record before registration.

Purpose of this follow-up

Thank you for your June 26 response to Community Education Councils 2, 3, and 20 regarding DYCD's School-Based COMPASS Request for Proposals awards.

Your letter clarified the role of the Comptroller's Office. We understand that your office does not ordinarily select afterschool providers, rescore proposals, or deny registration solely because families prefer one provider over another.

That is not what we are asking.

We are asking your office to exercise its full contract-registration review authority before any disputed COMPASS/SONYC contracts are registered.

Your letter states that, once final agency determinations are rendered and the COMPASS contracts are submitted for registration, your office will review whether DYCD followed proper procurement rules, whether funds exist, whether there was corruption in the procurement process, whether vendors are in good standing and eligible to receive City contracts, and whether DYCD complied with procurement rules governing vendor protests.

This is exactly the review families are asking for.

Our concern is not simply that school communities are unhappy. Our concern is that the public record does not yet show that DYCD followed a lawful, disclosed, documented, rational, and reviewable procurement process when making six-year school-based afterschool awards affecting children, students with disabilities, frontline workers, and public funds.

The scale of what is being registered underscores why this review matters. DYCD's own funding attachment puts the total contract-term value of these awards at approximately $3.34 billion across 102,104 slots and 111 competitions. These are six-year commitments of substantial public funds, and the materiality of the awards is itself a reason for careful registration review.

Two threshold requests: a hold during review, and a parallel audit

Two requests frame everything below, because both protect the public interest after the registration window closes.

First, we ask your office to use the full time available under City Charter § 328 to complete this review, and to flag or decline to register any disputed package until the procurement record is verified rather than registering on an incomplete file. We also ask that DYCD be advised not to take irreversible implementation steps, including staff terminations, displacement of existing programming, or parent-facing transition actions, while the registration review of disputed packages is pending. A registration review means little if the harm it is meant to prevent is executed before the review concludes.

Second, registration review is narrow and time-limited. The concerns in this letter, including scoring integrity, disability-access enforceability, workforce displacement, and program continuity, extend well beyond the registration window. We therefore ask the Comptroller to open a separate performance audit of DYCD's School-Based COMPASS/SONYC procurement and its implementation under the office's audit authority in City Charter § 93. An audit survives registration, reaches questions registration review cannot, and gives families and the City a remedy that does not expire the moment a contract is registered.

The most immediate question: Attachment 02 makes a codified School Partnership Agreement and proof of insurance conditions of award, and an incomplete package should be returned

Before reaching the broader procurement questions, there is a narrow and immediate ground squarely within your office's authority. Attachment 02 states that contract awards shall be subject to, among other things, timely completion of contract negotiations between DYCD and the selected proposers and codifying a school partnership agreement with the assigned school, and to demonstration of compliance with the City Comptroller's Office mandate that all contractors have the proper insurance. These are stated conditions of award, in DYCD's own controlling document.

This matters because your office's registration clock begins only when a complete contract package is submitted, and an incomplete package may be returned. If a disputed school has not codified a School Partnership Agreement with the assigned provider, whether because the school objects, has not signed, or because negotiations are not complete, then a stated condition of award under Attachment 02 has not been satisfied, and the package is not complete. The same is true of the required proof of insurance.

We therefore ask your office to confirm, for each disputed COMPASS/SONYC contract submitted or to be submitted for registration, whether the package contains a finalized, codified School Partnership Agreement formally accepted by the assigned school, and proof of the insurance required by the RFP and by the Comptroller's own mandate. Where either is absent, we ask that the package be returned as incomplete rather than registered. This is not a request that your office prefer one provider. It is a request that your office apply DYCD's own stated conditions of award and the office's own package-completeness rules.

There is a structural dimension to this that the registration record should address. At a school where the assigned provider cannot codify a School Partnership Agreement, the award has no lawful path to completion unless DYCD has a documented contingency. Attachment 02 gives DYCD the discretion to make that contingency difficult: the same document that lets DYCD decline the highest-scoring proposal and cap how many schools a provider receives for provider diversity and distribution means that the next viable provider at a contested school may have been capped or passed over by DYCD's own allocation decisions. If the assigned provider fails to satisfy the School Partnership Agreement condition, and the next viable provider was made unavailable by DYCD's own exercise of discretion, the package may be one that cannot be completed as awarded. We therefore ask your office to require DYCD to identify, for any disputed school where the School Partnership Agreement is not codified, the documented next step in the award process, including whether a next viable provider was available or was capped or passed over through provider-diversity, capacity, or distribution discretion. A condition of award that cannot be satisfied, with no documented contingency, is not a basis for registration.

The central concern: DYCD redesigned the procurement to exclude the evidence incumbents would have been strongest on, then defended the results with claims that evidence may not support

Before turning to the specific review items, we ask your office to hold one structural question throughout the review. It is the organizing concern behind every item that follows.

DYCD redesigned the procurement in a way that stripped out the school-specific evidence that would have most favored successful embedded incumbents: host-school support letters, existing school partnership agreements, actual staff, and school-specific budgets. DYCD then defended the resulting awards using exactly the claims that evidence would have supported: school fit, principal voice, provider readiness, inclusion capacity, program continuity, and community connection. The question for your office is whether those claims are in the administrative record, or whether the procurement's own design made it impossible for them to be.

DYCD's own proposal-submission training materials show how narrow the school-specific evaluated record actually was. For each school within a competition, a proposer entered only four things: a preference rank, a maximum number of supported slots, and two free-text fields, one describing working experience with the school or surrounding community and one describing partnering approach, each capped at 1,500 characters. That cap is roughly 200 words per field to describe an organization's entire history with a given school community. Those two short boxes are the only school-specific qualitative input in the evaluated record. Everything substantive that DYCD scored, the organization's afterschool experience, its program quality, its SEL curriculum, its staffing plan, lives in a questionnaire answered at the organizational level, not school by school. So the record splits cleanly: the substance was evaluated for the organization as a whole, and the school-specific content was two roughly 200-word text boxes, a rank, and a slot number. That cannot establish the depth of an embedded provider's multi-year relationship with a specific school, the continuity of its named staff, or the readiness of its specific site programming. The thinness of the evaluated school-specific record is not a matter of interpretation; it is visible in DYCD's own forms. DYCD then defended the awards on school-fit grounds the instrument was never built to assess.

The following facts are not in dispute. They are drawn from DYCD's own pre-proposal conference materials and responses, which are part of the public procurement record for EPIN 26026P0003.

First, host-school support letters and School Partnership Agreements were not part of the proposal, and were affirmatively excluded. DYCD's own FAQ states that applicants were not required to include school letters of support and that DYCD would not accept a Community Partnership Agreement or School Partnership Agreement with the host school as part of the proposal. DYCD's pre-proposal slides list the School Partnership Agreement as a post-award requirement and state it will not be accepted during the proposal stage. An applicant confirmed this exclusion directly at the October 21, 2025 pre-proposal conference, and DYCD did not dispute it. DYCD awarded school-based contracts first and required the actual school partnership afterward.

Second, the RFP's formal ranking mechanism was proposer-only and entirely excluded principals. At the October 21, 2025 pre-proposal conference, DYCD stated plainly that the proposer ranking process was designed solely to allow proposers to communicate their preferred sites to DYCD, that proposer rankings would not be shared with New York City Public Schools, and that the ranking was not designed to match with another entity. Principals did not participate in the RFP's formal ranking at all.

A separate informal principal-ranking process did occur, but outside the scored procurement record. According to accounts documented in public petitions and press reporting, principals were asked to rank providers in a closed-door process after proposals were evaluated, and were reportedly instructed not to discuss that process with parents, PTA leadership, School Leadership Teams, teachers, or Community Education Councils. The Computer School principal stated publicly that despite her school clearly identifying Manhattan Youth as the best fit, a different provider was selected, and that she received dismissive responses when she sought clarification. This informal process does not appear in the RFP as a disclosed, formally weighted procurement element.

The opacity of the principal's role in the formal procurement is itself documented. At the October 21, 2025 conference, the Imogen Roche Foundation asked directly what role the school principal had in selecting the provider, noting that the school partnership agreement was no longer part of the proposal. A follow-up question pressed further: the questioner still could not determine whether the "applicable NYCPS advisor" was a school leader, district leader, PTA or SLT member, UFT representative, or the individual principal. DYCD did not answer in the conference. Even applicants could not determine the principal's role during the procurement itself. Yet DYCD later publicly defended the awards by saying principals had a meaningful voice. The record must show exactly what that means: where, how, and with what weight principal input entered the award decision.

Third, for multi-school competitions, only one budget narrative was required, for the site with the largest number of proposed slots, and individual site budgets were explicitly deferred to post-award workscope development. DYCD confirmed both points at the October 21, 2025 conference: the budget narrative should be for the largest-slot site, and individual site budgets would be developed after award during workscope development. A provider operating several schools in one competition did not submit school-specific budget narratives for each site, and no school-specific financial feasibility determination was required before award. One budget narrative was used to represent a competition covering multiple distinct school communities, each potentially with different program sizes, sports ecosystems, disability-support requirements, and staffing needs.

Fourth, three community partnerships per competition could count as local fit across multiple schools, and paid subcontractors could count toward that requirement. DYCD confirmed at the conference that subcontractors could be counted toward the community partnership requirement. DYCD's own pre-proposal slides confirm that school partnerships do not count toward the three required community partnerships. So a provider proposing multiple schools in one competition submitted three partnerships, which could be paid vendors, to represent community connection across all of those schools.

Fifth, proposers were not expected to have hired or retained staff before award. DYCD confirmed at the conference that proposers were not expected to have hired or retained staff before contract award and program start date, and that resumes would not be accepted in place of job descriptions. DYCD is defending these awards in part by pointing to staffing readiness and inclusion capacity. But the procurement record contains job descriptions and staffing plans, not actual named staff, at the time of award.

Sixth, at the October 21, 2025 pre-proposal conference, a proposer asked who would be evaluating the proposals. DYCD did not answer the question. A separate proposer asked whether any part of the funding was from federal funds. DYCD did not answer that question either. Both answers should be in the procurement record.

DYCD's own concept paper, which preceded the RFP, sharpens these contradictions in two specific ways that the registration record should address.

First, the concept paper stated that school partnerships are central to program quality, that they help align afterschool with school-day learning, recruit hard-to-reach students, support safe passage, and ensure quality programming, and that the RFP would include details on the process for developing school partnerships, including whether proposers would interview with school principals. The final FAQ then excluded school letters of support and School Partnership Agreements from the proposal stage entirely and made school partnership a post-award requirement. DYCD's own concept paper said school partnerships are essential to quality programming. The final RFP excluded school partnership proof from the proposal stage and deferred it until after award. The record should explain that decision.

Second, the concept paper proposed requiring a minimum of ten percent of the total program budget, up to thirty percent, to be used for specialist subcontractors or consultants, and encouraged MWBE subcontractors and consultants. The final RFP removed that floor entirely. It retains only a thirty percent ceiling, stating that no more than thirty percent of the total budget may be subcontracted, and makes subcontracting encouraged but not required, even as the same RFP states that a goal of subcontracting is to strengthen diversity, equity and inclusion through partnerships with small, grassroots, emerging and BIPOC organizations most embedded in their communities. DYCD's public equity rationale depends in part on bringing in exactly those smaller, specialized, neighborhood-based, and MWBE providers through subcontracting. Removing the only hard subcontracting floor while invoking equity and community embeddedness as goals is a contradiction the record should explain.

Third, the concept paper reported that families and participants expressed high levels of satisfaction with current enrichment models and valued the variety of activities available. The concept paper's stated rationale for the new RFP was expansion, equity, and access, not provider failure or community dissatisfaction. If the record showed satisfaction with existing programs, the registration file should explain what justified displacing successful school-provider partnerships rather than using new seats at new schools for new providers.

The thesis this produces is the one your office's review can test directly.

DYCD redesigned the procurement in a way that stripped out the school-specific evidence that would have most favored successful embedded providers, then defended the resulting awards with school-specific claims that may not exist in the evaluated record. DYCD must produce the rationale for that design choice, and the administrative record must show whether the evidence DYCD is publicly asserting was actually collected, scored, and documented before award.

The provider diversity claim requires a documented rationale the public record does not yet show

DYCD has publicly defended these awards in part by invoking "provider diversity" as a goal and a justification. The public record raises a specific question about that rationale that the registration file should answer.

New York Edge was already the single largest COMPASS provider by dollar volume before the rebid. The extension notice shows New York Edge held DYCD COMPASS contracts totaling approximately $82 million, more than double the YMCA of Greater New York at approximately $43 million, and more than three times Manhattan Youth at approximately $26 million. By dollar, New York Edge was the dominant incumbent in the prior system.

After the rebid, New York Edge holds approximately 88 school-level award entries in the 2026 award list, the largest single-provider portfolio in the published results. The next largest visible portfolios are Mosholu-Montefiore at 21 school entries and Aspira and the Coalition for Hispanic Family Services at 16 each. New York Edge's own website described its pre-rebid footprint as "more than 100 schools across all five boroughs," so the 2026 award count may reflect a similar or slightly reduced school-specific footprint in COMPASS rather than a dramatic expansion. What is not in question is that New York Edge was the largest provider before the rebid by dollar, and holds the largest single award portfolio after it.

We raise this not to allege wrongdoing by New York Edge, whose individual awards we do not contest on their merits. We raise it because the provider-diversity rationale DYCD has publicly offered requires a documented explanation in the context of these facts: DYCD's largest prior incumbent by dollar retained the largest single 2026 award portfolio, while dozens of embedded neighborhood providers whose prior contract values were a fraction of New York Edge's lost multi-year relationships with specific schools. The Coalition for Hispanic Family Services, which held a twelve-year contract at Louis Armstrong Middle School in Queens, is one documented example among many.

Attachment 02, the Basis for Contract Award and Procedures, confirms that provider diversity was a disclosed award factor, not a hidden one. It states that awards would be distributed among viable proposers to ensure overall impact, program and provider diversity, and that where multiple viable proposers selected the same school, DYCD would make the award based on demonstrated capacity and provider diversity. This sharpens rather than resolves the question. Provider diversity was disclosed as a discretionary allocation factor, but Attachment 02 does not define it, assign it a numeric weight, or state how it would be measured or applied school by school. It was not one of the six scored evaluation criteria. It operated as a post-scoring allocation principle entirely within DYCD's discretion.

Before registering any contract that invokes provider diversity as a justification, please review whether the administrative record contains: a written definition of what provider diversity meant in this procurement; documentation of how it was measured and applied as a post-scoring allocation factor; an analysis showing how the resulting portfolio is more diverse than the prior one; and an explanation of how displacing embedded neighborhood providers while the largest prior incumbent by dollar retains the largest single award portfolio advances a diversity rationale. Because provider diversity was a discretionary allocation factor rather than a scored or defined criterion, the registration record should show that it was applied rationally and consistently rather than as an unstructured justification applied after the fact.

Attachment 02 confirms DYCD reserved broad discretion to override scores and cap provider awards, which must be supported by a complete and rational record

The single most important document for your office's review is Attachment 02, the Basis for Contract Award and Procedures. It confirms that this was not a procurement in which the highest-scoring proposal won. DYCD reserved sweeping discretion to allocate awards on grounds other than score, and DYCD's own language states plainly that a high score on a proposal is not a guarantee of a contract award.

Attachment 02 reserves to DYCD, among other rights: the right to determine, in its sole discretion, how many eligible schools a proposer will be awarded based on demonstrated organizational capability, programmatic distribution, geographic distribution, and the best interests of the City; the right, where multiple viable proposers selected the same school, to award based on demonstrated capacity and provider diversity; and most significantly, the express right to not award the highest-ranking and or scored proposal within a competition if the proposer has already received an award in another competition. It also reserves the right not to award proposals in order to support balanced and equitable distribution of services, to reallocate funds across competitions, and to make awards to ensure equitable distribution.

This discretion may be lawful. Agencies are permitted to build allocation judgment into a competitive procurement, and DYCD disclosed these reservations in the RFP. But the existence of broad discretion is precisely what makes a complete and rational administrative record essential. Under the arbitrary-and-capricious standard that governs review of these decisions, discretion is lawful only when it is exercised rationally, consistently, and on a documented basis. A reserved right to decline the highest-scoring proposal, to cap a provider's footprint, and to redistribute awards for diversity and geographic balance cannot be exercised on an empty record. Where DYCD departed from score or from the school's own ranking, the file must show why.

The central question for your office therefore sharpens. It is no longer only whether the procurement measured school-specific fit. It is whether DYCD can produce, for each disputed school, the record showing how it used this discretion: the proposal scores, the identity of every viable proposer scoring 70 or above, the NYCPS advisor ranking, and the written rationale for any award that did not follow the highest score or the school's ranking. Please require DYCD to identify every disputed school at which the selected provider was not the highest-scoring proposer, or not the NYCPS advisor's first-ranked provider, or not the incumbent, and to produce the written, school-specific basis on which DYCD applied provider diversity, demonstrated capacity, programmatic or geographic distribution, the award cap for proposers already awarded elsewhere, or the best-interests-of-the-City standard. If that record does not exist, then the discretion Attachment 02 reserves was exercised without the rational, reviewable basis the law requires.

1. Confirm registration status of each disputed contract

Please confirm, for each disputed school or program:

• Has DYCD submitted the contract package to the Comptroller?
• If yes, on what date was it received?
• Is the package complete?
• Is it pending registration?
• Has it been returned, objected to, or registered?
• Which schools, sites, providers, PINs, dollar amounts, and contract terms are included?

Families cannot meaningfully respond to a process when they do not know whether the contract is still in negotiation, pending registration, already registered, or moving toward implementation.

2. Review whether DYCD used only disclosed RFP criteria

DYCD has repeatedly invoked scoring, capacity, principal rankings, and "provider diversity."

Please review whether DYCD used only the criteria disclosed in the RFP and related evaluation documents.

In particular:

• Where was "provider diversity" defined?
• Was it a scored criterion?
• Was it a tie-breaker?
• Was it a post-scoring allocation principle?
• Was it used to override principal preference?
• Was it disclosed to applicants and school communities before awards were made?
• Is there a written record explaining how it was applied school by school?

If "provider diversity" was used as an undisclosed or unexplained factor, that raises serious procurement-process concerns under the competitive sealed proposal rules that govern this RFP.

Please also review the change between the concept paper and the final RFP on subcontracting. The concept paper proposed requiring a minimum of ten percent of the total program budget to be used for specialist subcontractors or consultants, with encouragement of MWBE and neighborhood-based providers. The final FAQ removed that minimum, stating that subcontracting is encouraged but not required. If provider diversity and equity were goals of this procurement, please review whether removing the only hard subcontracting minimum is consistent with those goals, and whether the rationale for that change was documented.

3. Review the NYCPS advisor ranking process, which Attachment 02 confirms was advisory, score-gated, and not necessarily the principal

DYCD has publicly defended the awards by saying principals had a meaningful voice and that more than 80 percent received their first- or second-choice provider. Attachment 02 now allows that claim to be tested against the actual disclosed procedure, and the gap between the public defense and the documented process is one of the most important questions your office should resolve before registration.

There were two distinct ranking mechanisms, and Attachment 02 and the addenda define both.

The first was the proposer preference ranking. DYCD stated, at the October 21, 2025 pre-proposal conference and in the FAQ, that this process existed solely to let proposers communicate their own preferred sites to DYCD, that it was not scored, and that it would not be shared with New York City Public Schools. Schools and principals did not participate in it.

The second was the NYCPS advisor ranking, defined in Attachment 02. The procedure was specific and sequential. DYCD first evaluated and scored every proposal. Only proposals scoring 70 or above were deemed viable. Only then were the School Community Based Organization Partnership Profile responses for those viable proposals moved to what Attachment 02 calls the applicable NYCPS advisor, eligible school personnel designated to serve as an advisor to the procurement. That advisor reviewed and ranked the viable proposers in order of preference, based solely on the proposer's answers to the partnership profile questions. Attachment 02 then states that NYCPS would provide DYCD with its ranking to take into consideration, and that in the event a school did not participate as an advisor within the prescribed timeframe, DYCD reserved the right to award based on the initial score from its own evaluation committee.

Four features of that documented process bear directly on DYCD's public defense. First, Attachment 02 refers throughout to eligible school personnel and the NYCPS advisor, not to the principal. The record should show who actually served as the advisor at each disputed school. Second, the advisor ranking was explicitly advisory, something DYCD would take into consideration, not a binding or independently scored input. Third, the advisor saw only the two partnership-profile answers, each capped at 1,500 characters, for already-scored viable proposals, and at any school that did not respond in time, the advisor role vanished entirely and DYCD awarded on its own score. Fourth, and most consequential, the advisor only ever saw proposers who had already cleared the 70-point viability threshold on DYCD's organizational scoring. A school's known and preferred incumbent could therefore be filtered out, on organizational scoring the school never saw, before the school was ever consulted. The school could rank only among the proposers DYCD's scoring had already admitted, which means the advisory step could not restore a provider the scoring had already eliminated. A defense resting on principal voice cannot be evaluated without the records behind that mechanism.

Separately, parent and principal accounts documented in public petitions and press coverage describe principals being asked to rank providers in a closed-door process and reportedly being told not to discuss it with parents, PTA leadership, School Leadership Teams, teachers, or Community Education Councils. The Computer School principal stated publicly that despite her school identifying Manhattan Youth as the best fit, a different provider was selected, and that she received dismissive responses when she sought clarification. Whether that account describes the Attachment 02 advisor process or something outside it is itself a question the record should answer.

Please review, for each disputed school: who served as the NYCPS advisor and whether that person was the principal; what materials the advisor reviewed; what ranking the advisor submitted; whether the school participated within the prescribed timeframe or whether DYCD awarded on its own score; how DYCD weighed or departed from the advisor ranking; whether any award diverged from the advisor's first-ranked provider and on what written basis; and what the documented source is for DYCD's public claim that more than 80 percent of principals received their first- or second-choice provider. If principal voice was central to DYCD's public defense, the advisor records must be produced, and they must show a process that was consistent, documented, and reviewable.

4. Review evaluator qualifications, conflicts, and scoring records

Please review whether the evaluation process complied with applicable procurement rules and internal procedures.

Families are asking whether:

• Evaluators had relevant youth-development, afterschool, disability-access, middle-school, procurement, or program-operations expertise.
• Evaluators signed conflict-of-interest disclosures.
• Proposals were assigned consistently.
• Any randomized evaluator pool was properly approved.
• Each proposal received the required number of reviews.
• Evaluator instructions were consistent.
• Original and amended rating sheets were preserved.
• Similar or substantially identical proposals received inconsistent scores at different schools.
• DYCD reviewed scoring consistency before making awards.

A six-year award affecting children should not rest on unexplained scoring that cannot be audited. At the October 21, 2025 pre-proposal conference, a proposer asked directly who would be evaluating the proposals. DYCD did not answer the question in the conference. The evaluator roster, qualifications, conflict statements, and assignment methodology should all be in the registration file.

5. Review the Recommendation for Award records

For each disputed contract, please review whether DYCD prepared a complete Recommendation for Award and whether it supports the outcome.

The record should show:

• How many proposals were received.
• The technical rating of each proposal.
• The proposed price or budget.
• The basis for award.
• The selected provider's responsibility determination.
• The relevant worksite or school.
• The dollar amount.
• The funding source.
• Any required justifications or written determinations.
• Prior performance assessments, audits, and monitoring records where applicable.
• The specific reason the selected provider was deemed most advantageous to the City.

The public should not have to guess why a longstanding provider lost a school or why a principal's preferred provider was not selected.

6. Review prior performance and site-specific experience

Many displaced providers had longstanding relationships with schools, strong attendance, trusted staff, successful programming, and years of site-specific knowledge.

Please review whether DYCD considered:

• Prior performance at the specific school.
• Site-level attendance and engagement data.
• Monitoring reports.
• Audits.
• Principal and school feedback.
• Parent and student feedback.
• Staff continuity.
• Experience serving the age group and school community.
• Experience operating comparable middle-school programming.

If DYCD treated existing site-specific success as "bias" or ignored prior performance in the name of a "clean slate," the registration record should identify the legal and procedural basis for that approach.

7. Review the vendor protest process

Your June 26 letter specifically states that your office will review whether DYCD complied with procurement rules governing vendor protests.

Please review:

• Which providers filed protests.
• When each protest was received.
• Whether DYCD issued a written determination within the required timeframe.
• Whether the determination stated reasons.
• Whether the decision was sent to the protesting vendor and selected vendor.
• Whether copies were sent to the Comptroller and other required procurement officials.
• Whether DYCD considered whether delaying the procurement was in the City's best interest.
• Whether the protest record was included in the registration package.

A protest process is meaningful only if the agency's decision is reasoned, documented, and reviewable.

8. Review public notice and comment records

Please review whether DYCD complied with any applicable public notice and comment requirements before entering into contracts.

For each disputed contract, please determine:

• Was a City Record notice published?
• Did the notice identify the proposed vendor, worksite, dollar amount, procurement method, and comment process?
• Was the public given the required opportunity to comment where applicable?
• Were comments from parents, CECs, PTAs, providers, workers, and disability families included in the contract file?
• Did DYCD consider those comments before moving forward?

If public comments were collected but not included in the contract file, that raises a serious accountability concern.

9. Review whether the registration package is complete

Please do not register any disputed package unless the required documents are complete.

The package should include, where required:

• Executed contract.
• Final budget.
• Final scope of work.
• Advice of award.
• Vendor information.
• Worksite or school.
• Dollar amount.
• Funding source.
• Procurement method.
• Number of responses.
• Recommendation for Award.
• Responsibility determination.
• PASSPort/VENDEX materials.
• Legal authority certificate.
• Certificate of procedural requisites.
• Public comments.
• Protest determinations.
• Final transition and implementation documents.

In particular, please confirm that the certifications required under City Charter § 327 are present, complete, and truthful: the certification that the procedural requisites for solicitation and award were met, and the Corporation Counsel certification that DYCD had legal authority to award each contract. Please also confirm that these certifications are actually supported by the underlying documentation rather than certified on a file that is missing required records.

A contract should not be registered if the documents needed to verify lawful procurement are missing or incomplete.

10. Review vendor responsibility, capacity, and business integrity

Your letter notes that the responsibility to ensure awards are made to vendors with the requisite qualifications, capacity, and business integrity remains with DYCD.

That is precisely why your office should verify that the registration package contains a real responsibility determination consistent with the vendor-responsibility standards in PPB Rule § 2-08.

For each selected provider, please review whether DYCD documented:

• Operational capacity.
• Experience serving the relevant age group.
• Experience serving comparable school communities.
• Staffing capacity.
• Licensing readiness.
• Financial capacity.
• Business integrity.
• Record of compliance.
• Ability to provide the promised services at the assigned scale.
• Ability to implement by September.

HHS Accelerator prequalification is not a finding of responsibility for a particular procurement. A prequalified vendor can still be found not responsible for a specific award. Where a provider is assigned to a large or complex middle school with disability-access responsibilities or specialized programming, the record should show actual capacity at that site, not merely a written promise or a general prequalification status.

11. Review final workscopes, budgets, seats, and program continuity

Families are concerned that minimum RFP compliance may not equal continuity.

Please review whether final workscopes and budgets preserve or replace actual school-level programming, including:

• Sports and MSAL teams.
• Theater and musical productions.
• Debate.
• Music.
• STEM and robotics.
• Fencing.
• Cheerleading.
• Homework support and tutoring.
• SHSAT or academic preparation.
• Late pickup.
• Cross-school events.
• Club access.
• Disability-aware routines.

Please also review:

• Prior funded slots.
• New funded slots.
• Prior funding.
• New funding.
• School enrollment.
• Estimated unique students served.
• Whether middle-school a-la-carte participation was considered.
• Whether "continuity of slots" translates into continuity of actual children served.

A funded slot is not always the same as a unique child served, especially in middle-school programs where students may attend specific clubs, sports, or activities rather than full-time daily programming.

12. Review licensing and implementation readiness

Please review whether providers are actually ready to operate by September, including whether each provider holds or is on track to hold the School-Age Child Care licensing required under the applicable OCFS regulations (18 NYCRR Part 414) for the sites it has been assigned.

The registration package should show:

• Licensing status.
• Site approvals.
• Required clearances.
• Staffing plan.
• Hiring timeline.
• Training timeline.
• Contingency plan if licensing or staffing is delayed.
• School partnership agreement status.
• Family communication plan.
• Start date and implementation schedule.

The City should not register contracts that cannot be responsibly operationalized before children arrive.

13. Review disability-access obligations

This is one of the most serious issues, and the RFP itself sets the standard against which the registration packages should be measured.

DYCD-funded afterschool programs serve students with IEPs, 504 plans, autism, ADHD, anxiety, sensory needs, behavioral support needs, and twice-exceptionality. The RFP does not treat disability access as aspirational. It requires the Inclusion Coordinator to manage participants' Individualized Accommodation Plans and to maintain Student Behavioral Support Plans and Logs, requires a site-specific Referral Plan and a customized Crisis Navigation Plan created by the Program Director, and requires compliance with the ADA, the Rehabilitation Act, the New York State Human Rights Law, and the New York City Human Rights Law, including individualized assessment before any child is excluded. The RFP also specifies that the post-award School Partnership Agreement must include processes to support families to request screening assessments and accommodations, which means the document a family relies on to secure accommodations is itself deferred until after award. These family-facing obligations matter for a reason beyond the students. Parents and guardians with disabilities are themselves members of the public who interact with the program, and a public entity's obligations under the ADA and Section 504 run to them directly, not only to their children. Where the assigned provider is unknown and the accommodation process is deferred, a disabled parent's established communication channel, accommodation arrangement, and predictable access to the program may be disrupted with no individualized plan in place. The registration record should therefore reflect that the RFP's family-facing accommodation requirements account for access by disabled parents and guardians, not only by disabled students. These are contract requirements, not goals.

Please review whether the contract package contains enforceable, site-specific disability-access obligations, including:

• Inclusion Coordinator role: per DYCD's own pre-proposal materials, this is a role assignment from existing staffing, not a required additional hire, and each site may draw on a central agency point-person. The question is therefore not whether a coordinator was designated in the proposal, but who specifically holds the role, whether they are on site during all program hours, what disability-specific training they hold, what formal authority they have to modify program access, and what the coverage plan is when they are absent.
• Whether the coordinator is site-based or shared across multiple sites, and what the coverage plan is.
• Accommodation request process.
• IEP/504 access-review process.
• Parent meeting process before the first day.
• Staff training in autism, ADHD, sensory needs, anxiety, executive functioning, de-escalation, elopement, and disability-related behavior.
• Written de-escalation protocol.
• Sensory-support protocol.
• Parent communication protocol.
• Non-exclusion/counseling-out protections.
• Access to sports, arts, theater, debate, STEM, trips, late pickup, and clubs.
• Specific plan for twice-exceptional students.
• 30/60/90-day review process.
• Named DYCD and provider contacts for unresolved access problems.

A promise of an "inclusion coordinator" is not, by itself, a disability-access transition plan.

If disability and inclusion were part of the justification for these awards, they must also be reflected in the contracts and implementation documents.

14. Review whether the procurement evaluated provider readiness for schools with specialized or high-disability populations

This concern follows directly from the structure of the procurement. As described above, DYCD made awards at the individual-school level using competition-level proposals, and the only school-specific content in the evaluated record was a preference rank, a maximum slot number, and two free-text fields of roughly 200 words each. That structure raises a particular problem at schools whose populations are not generic.

A competition-level proposal and two short text boxes cannot establish a provider's readiness to serve a school with an unusually high proportion of students with IEPs, a significant autistic or sensory-sensitive population, a substantial population with emotional-regulation or behavioral-support needs, a community with significant communication-access or language-access needs, or a specialized instructional model. For such a school, the questions that determine whether children can actually access the program are concrete and site-specific: whether staff hold the relevant training and communication-access skills, whether the routines and trusted adults that make participation possible are preserved or replaced, what the de-escalation and crisis protocols are, and how students with disabilities will access the full program rather than be supervised separately from it. A provider's general afterschool experience does not answer any of those questions for a specific specialized population.

DYCD's own RFP recognizes that disability access requires individualized assessment, reasonable accommodation, and access to centralized supports, and it requires site-specific Referral Plans and Crisis Navigation Plans. But those are post-award implementation obligations. They do not answer the procurement question, which is whether DYCD evaluated a provider's capacity to serve a specialized population before selecting that provider, or whether it deferred that question to post-award cleanup. Where it is deferred, disability access was not a selection criterion at all.

For any disputed school that serves a specialized or high-disability population, please review whether the administrative record contains a site-specific evaluation, made before award, of the selected provider's capacity to serve that population, including relevant staffing, training, communication access, accommodation continuity, and transition planning. If the record contains only a generic competition-level proposal and the two short partnership-profile fields, then for these schools in particular the procurement did not evaluate the very fit on which DYCD has publicly defended the awards.

15. Review whether DYCD's contractor-selection method complied with the ADA Title II prohibition on discriminatory selection criteria

This concern is distinct from whether the final contracts contain disability-access provisions. It goes to the procurement method itself. Under the federal ADA Title II regulation at 28 CFR 35.130, a public entity may not, directly or through contractual or other arrangements, utilize criteria or methods of administration that have the effect of subjecting qualified individuals with disabilities to discrimination, or that defeat or substantially impair the program's objectives for individuals with disabilities. The same regulation states specifically that in the selection of procurement contractors, a public entity may not use criteria that subject qualified individuals with disabilities to discrimination on the basis of disability. This is an effects-based standard. It does not require any intent to discriminate.

That standard is directly implicated here. DYCD's own RFP recognizes that lasting relationships with trusted adults and peers, predictable routines, individualized accommodation, and continuity of support are central to the program, and for students with disabilities those conditions are frequently the basis on which meaningful access depends. Yet the six scored evaluation criteria in Attachment 02 contain no factor that evaluates the disability-access impact of replacing an embedded provider: not continuity of existing accommodations, not retention of staff who hold individual children's behavioral and sensory histories, not the transition risk to students whose access depends on known routines and known adults. A contractor-selection method that treats provider replacement as access-neutral, in a program the agency itself describes as relationship-dependent, may operate as a method of administration that has the effect of impairing the program's objectives for disabled students.

Please review whether DYCD, in designing and applying its contractor-selection criteria, evaluated the disability-access consequences of displacing incumbent providers, including continuity of accommodations, behavioral and sensory support histories, and the transition risk to students whose meaningful access depends on established routines and relationships. If the selection criteria did not account for those consequences, please review whether the method of administration is consistent with 28 CFR 35.130, and whether the registration packages can demonstrate that meaningful access for disabled students was protected by the selection process rather than deferred to post-award repair.

16. Review workforce continuity and staff retention

Afterschool continuity depends on the people children know.

Please review whether final contracts or workscopes address:

• Whether current staff will be retained.
• Whether staff must reapply.
• Whether pay, hours, and benefits are preserved.
• Whether site directors, coaches, group leaders, teaching artists, and specialists can continue.
• Whether incoming providers have written hiring-preference language.
• Whether subcontracting is needed to preserve existing programming.
• Whether workforce disruption was analyzed before award.
• Whether any applicable City workforce-transition or displaced-worker protections apply to this change of provider, and if so, whether they were followed.

When trusted staff disappear, students lose relationships, routines, and institutional knowledge.

17. Review consistency across schools and co-located campuses

Please review whether DYCD treated similarly situated schools and providers consistently.

Families are concerned about:

• Schools that wanted to keep a provider and lost it.
• Schools that wanted a provider removed and kept it.
• Co-located campuses where one school lost a shared provider while another retained it.
• Providers moved from schools that wanted them into schools that did not.
• Substantially similar proposals allegedly receiving different scores.
• Large differences in outcomes without public explanations.

These patterns require a school-specific record, not a citywide talking point.

18. Review the difference between model consultation and provider selection

DYCD has pointed to stakeholder engagement before the RFP.

That is different from community participation in the actual provider-selection decision at each school.

Please review whether the record distinguishes between:

• feedback on the general COMPASS/SONYC model; and
• actual school-level provider selection, principal rankings, award decisions, and transition planning.

Parents may have been consulted about what afterschool should include. They were not meaningfully included in deciding who would operate the program at their child's school.

19. Review conflict, integrity, and transparency concerns

I am not asking your office to assume corruption.

I am asking your office to ensure the record contains the documents necessary to rule it out.

Please review:

• Evaluator conflict disclosures.
• Vendor responsibility documentation.
• Lobbying or vendor-contact records where applicable.
• Any integrity reviews.
• Any conflict-of-interest screening.
• Any unusual scoring or award patterns.
• Any documentation explaining provider concentration and provider diversity decisions.

Public trust requires a record that can be reviewed.

20. Review whether community materials are in the contract file

Before registration, please confirm whether DYCD's contract file includes and addresses:

• CEC resolutions.
• Parent testimony.
• Public comments.
• Disability grievances.
• Provider protests.
• School letters.
• PTA/PA letters.
• Principal concerns.
• Worker impact statements.
• Student letters.
• Press-documented concerns.
• Requests for transition planning.

If these materials were submitted before registration but not included in the contract file, that is a transparency problem.

21. Review whether DYCD and the selected providers fulfilled the RFP's inclusion, accessibility, and crisis-response requirements

Please review whether DYCD's registration package demonstrates that each selected provider has met, and is contractually bound to meet, the RFP's own inclusion, accessibility, and crisis-response requirements.

DYCD's pre-proposal materials did not treat disability access as optional. They required providers to comply with the ADA, SACC, and NYC/NYS Human Rights Laws; conduct individualized assessments; submit resource requests such as paraprofessionals or nurses; appoint an Inclusion Coordinator; and complete accessibility training. The materials also required mental-health and crisis-response training, de-escalation/referral training, an annual referral plan, and a site-specific Crisis Navigation Plan.

Before any disputed contract is registered, please review whether the contract package contains enforceable, site-specific evidence of:
• the named Inclusion Coordinator for each site, with confirmation that the role is filled by an identified person rather than left as a generic staffing-pattern designation: per DYCD's own pre-proposal guidance, this role may be assigned to existing staff and supported by a central agency point-person rather than a dedicated hire, which means the contract file must show who that person actually is, whether they are on site during all program hours, what disability-specific training they hold, and what authority they have to modify program access;
• whether that coordinator is site-based or shared across multiple sites, and the coverage plan where shared;
• staff accessibility training;
• autism, ADHD, sensory, anxiety, executive-function, de-escalation, and disability-related behavior training;
• individualized assessment procedures;
• IEP/504 and access-needs review procedures;
• resource-request procedures for paraprofessionals, nurses, or other supports;
• mental-health and crisis-response training;
• annual referral plans;
• site-specific Crisis Navigation Plans;
• parent communication protocols;
• non-exclusion/counseling-out protections;
• and procedures for ensuring students with disabilities can access sports, arts, theater, debate, STEM, clubs, trips, and late pickup.

A general statement that a provider will be "inclusive" or will appoint an "inclusion coordinator" is not enough. If inclusion and accessibility were part of the RFP requirements, they should appear in the final contract package as enforceable obligations.

These are not aspirational goals; they track binding law. DYCD and its providers are subject to Title II of the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, and the New York City Human Rights Law (NYC Administrative Code § 8-107, including its public-accommodation provisions), with the New York State Human Rights Law (Executive Law § 296) applying in parallel. These statutes require individualized assessment, reasonable modifications to policies and practices, and meaningful access for students with disabilities. Please confirm that these obligations appear in the contract package as material terms with consequences for non-compliance, rather than as general assurances. A single shared "inclusion coordinator" does not, by itself, satisfy a provider's independent obligations under these laws at each site.

We are asking your office to confirm whether DYCD's registration submissions show that these inclusion/accessibility requirements were evaluated, incorporated into the final contracts, and made operational before implementation.

22. Review the disclosed numeric evaluation weights against the actual award outcomes

Beyond confirming that only disclosed criteria were used, please review the actual point structure, because the structure itself bears directly on DYCD's public defense of these awards. Attachment 02 published the weighting for evaluation criteria as follows: Organizational Experience and Capability, 21 points; Service Requirements and Program Outcomes, 40 points; Staffing, 20 points; Community Partnership, Subcontractors and School Partnerships, 8 points; DYCD Approaches, 6 points; and Budget Management, 5 points.

Two features of that 100-point structure are significant. First, none of the six scored criteria is dedicated to school-specific fit. Organizational experience, service requirements, staffing, approaches, and budget are all evaluated at the level of the organization and its proposed program model, not its fit with any particular school. The only criterion that touches the relationship with a specific school is the 8-point Community Partnership, Subcontractors and School Partnerships category, and even that category is mostly satisfiable without a school-specific tie: the RFP requires three community partnerships, expressly allows paid subcontractors to count toward them, and the genuinely school-specific input within that category is the pair of 1,500-character partnership-profile boxes. So on the face of the scored rubric, the school-specific content is a fraction of a single 8-point category out of 100, while DYCD has publicly defended specific awards on grounds of school fit, principal voice, and community connection. Second, provider diversity does not appear among the scored criteria at all, which confirms it operated only as a post-scoring allocation factor.

We do not contend that an agency must make school fit the dominant scored criterion. Distribution and capacity goals can be legitimate. The narrower point is the mismatch: a procurement in which no scored criterion is dedicated to school-specific fit, and in which both the proposer's school preference and the school's own advisory ranking are unscored or defeasible, cannot then be publicly justified on school-specific grounds. The instrument and the public defense do not match, and the registration record should be examined with that mismatch in view. The record should also let your office compare this published weighting to how points were actually assigned, so that each award can be reconstructed from the rubric and the rating sheets.

For each disputed award, please review:
• the numeric weight the RFP assigned to each evaluation criterion;
• the point breakdown the selected provider received by criterion;
• the point breakdown the displaced or principal-preferred provider received by criterion;
• whether any criterion was weighted differently in practice than the RFP stated;
• and whether the final point spread between providers actually supports the award.

This is the single most auditable element of the procurement. If awards cannot be reconstructed from the disclosed weights and the rating sheets, the scoring is not reviewable, and a contract should not be registered on it.

23. Review MWBE participation and subcontractor compliance in the registration package

"Provider diversity" as DYCD has used it is a separate question from the City's formal MWBE requirements, which carry their own documentation that your office routinely reviews at registration.

For each disputed contract, please review whether the package contains:
• the applicable MWBE participation goals for the procurement;
• the selected provider's MWBE utilization plan;
• any waivers granted and the basis for them;
• subcontractor compliance plans where subcontracting is used to deliver programming;
• and confirmation that MWBE representations were verified rather than merely asserted.

Where DYCD has invoked diversity as a justification for award outcomes, the formal MWBE record is the place that claim can be tested against an actual standard.

24. Return or object to incomplete packages, consistent with the office's established practice

The request that your office return or object to deficient packages is not extraordinary. Returning incomplete or non-compliant submissions to the contracting agency is an established part of how the Comptroller's registration function already operates.

We ask only that the office apply that ordinary practice here: where a disputed package lacks required procurement documentation, a genuine responsibility determination, protest records, worksite-specific budgets, procedural certifications, or enforceable disability-access obligations, the package should be returned to DYCD for completion rather than registered on a thin record. Treating these disputed contracts with the office's normal rigor is the entire ask.

25. Note on parallel public-records requests

Families and education councils are independently seeking the underlying RFP and award records through the Freedom of Information Law. We raise this not as a threat but as context: the documentation gaps described in this letter will become part of the public record regardless of the registration outcome.

It is therefore in the City's interest that the registration file be complete and accurate now. A contract registered on a record that later proves incomplete when those documents surface publicly is far more damaging to public trust than a package returned for completion before registration.

26. Review whether the Round 2 reissuance was fair and equal, and whether the registration package reflects the correct proposal version

DYCD released Round 2 of the COMPASS RFP on October 31, 2025, because the agency made significant changes to the RFP after Round 1 was issued. When an agency makes significant changes to an RFP in PASSPort, a new round is issued with an addendum explaining the changes, and all proposals must be resubmitted. Round 1 proposals did not carry over and would not be considered.

This creates a distinct set of procurement-integrity questions the registration package should be able to answer.

First, the changes that triggered Round 2 should be documented. If DYCD made significant changes to the RFP after proposals were underway, those changes should have been provided equally to all applicants with sufficient time to respond. The record should show what changed and when each applicant received notice.

Second, the resubmission process was not seamless. MOCS specifically warned applicants that not all Round 1 information could be copied to Round 2, that competition-pool selections in particular could not be copied over, and that copied responses might require updating. The record should show that each applicant had a fair and equal opportunity to adjust school selections, budgets, staffing plans, ranking preferences, and school-specific profile answers in light of the Round 2 changes.

Third, the registration package must be built on Round 2 proposals, not Round 1 submissions. If any Round 1 material was improperly considered, or if the scoring record mixes Round 1 and Round 2 submissions, that is a procedural defect.

Before registration, please review whether the contract file contains:
• the Round 2 addendum with a complete list of all changes made between Round 1 and Round 2;
• documentation that every applicant received the Round 2 changes with adequate notice and time to respond;
• confirmation that proposals were evaluated from Round 2 submissions only, with no Round 1 material improperly carried into the evaluation;
• the Round 2 proposal-submission instructions and any guidance DYCD provided about what could and could not be copied from Round 1;
• and any record addressing whether the Round 2 reissuance and compressed timeline affected the fairness or completeness of the competitive process.

27. Review HHS prequalification and Filed status eligibility for every selected provider

The RFP restricted eligibility to nonprofit organizations with an Approved HHS Prequalification. The RFP states that an organization must have an approved HHS PQL Application by November 7, 2025 to be eligible to submit, and lists this as a minimum qualification requirement, with proposals that fail it deemed non-responsive. Separately, the City's own PASSPort Vendor Admin Checklist states plainly that a vendor's account status must be Filed for contract awards to be processed and registered.

These are not procedural suggestions. They are eligibility conditions for award and registration, stated in DYCD's own RFP and in the City's own vendor guidance. If any selected provider did not hold an Approved HHS Prequalification by the required date, or was not in Filed status when the award was made or the contract submitted for registration, that is a procurement eligibility defect, not a technical paperwork issue.

Before registration, please review and confirm for every selected provider under any disputed contract:
• whether the provider held an Approved HHS Prequalification by November 7, 2025 as the RFP required;
• whether the provider's account was in Filed status in PASSPort before the award was made and before the package was submitted for registration;
• whether all required vendor disclosures, responsibility questionnaires, and PASSPort/VENDEX materials were complete and current at the time of award;
• and whether any selected provider was missing any required eligibility status or disclosure at any point in the procurement-to-award sequence.

Where any eligibility gap exists, please identify it plainly and explain what remediation, if any, DYCD undertook before proceeding to award.

28. Review whether DYCD's six-year client-services awards comply with the multi-term contract requirements of PPB Rule § 2-04

Please also review whether DYCD's use of six-year client-services contracts complies with Section 2-04 of the Procurement Policy Board Rules (9 RCNY § 2-04), which governs multi-term contracts for client services. The RFP states that the anticipated contract term is six years and one month, from August 1, 2026 through August 31, 2032, with no option for renewal. A single committed term of that length, with no renewal mechanism, is precisely the kind of multi-term commitment for which § 2-04 requires a documented determination.

Under § 2-04, a multi-term client-services contract is not the default; it is a specific exception that an agency may use only where doing so is in the City's best interest, on grounds such as continuity of service over more than one year, high contractor start-up costs, or high phase-in and phase-out costs associated with changing contractors. Subsection (c) requires the agency to plan for the use of a multi-term contract; subsection (d) requires the agency to make and approve a determination supporting the multi-term contract; and subsection (e) governs the permitted length of the term. The required determination and the analysis behind it must appear in the contract file.

That creates a serious question here.

DYCD is using six-year client-services contracts, a structure justified by continuity, stable provider relationships, high transition costs, and service linkages, while simultaneously disrupting longstanding school-based ecosystems without publicly releasing the phase-in/phase-out plan, staff-continuity plan, disability-access plan, program-continuity plan, or school-specific transition analysis.

Before registration, please review whether DYCD's contract files include:
• the § 2-04(d) determination supporting the use of a six-year multi-term contract term, with the approvals that subsection requires;
• the analysis of continuity of service supporting that determination;
• the analysis of phase-in/phase-out costs;
• the § 2-04(c) planning documentation for the use of multi-term contracts in these awards;
• the transition plan for schools losing longstanding providers;
• the plan for preserving local partnerships, sports leagues, arts, debate, theater, clubs, and other existing programming;
• the workforce-retention or staff-transition plan;
• the disability-access transition plan;
• and any explanation of how disrupting existing ecosystems is consistent with the continuity rationale that justifies a multi-term award under § 2-04.

The question is not whether DYCD may issue multi-year contracts. The question is whether DYCD made and documented the § 2-04 determination the Rules require before committing the City to a six-year term, and whether that determination can stand when the same awards disrupt the very continuity that justifies a multi-term contract.

29. Review whether DYCD produced the client-services plan and public hearing required by City Charter § 325

COMPASS/SONYC are client-services contracts, which triggers a separate planning obligation under City Charter § 325. Section 325 requires an agency awarding client-services contracts to produce a draft and final plan and schedule detailing its anticipated contracting actions, including the type of services to be provided, the authorized maximum funding, the authorized number of contracts to be let, and the month and year of the next planned competitive solicitation. The agency must also hold at least one public hearing following release of the draft plan and schedule to receive testimony.

We recognize that § 325 provides that failure to include a contract in the plan and schedule is not itself grounds for invalidating the contract. We are not asking your office to invalidate any contract on that basis. We are asking, as a matter of transparency and planning, that the record show DYCD actually treated this as the planned, large-scale client-services portfolio action it was, rather than a series of school-level surprises.

Please produce or confirm the existence of:
• DYCD's draft and final client-services plan and schedule covering the COMPASS/SONYC procurement;
• the record of the public hearing held following release of that draft;
• the authorized funding and authorized number of contracts reflected in the plan;
• the planned competitive-solicitation timeline; and
• any continuity or transition analysis associated with the plan.

30. Review compliance with federal procurement standards, given that afterschool funding includes federal sources

Your office's own June 2025 report, "Stranded After School," identifies the funding sources that support the City's school-based afterschool programs, and they include federal Title I and Title III funds and Child Care Block Grant voucher funding, alongside City and State sources. Where federal funds, or federal funds passed through the State or City, support a contract, the federal procurement standards in the Uniform Guidance (2 C.F.R. Part 200) attach in addition to the City's own rules, and those standards are demanding in exactly the areas at issue here.

Because the precise funding mix for each individual COMPASS/SONYC contract is not public, please first identify every federal, state, and City funding source used for each disputed contract. Then, for any contract that includes federal or federally passed-through funds, please confirm whether DYCD complied with the applicable 2 C.F.R. Part 200 procurement standards, including:
• documented procurement procedures;
• full and open competition;
• written conflict-of-interest standards;
• award only to responsible contractors;
• oversight of contractor performance;
• disclosure of all evaluation factors in the solicitation;
• and records sufficient to detail the history of the procurement, including the rationale for the selection or rejection of each contractor and the basis for the contract price.

Given that your office has already documented federal funding in this program area, the question of whether the federal procurement standards were met is not speculative. If federal funds touch any of these contracts and these records do not exist, that is an independent compliance problem that should be resolved before registration, not after.

31. Review Child Care and Development Fund obligations where CCDF or Child Care Block Grant funds are used

The Child Care Block Grant your office identified is part of the federal Child Care and Development Fund, administered through the State. Its governing law, reauthorized in 2014 and implemented through the 2016 and 2024 Final Rules, imposes binding health, safety, background-check, and continuity-of-care requirements on providers serving subsidized children, and noncompliance with the background-check requirements alone authorizes the federal government to withhold five percent of the State's CCDF funds until corrected.

For any disputed contract that CCDF or Child Care Block Grant funds touch, please review whether the contract file contains:
• documentation that each selected provider meets the CCDF health and safety requirements across the mandated topic areas;
• comprehensive criminal background-check records for all staff with unsupervised access to children, consistent with 42 U.S.C. § 9858f;
• pre-licensure and annual unannounced inspection records;
• group-size and child-to-staff ratio documentation;
• emergency-preparedness and disaster plans;
• and any analysis of how the provider transition preserves continuity of care, which the CCDF reauthorization treats as a central federal objective and which bears directly on the displacement of longstanding providers.

32. Review Title I, Part A obligations where Title I funds are used

Title I funds carry both a supplement-not-supplant requirement and a binding parent-and-family-engagement mandate. Under the Every Student Succeeds Act, supplement-not-supplant is measured by whether the local educational agency maintains a written methodology ensuring each Title I school receives all the state and local funds it would have received regardless of its Title I status. Separately, Title I requires that parents be involved in an organized, ongoing, and timely way in the planning, review, and improvement of programs, and that schools jointly develop a school-parent compact.

For any disputed contract that Title I funds touch, please review whether the file contains:
• the written supplement-not-supplant methodology applicable to these funds;
• the Title I parent-and-family-engagement policy and the school-parent compact for each affected school;
• documentation of how parents were involved in the planning, review, and improvement of the program, including the provider transition;
• and any record reconciling the exclusion of families from provider selection with the Title I parent-engagement requirement.

33. Review Title III, Part A obligations where English-learner funds are used

Title III is the only federal funding stream designated for English learners, and it is bound by a strict supplement-not-supplant rule: using Title III funds to purchase for English learners the same resource provided to other students from state, local, or other federal funds is supplanting. Allowable uses include after-school tutoring for English learners and family and community engagement. English learners are also protected by federal civil-rights law independent of funding source.

For any disputed contract that Title III funds touch, please review whether the file contains:
• identification of the English-learner-specific supplemental services the Title III funds purchase, tracked separately from base programming;
• documentation demonstrating supplement-not-supplant compliance for those services;
• at schools with significant English-learner or multilingual-learner populations, the incoming provider's workscope showing whether the English-learner-specific services delivered by the prior provider were preserved;
• any analysis of English-learner service continuity in the award decision;
• and confirmation of compliance with federal civil-rights obligations to English learners and their limited-English-proficient parents, including the obligations addressed in the joint Department of Education and Department of Justice guidance.

34. Review 21st Century Community Learning Centers obligations where Title IV-B funds are used

21st Century Community Learning Centers funding, authorized under Title IV, Part B, is the only federal funding source dedicated exclusively to out-of-school-time programs. It requires competitive selection, an independent external evaluation issued annually, ongoing family engagement, and supplement-not-supplant compliance, and it carries explicit obligations to provide children with disabilities an equal opportunity to participate.

For any disputed contract that 21st Century Community Learning Centers funds touch, please review whether the file contains:
• the competitive application and award records for the subgrant;
• the most recent independent annual external evaluation for each affected program;
• documentation of the required ongoing family-engagement activities;
• supplement-not-supplant documentation;
• and the records demonstrating equal-opportunity participation for children with disabilities.

35. Records we ask the contract file to contain before registration

To allow the questions in this letter to be assessed against an actual documentary record rather than assumed, we ask that, before registration, the contract file for each disputed contract contain, and that your office be able to confirm the presence of, the following.

On funding and its conditions:
• identification of every federal, state, and City funding source for the contract, by name and amount, with the Assistance Listing number and pass-through entity for any federal funds;
• the share of the contract attributable to each source;
• and all grant agreements, nondiscrimination assurances, accessibility assurances, and reporting requirements applicable to those funds.

On procurement integrity and disclosure:
• evaluator conflict-of-interest statements;
• vendor responsibility documentation, including PASSPort/VENDEX materials;
• Doing Business Database disclosures for the selected providers;
• lobbying contacts and registrations concerning the awards;
• any Conflicts of Interest Board screening relevant to the procurement;
• and communications concerning the awards between DYCD and City Hall, MOCS, elected officials, or the selected and displaced providers.

On scoring and award:
• the published evaluation criteria and their numeric weights;
• the rating sheets and the point breakdown by criterion for the selected and displaced or principal-preferred providers;
• the Recommendation for Award and the responsibility determination;
• any documentation of how and where principal input was captured and used, given that the only ranking mechanism in the RFP was proposer self-ranking not shared with principals;
• the vendor protest determinations;
• and any written definition and application of "provider diversity."

On the procurement design rationale:
• all records, memoranda, emails, meeting notes, drafts, analyses, and internal communications concerning the decision to exclude host-school letters of support, Community Partnership Agreements, and School Partnership Agreements from the proposal stage, including any discussion of incumbent-provider advantage, school or principal influence, provider diversity, competition fairness, provider concentration, and the intended role of principals, superintendents, NYCPS advisors, PTAs, SLTs, or school communities in provider selection;
• all records comparing the prior COMPASS/SONYC procurement to the 2025/2026 RFP, including any changes to the role of School Partnership Agreements, principal input, school letters of support, incumbent performance, provider ranking, community partnerships, staff resumes, school-specific budgets, and post-award partnership requirements.

On the principal-ranking process:
• all records concerning the informal principal-ranking process conducted outside the formal scored RFP, including the instructions given to principals, the forms used, the results produced, how the results were transmitted to DYCD, how they were weighted in award decisions, and any communications instructing principals to keep the process confidential from parents, PTAs, SLTs, or CECs;
• any written methodology showing how principal input was weighted relative to competitive scoring, provider diversity, and capacity;
• and any school-specific documentation explaining why the award diverged from the principal’s stated preference.

On provider concentration and the application of provider diversity:
• all records defining "provider diversity" as used in this procurement, including any instructions in Attachment 02, any scoring guidance, and any post-scoring allocation guidance;
• all records showing how provider diversity was applied to produce the final award distribution, including any analysis of whether the resulting portfolio is more diverse than the prior one;
• and all records explaining how awarding approximately 88 school-level programs to a single provider is consistent with a provider-diversity rationale, given that New York Edge held the largest prior COMPASS contract portfolio by dollar (approximately $82 million) and holds the largest 2026 award portfolio by school count.

On the subcontractor minimum change:
• all records explaining the decision to remove the concept paper’s proposed ten percent minimum subcontractor requirement from the final RFP, including any analysis of the impact on smaller, specialized, neighborhood-based, or MWBE providers;
• and any analysis of whether the absence of a subcontractor minimum is consistent with DYCD’s stated equity and provider-diversity goals.

On HHS prequalification and Filed status:
• for every selected provider under any disputed contract, confirmation of HHS prequalification status at the time of proposal submission and Filed status at the time of award;
• and any records showing remediation where a provider was missing required eligibility status or disclosures at any point in the procurement-to-award sequence.

Where any required record does not exist, we ask that this be stated plainly rather than the item omitted, since the absence of a required record is itself relevant to whether a contract should be registered.

Summary of what we are asking your office to verify

Before registering any disputed COMPASS/SONYC contract, please confirm that:

0. The administrative record bridges the structural evidence gap described above: the contract file contains school-specific documentation sufficient to support DYCD's public claims of school fit, principal voice, staffing readiness, inclusion capacity, and program continuity, given that the procurement did not require host-school support letters, did not include principal rankings, required only one budget narrative per competition, counted paid subcontractors as community partnerships, deferred individual site budgets to post-award workscope development, and did not require named staff before award.
1. DYCD followed the required procurement rules.
2. Evaluation criteria were disclosed and consistently applied.
3. Evaluators were qualified and conflict-free.
4. Rating sheets and award recommendations exist and support the outcomes.
5. The basis for principal input is documented: the formal RFP ranking mechanism was proposer-only and not shared with principals; any separate informal principal-ranking process is disclosed, its methodology is documented, and its weight in the award decision is explained school by school.
6. Provider diversity was defined, disclosed, and lawfully applied.
7. Prior performance and site-specific experience were considered appropriately.
8. Vendor protests were processed with reasoned written determinations.
9. Public notice and comment requirements were satisfied where applicable.
10. Registration packages are complete.
11. Vendors were determined responsible based on qualifications, capacity, and business integrity at the specific awarded site, not merely on HHS prequalification status.
12. Final workscopes and budgets support the services children are supposed to receive.
13. Licensing and implementation plans are realistic.
14. Disability-access obligations are enforceable, written, and site-specific, with named Inclusion Coordinators and documented coverage plans.
15. Workforce and staff-continuity issues were considered.
16. The process was free of corruption, conflicts, or undisclosed decision-making.
17. The administrative record is sufficient to support registration.
18. DYCD and the selected providers fulfilled the RFP's own inclusion, accessibility, individualized-assessment, resource-request, Inclusion Coordinator, accessibility-training, de-escalation, referral, and site-specific crisis-navigation requirements.
19. DYCD's use of six-year client-services contracts is supported by the determination and analysis that PPB Rule § 2-04 requires, including continuity, phase-in/phase-out, and planning documentation.
20. The disclosed numeric evaluation weights actually reconstruct the award outcomes from the rating sheets.
21. MWBE participation goals, utilization plans, waivers, and subcontractor compliance are documented and verified.
22. The § 327 certification of legal authority and procedural requisites is complete, truthful, and supported by the underlying documentation.
23. Disability-access obligations under the ADA, Section 504, and the City and State Human Rights Laws appear as enforceable material terms, not general assurances.
24. DYCD produced the client-services plan, schedule, and public hearing required by City Charter § 325 for this portfolio of awards.
25. The Round 2 reissuance record is complete: the addendum documents what changed, all applicants received equal notice and time to respond, and the registration package is built on Round 2 submissions only with no Round 1 material improperly considered.
26. Given that afterschool funding includes federal Title I, Title III, and Child Care Block Grant sources, DYCD complied with the 2 C.F.R. Part 200 procurement standards for any contract that federal funds touch.
27. For any contract CCDF or Child Care Block Grant funds touch, the provider meets the federal health, safety, background-check, inspection, and continuity-of-care requirements.
28. For any contract Title I funds touch, the supplement-not-supplant methodology and the parent-and-family-engagement requirements are documented.
29. For any contract Title III funds touch, English-learner-specific supplemental services and their continuity are documented and supplement-not-supplant is met.
30. For any contract 21st Century Community Learning Centers funds touch, the competitive selection, independent annual evaluation, family engagement, and disability-access records exist.
31. The contract file contains the procurement-design rationale records demanded in section 35: the documented basis for removing school partnership from the proposal stage, and any comparison of this procurement to prior COMPASS/SONYC procurements.
32. The record documents the NYCPS advisor ranking process for each disputed school: who served as the advisor, whether it was the principal, the ranking submitted, whether the school participated within the prescribed timeframe, and how DYCD weighed or departed from that ranking, along with any records of a separate closed-door principal-ranking process and instructions to keep it confidential.
33. The record explains how the award outcome for New York Edge, which held the largest prior COMPASS contract portfolio by dollar (approximately $82 million) and holds the largest 2026 award portfolio (approximately 88 school-level entries), is consistent with a provider-diversity rationale, including any written definition of provider diversity and any portfolio analysis supporting the outcome.
34. The record explains the removal of the concept paper’s ten percent minimum subcontractor requirement, including any analysis of impact on smaller, MWBE, and neighborhood-based providers.
35. Every selected provider was HHS prequalified at the time of proposal submission and in Filed status at the time of award, and any eligibility gaps are documented and remediated.
36. For each disputed school, the file contains the record supporting DYCD's exercise of the Attachment 02 discretion to decline the highest-scoring proposal, cap a provider's awards, or allocate for provider diversity, capacity, or distribution, including a written rationale wherever an award did not follow the highest score or the NYCPS advisor ranking.
37. Each disputed package contains the codified School Partnership Agreement and proof of insurance that Attachment 02 makes conditions of award, and any package missing either is returned as incomplete.
38. The record shows that DYCD's contractor-selection criteria accounted for the disability-access consequences of provider replacement, consistent with the ADA Title II prohibition at 28 C.F.R. 35.130 on selection criteria and methods of administration that have the effect of discriminating against students with disabilities.
39. For any disputed school serving a specialized or high-disability population, the record contains a site-specific, pre-award evaluation of the selected provider's capacity to serve that population, rather than a generic competition-level proposal and two short partnership-profile fields.
40. The disability-access record reflects the RFP's family-facing accommodation requirements, so that access for parents and guardians with disabilities, not only students, is accounted for.

A note on the standard of review

We are asking your office to apply the standard the registration process exists to support: confirmation that the administrative record is sufficient to show that these awards were not arbitrary or capricious, were rationally supported, and complied with applicable law, so that the record could withstand review under Article 78 of the Civil Practice Law and Rules. This is not a threat of litigation. It is the substance of what registration review protects. Where the record is incomplete now, registering the contract does not cure the defect; it simply moves the dispute downstream, where unwinding an implemented six-year contract is far more disruptive to children and schools than completing the record today. We note as well that the public-accommodation provisions of the City Human Rights Law are themselves enforceable against public agencies through Article 78, which is one more reason the disability-access obligations described above should be verifiable in the record before registration.

Specific requests to your office

We respectfully request that the Comptroller's Office:

0. Review whether the administrative record bridges the structural evidence gap described above: the contract file must contain school-specific documentation sufficient to support DYCD's public claims of school fit, principal voice, staffing readiness, inclusion capacity, and program continuity, given that the procurement excluded host-school support letters and School Partnership Agreements, used a formal ranking mechanism that was proposer-only and not shared with principals (with any separate informal principal-ranking process undisclosed and of undefined weight), required only one budget narrative per competition, deferred individual site budgets to post-award workscope development, allowed paid subcontractors to count as community partnerships, and did not require named staff before award. If that documentation is absent, the public defense DYCD has offered is not supported by the administrative record.
1. Confirm whether disputed COMPASS/SONYC contract packages have been submitted for registration.
2. Identify which packages are pending, including PINs, vendors, schools/sites, submission dates, and current status.
3. Confirm that your office will review the complete procurement record before registration.
4. Confirm that DYCD's vendor protest decisions will be included and reviewed.
5. Return or object to any package lacking required procurement documentation, responsibility determinations, protest records, worksite-specific budgets, procedural certifications, or evidence of compliance.
6. Refer any integrity, conflict, corruption, or documentation concerns to the appropriate oversight body, including DOI where appropriate.
7. Provide families and CECs with a written explanation of what your office reviewed and what registration status was assigned to the disputed contracts.
8. Identify a point of contact for families, CECs, PTAs, providers, and school communities submitting registration-relevant evidence.
9. Confirm that the registration package includes enforceable site-specific inclusion/accessibility obligations, including named Inclusion Coordinators, individualized assessment procedures, disability-resource request procedures, accessibility training, and crisis-navigation plans.
10. Confirm that DYCD's six-year contract term is supported by the § 2-04(d) determination and the continuity, phase-in/phase-out, and planning analysis that PPB Rule § 2-04 requires, and consider the impact on fragile or difficult-to-serve student populations.
11. Use the full time available under City Charter § 328 and decline to register any disputed package until the procurement record is verified.
12. Advise DYCD not to take irreversible implementation steps, including staff terminations, displacement of existing programming, or parent-facing transition actions, while review of disputed packages is pending.
13. Open a separate performance audit of the COMPASS/SONYC procurement and its implementation under City Charter § 93.
14. Confirm that the disclosed numeric evaluation weights reconcile with the actual award outcomes for each disputed contract.
15. Confirm that MWBE participation and subcontractor compliance documentation is present and verified.
16. Confirm that the § 327 certification of legal authority and procedural requisites is complete, truthful, and supported by documentation.
17. Confirm that disability-access obligations under the ADA, Section 504, and the City and State Human Rights Laws are incorporated into the final contracts as enforceable material terms.
18. Confirm that the record for each disputed award is sufficient to withstand review under Article 78 as non-arbitrary, rationally supported, and compliant with law.
19. Produce or confirm DYCD's § 325 client-services plan, schedule, and public-hearing record for the COMPASS/SONYC procurement.
20. Produce the Round 2 addendum and change log, confirm that all applicants received equal notice and opportunity to respond to the Round 2 changes, and confirm that the registration package reflects Round 2 submissions only.
21. Identify every federal, state, and City funding source for each disputed contract, and for any contract that federal funds touch, confirm compliance with the 2 C.F.R. Part 200 procurement standards.
22. For any contract CCDF, Title I, Title III, or 21st Century Community Learning Centers funds touch, confirm that the source-specific federal obligations are documented in the contract file.
23. Demand the procurement-design rationale records identified in section 35: the documented basis for removing School Partnership Agreements from the proposal stage, and all records comparing this procurement to prior COMPASS/SONYC procurements.
24. Confirm that the contract file states plainly where any required record does not exist, since absence of a required record is itself relevant to whether a contract should be registered.
25. Demand all records of the informal principal-ranking process conducted outside the formal scored RFP, including instructions to principals, ranking forms, results, weighting methodology, and any communications instructing principals to keep the process confidential from parents, PTAs, SLTs, or CECs.
26. Demand all records defining and applying “provider diversity” in this procurement, including any written analysis explaining how the award outcome for New York Edge, which held the largest prior COMPASS contract portfolio by dollar and holds the largest 2026 award portfolio by school count, is consistent with a provider-diversity rationale.
27. Demand all records explaining the removal of the concept paper’s ten percent minimum subcontractor requirement, including any equity and MWBE impact analysis.
28. Confirm that every selected provider was HHS prequalified at the time of proposal submission and in Filed status at the time of award, and identify any provider where either condition was not met.
29. Require DYCD to identify every disputed school at which the selected provider was not the highest-scoring proposer, not the NYCPS advisor's first-ranked provider, or not the incumbent, and to produce the written, school-specific basis on which it applied the Attachment 02 discretion to decline the highest score, cap awards, or allocate for provider diversity, capacity, or distribution.
30. Confirm, for each disputed package, that it contains the codified School Partnership Agreement and proof of insurance that Attachment 02 makes conditions of award, and return as incomplete any package missing either.
Where the School Partnership Agreement is not codified at a disputed school, require DYCD to identify the documented next step in the award process, including whether a next viable provider was available or was capped or passed over through provider-diversity, capacity, or distribution discretion.
31. Require DYCD to show that its contractor-selection criteria evaluated the disability-access consequences of displacing incumbent providers, and review whether the selection method is consistent with 28 C.F.R. 35.130.
32. For any disputed school serving a specialized or high-disability population, require DYCD to produce the site-specific, pre-award evaluation of the selected provider's capacity to serve that population, including staffing, training, communication access, accommodation continuity, and transition planning.
33. Confirm that the disability-access record accounts for access by parents and guardians with disabilities, consistent with the RFP's family-facing accommodation requirements and the public entity's direct obligations under the ADA and Section 504.

Closing

This is not a request for your office to take over DYCD's role.

It is a request that your office fully exercise its own registration authority at the moment when that authority matters most.

Three verified findings from the public record frame everything in this letter.

First, DYCD redesigned a procurement in a way that excluded the evidence most favorable to successful embedded providers: host-school support letters, school partnership agreements, actual named staff, and school-specific budgets. DYCD then defended the awards using school-specific claims that the procurement’s own structure was incapable of generating. Whether or not the design choice was legitimate, DYCD must produce the documented rationale for it, and the contract file must show that the evidence DYCD is publicly asserting was actually collected before award.

Second, Attachment 02 confirms that DYCD reserved broad discretion to allocate awards on grounds other than score, including the express right not to award the highest-scoring proposal if the proposer had already won elsewhere, the right to cap any provider's footprint, and the right to distribute awards for provider diversity, capacity, and geographic balance. DYCD's own document states that a high score is not a guarantee of award. That discretion is lawful only if it was exercised rationally, consistently, and on a documented basis. For each disputed school, DYCD must produce the record showing how it used that discretion.

Third, Attachment 02 makes a codified School Partnership Agreement and proof of insurance express conditions of award. Your office's registration clock begins only on a complete package, and an incomplete package may be returned. Any disputed package that lacks the codified School Partnership Agreement or the required insurance is, by DYCD's own terms, not complete.

These verified facts define the question your office’s review must answer: does the administrative record support DYCD’s public defense and satisfy DYCD's own conditions of award, or does the public defense outrun the file?

These contracts will shape afterschool services for six years. They affect working families, students with disabilities, school communities, frontline workers, and public funds.

Once contracts are registered and implemented, the practical harm will be much harder to reverse.

Before registration, the City still has an opportunity to ensure that the process was lawful, documented, transparent, and worthy of public trust.

Thank you for your attention and for your commitment to accountability, transparency, and responsible stewardship of public funds.

Sincerely,

Jamie Parganos
[phone]
[email]
Parent / affected school community member

Suggested attachments

1. CEC resolutions
2. School-by-school affected-site tracker
3. Parent impact statement summary
4. Disability-access concerns summary
5. Provider protest / appeal status list, if available
6. Press and public testimony index
7. Requested records list / procurement-document checklist