Nailing Shut the Policy Window : The Policy Evolution of America ’ s First Urban School Voucher Program

This article describes the origins and evolution of the Milwaukee Parental Choice Program, arguing that voucher policy in Milwaukee continues to exist long after the policy window that enabled its creation closed. The author, using the framework of public policy windows, concludes that under certain conditions untested policy initiatives can lead to policy paralysis. The study is of interest to legislators considering new and untested policy initiatives, program evaluators, and scholars interested in the history of school voucher policy.

This article takes a case study approach using the case of the MPCP to argue that under certain circumstances, public policies can exist long after the policy windows that enabled their creation closed, which leads to a policy paralysis and inability to address an ongoing public policy concern.Specifically, the author answers the question, "What happens when a policy window closes.But the policy itself cannot be eliminated for pragmatic reasons?" by: 1) Providing background on the MPCP; 2) Presenting a historical account of the origins of the Milwaukee voucher program; 3) Explaining how and why the policy window for voucher reform as a viable approach to Milwaukee's educational struggles closed; 4) Explaining why voucher policy in Milwaukee outlived the existence of the policy window that first enabled its creation; and, 5) Analyzing the repercussions of the policy paralysis regarding the educational challenges facing Milwaukee.

What is the MPCP?
In its most technical definition, the MPCP is a state program that allows Milwaukee students from families with household incomes at or below 300% of the federal poverty level to attend a qualifying private school at state expense (Kava, 2013).Qualifying schools are those that choose to participate, agree to accept students via random selection, receive accreditation from an entity approved in the Wisconsin state statutes, agree to accept the maximum voucher amount as full payment, and meet a variety of other fiscal and academic criteria (Kava, 2013).However, in reality, the MPCP is, and always has been, different things to different audiences.This is a key point, as the MPCP was always more complex than a policy response to poor academic performance.

MPCP as Education Reform
Before the program began, the MPCP was heralded as an education reform designed to improve academic outcomes.Then President George H.W. Bush spoke of the academic potential of the MPCP, stating: "When schools compete to attract students, that can't help but to improve education" (Ahlgren, 1990).A state mandated academic evaluation conducted over the first five years of the program's existence, as well as a more recent five-year study completed in 2011, support the claim that the MPCP is designed to be a program that improves academic outcomes (Witte et al, 2012).In fact, in 2013, the Wisconsin Department of Public Instruction (DPI), which oversees the operation of the MPCP, advocated against expanding the program on the grounds that it does not improve academic achievement (DPI, 2013).This position spurred strong reaction among advocates of school choice in Milwaukee, who claimed that the program does in fact improve academic outcomes (School Choice Wisconsin (SCW), 2013).Whether or not the Milwaukee voucher program is improving outcomes at a level that justifies its existence is debatable.Lubienski et al. (2009) concluded there is no consensus on the effects of voucher policy in Milwaukee or elsewhere.The argument of Powers & Cookson, Jr. (1999), that politics make untangling school voucher research uniquely difficult, have proved true.Despite studies finding slight reading gains and graduation rate advantages for voucher users (Cowen et al., 2013), it is clear that after over two decades of voucher policy, Milwaukee students are still struggling academically (Andersson & Ford, 2014).On aggregate, Milwaukee children trail most of their big city peers on the Trial Urban National Assessment of Educational Progress (National Center for Education Statistics, 2011).Despite the lack of consensus on the academic effects of the MPCP, the willingness of supporters and opponents alike to point to academic data when making their case illustrates that the MPCP is designed, in part, to be an education reform.

MPCP as Cost-Savings
The MPCP can also accurately be described as a cost saving reform.Robert Costrell (2011) concluded that the MPCP saves Wisconsin taxpayers over $50 million annually.Because the maximum voucher amount is considerably less than the combined state and local support for students in MPS, state taxpayers send less education dollars to Milwaukee when a student who otherwise would have attended MPS uses the MPCP.The positive statewide financial impact of the MPCP is a reason Republican legislators representing districts nowhere near Milwaukee have consistently supported the MPCP (Witte, 2000;Richards, 2014).Throughout the MPCP's history, the political debate over the MPCP was driven partly by fiscal issues unrelated to the academic effects of the voucher program (Costrell, 2011).The prominent role of cost savings in the policy debate suggests that Percy and Maier's (1996) argument that vouchers are a form of privatization less premised on public cost savings, did not play out in reality.As more evidence surfaces that the aggregate academic effects of the MPCP are modest at best, pro-voucher arguments increasingly focus on the increased efficiency of the MPCP, (i.e., the same outcomes for a lower cost) (Carlson, Cowen, & Fleming, 2013;Cowen et al., 2013).Whether this is a bait and switch among program advocates, or a wise policy evaluation criterion, it is evidence that the success or failure of voucher policy is, in the political discourse, tied to the issue of cost savings.

MPCP as Entitlement
The MPCP has also been described as an entitlement program.Though the MPCP began as an experiment where parents directed funds to private schools, over its existence, it has evolved into an alternative form of public education for Milwaukee students.The high degree of switching between MPCP and MPS schools, in addition to the similar demographic and aggregate performance profiles of the two groups, suggest that Milwaukee school consumers view both sectors in much the same way (Witte et al., 2012;Howell, 2013).A 2013 letter from the United States Department of Justice to DPI formalized the viewpoint that MPCP schools are actually public institutions by advising that schools in the program be treated like public schools in regard to tracking the enrollment of, and services provided to, participating special needs pupils (Bhargava, Wohlenhaus & Fischbach, 2013).
Public, private, or somewhere in between, the MPCP is a significant provider of publicly funded education to a primarily minority low income slice of Milwaukee students.Parents whose children use vouchers report high levels of satisfaction with the MPCP, despite its documented performance shortcomings (Teske, Fitzpatrick, & Kaplan, 2007).The heated political battles over the MPCP, fueled in part by program parents, are further evidence that the MPCP is a large and important entitlement program to many Milwaukee families.

MPCP as Politics
The MPCP was borne of an awkward and short-lived alliance between African American Democrats and white Republicans (Witte, 2000;Dougherty, 2004).Today, the school choice lobby in Wisconsin boasts three former speakers of the state assembly, and is on par in influence with the state teachers union (Lueders, 2011).It follows that the program has, since its creation, been a political football (Staff, 1998).At the height of its functioning, the MPCP serves as a vehicle for dueling political groups to project their deepest suspicions of true intent upon one another.
Public policies are responses to problems, and while the development of voucher policy in Milwaukee indicated dissatisfaction with the city's current public school system, there was (and still is) a lack of consensus on what specific problem the MPCP was designed to solve (Lindblom, 1959;Cohen, March, & Olsen, 1972;Kingdon, 1995).If the MPCP is so many things to so many different people, how can the overall value of the program objectively be evaluated, and how can shortcomings of voucher policy be addressed by new or changed public policies?To answer this question, it is necessary first to look back in a historical account of the opening of the policy window for vouchers in Milwaukee.

Opening the Policy Window for the MPCP
As previously stated, policy windows open when a set of circumstances and actors come together to provide an opportunity to address a public concern with a new public policy (Kingdon, 1995).It was a set of changing circumstances in Wisconsin that led to the June 8, 1990 signing of Wisconsin Assembly Bill 25 by Wisconsin Governor Tommy Thompson (Witte, 2000).That bill, a budget adjustment bill, created a capped voucher program for nonsectarian schools.Its passage signified both a new era for public education in Milwaukee, and the end of a process that opened the policy window for Milwaukee's voucher policy.
Milton Friedman is credited with first proposing the use of school vouchers in a 1955 book chapter (Friedman, 1955).Friedman argued that private markets are better positioned to regulate the delivery of public education than government oversight.For years, Friedman's theory had not been put to any real-world test.In Milwaukee, however, a series of events in the decades prior to the implementation of any school voucher programs in the United States opened the policy window, allowing Friedman's theory to be turned into a reality.One of those events was the longsimmering legal battle over segregation in MPS.That battle, led by Milwaukee attorney Lloyd Barbee, resulted in the creation of Wisconsin's Chapter 220 voluntary racial busing plan, and laid the groundwork for African American support of the original MPCP (Dougherty, 2004).But the perfect storm enabling vouchers was more than the events enabling the interracial alliance supporting the program's creation.
Frustration over the ability of MPS to reform from within played a key role in making an outside reform like school vouchers a realistic possibility for Milwaukee.A 1975 account of an effort by a University of Wisconsin-Milwaukee education expert to work with MPS reveals the huge disconnect between the MPS board and outsiders at the time.The expert, Robert Ingle, proposed that each MPS board member list "the seven most pressing problems in the school system."The simple proposal degraded into "almost an hour of bickering and arguing among the board members" which prompted Ingle to leave the meeting (Editorial Board, 1975).Additional accounts from Milwaukee newspaper archives reveal that conflict between board members and between board members and the superintendent was commonplace in the early 1980s (Bednarek, 1980;Hurley, 1980).The editorial board of the Milwaukee Journal frequently chided the MPS board, using descriptions such as "schizophrenic" and "bitterly divided" (Editorial Board, 1984;Editorial Board, 1986).
Equally evident in the journalistic accounts of MPS in the 1980s was a growing frustration with the academic performance of Milwaukee students.The initial frustration with MPS came not just from the low levels of achievement in the district, but also from an attempt by the district administration to hide its struggles.A 1980 analysis of reading scores in the Milwaukee Sentinel found that, contrary to MPS claims, the district was performing well below national averages (Staff, 1980).Though then MPS superintendent Lee McMurrin slammed the paper's reporting, the episode spelled the end of the district's practice of placing its students' performance into the three vague categories of above average, average, and below average (Samuels, 1980).
In the following years, the Milwaukee Sentinel editorialized about MPS under headlines calling MPS' failures "appalling," and placing blame on individual schools for "refusing to challenge students" (Editorial Board, 1981;Editorial Board, 1982).The middle of the decade brought accounts of increased programming, bold plans, and efforts such as decreasing class sizes to improve achievement in Milwaukee (Stanford, 1985).By the late 1980s, a noticeable shift away from internal MPS reform plans, and towards non-MPS solutions to Milwaukee's education struggles occurred.In 1987, activist Howard Fuller, along with State Representatives Polly Williams and Spencer Coggs, led the charge to create a new school district on the north side of Milwaukee centered around the mostly African American North Division High School (Bendarek, 1987).Though that specific effort failed, it was a precursor to a defeated voucher proposal in 1988, and the eventual successful passage of the bill creating the MPCP (Witte, 2000).Also important to the development of the MPCP was the presence of the Lynde and Harry Bradley Foundation in the City of Milwaukee.The foundation, a strong supporter of conservative causes like school choice, was well positioned to provide the infrastructure necessary to support a burgeoning school choice movement in its own backyard.
The frustration over low academic achievement, the public perception of a school district unable to reform itself, the long-simmering perceived alienation of Milwaukee's African American community from a non-responsive MPS bureaucracy, and a willing set of strong personalities like Governor Tommy Thompson, Howard Fuller, Polly Williams, and State Senator Gary George, combined to make Friedman's theoretical policy idea a palatable policy option (Dougherty, 2004;Kingdon, 1995).No less important to the enactment of the MPCP was the influence of program design.The limited scope of Milwaukee's initial voucher program, described as a pilot program, also contributed to its passage (Witte, 2000).The original MPCP was:  Capped at 1% of MPS enrollment, which in 1990 meant no more than about 920 pupils could use the program;  Restricted to families with household incomes at or below 175% of the federal poverty level;  Restricted to schools enrolling at least 51% tuition-paying pupils;  Limited to students currently in public schools or new to school; and,  Limited to nonsectarian schools.
These limitations ensured that the MPCP would not be a significant threat to MPS' market share.Though the program was new, legislators could accurately describe the program as an experiment rather than a significant policy shift.The inclusion of a state-mandated program evaluation furthered the ability for tepid supporters to frame their initial support as a simple willingness to try to something new.But over the next twenty years, the reality on the ground shifted considerably.The size, scope, regulation, support, and critiques of the program grew to the point where today.The MPCP has become a part of the status quo of public education in the city of Milwaukee.

Closing the Policy Window
That the MPCP ever became law is somewhat remarkable.Twenty-five years later, only a handful of urban areas in the United States have a private school voucher program, and none approach the scope and size of the MPCP.Indeed, at its inception the MPCP was revolutionary.It was new, trendy among policy wonks and media, and held great promise as a "disruptive innovation," i.e., an education reform that can disrupt a long-entrenched education system decades before the term "disruptive education" was popularized (Christensen et al., 2008).Much of the initial excitement surrounding the introduction of voucher policy in Milwaukee was driven by the near universal promise of school vouchers.Any new public policy contains potential downsides such as high startup costs, implementation challenges, regulatory difficulties, etc. (Kingdon, 1995).But, the MPCP appeared to be all upside.At the time of passage, it was mostly taken for granted that the private schools in the MPCP would outperform public schools in Milwaukee (Chubb & Moe, 1990;Witte, 2000).Even skeptics arguing that private schools might cream the best students or not adequately represent civic values did not question the expected achievement advantage for private schools (Witte, 2000).Proponents argued that the new program would not only not harm public schools, but force them to improve through market competition.This point of view was reinforced by John Chubb and Terry Moe's influential book, Politics, Markets, and America's Schools, released near the time of the MPCP's enactment (Chubb & Moe, 1990).The basic idea was that districts could no longer afford to be complacent with low income parents.If parents were not satisfied with their current public schools, they could use a voucher to attend a private school at state expense.MPS would inevitably respond to the loss of market share by responding to parental needs and improving their quality of instruction.Thus, vouchers were not just a mechanism to give low income pupils more opportunity, they were a way to improve public schools without wading too deeply in the morass of classroom level reforms.And cost?The MPCP in 1991 cost Wisconsin taxpayers $2,446 per pupil, far less than the $5,748 per pupil cost of a MPS pupil (Greene, Peterson, & Du, 1999;Kava, 2013).Meaning, each time a student attended a private school via a voucher instead of MPS, advocates could claim a $3,302 savings to state of Wisconsin taxpayers.As can be seen in Figure One, the comparative state and local cost of the MPCP has consistently been well below that of the MPCP (Costrell, 2009).The task of regulating the new program also promised to be far less complicated than the high level of oversight of Wisconsin public schools.Though the original MPCP did require schools to meet one of four chosen accountability objectives in the areas of parental involvement, attendance, academic progress and grade level advancement, the program promised a new market-based approach to school regulation (Witte, 2000;Kava, 2013).It was assumed parents would not send their children to low-performing schools, so little need was seen for expansive input regulations.In all, the MPCP was thought to be a true panacea for urban education.
It did not take long for the reality of the challenges of urban education to collide head on with the expectations of the most fervent free market education advocates.The first official evaluation of the MPCP, released in November 1991, found that students using vouchers did not outperform MPS pupils.The evaluation's author, John Witte, wrote: "This program is not now, nor probably will it ever be, the answer for the extensive and complex problems associated with providing a quality education for Milwaukee children" (Ahlgren, 1991B;Witte, 1991).Further, DPI released statistics showing that 155 of the 259 pupils who used the MPCP for the entirety of its first year of operation were no longer using it in its second (Ahlgren, 1991A).But despite the high program attrition, overall enrollment in the program increased to 521.The high rate of program turnover, and underwhelming effects on academic achievement identified in the first year of the MPCP, poked holes in some of the initial premises of the program, and also foreshadowed much of the $0.00 $2,000.00$4,000.00$6,000.00$8,000.00$10,000.00$12,000.001991 1992 1993 1994 1995 1996 1997 1998 program's future.First, Witte's finding revealed that a higher rate of performance in Milwaukee private schools was no sure thing.Like public schools, private schools could offer a range of quality, and were not insulated from the factors contributing to low achievement in MPS.Second, the high rate of attrition combined with increasing enrollment undermined the pure market principles on which the MPCP was based.It could not be assumed that the free market could adequately regulate private schools if schools had a steady pool of new customers to replace the majority of dissatisfied customers.This situation suggested that some parents were making decisions based on frustrations with their current environment rather than enthusiasm for their chosen private school.
Under this backdrop, the MPCP experienced its first school closure when the Juanita Virgil Academy declared bankruptcy and folded in the middle of the 1990-1991 school year (Witte, 2000).This occurrence, too, foreshadowed the many MPCP school closures that would occur over the next two decades (Ford, 2011).Though the failure of some businesses is to be expected in a functioning marketplace, the disruption caused by the failure of a publicly funded school in the middle of the year was not seriously considered before it actually happened in 1991.
Lower than hoped for achievement, a closed school, high student attrition, low overall enrollment, a lawsuit, and constant political battling, made the first two years of the MPCP a less than ideal policy experiment.Though there were bright spots, including high levels of parental satisfaction, the initial implementation of the MPCP was a messy affair that killed off any illusions of it being a silver bullet for urban education.The alliance between white Republicans and African American Democrats eroded quickly, with key supporters such as Representative Annette Williams withdrawing their support for the program (Witte, 2000;Dougherty, 2004).By 1995, the conditions that led to the creation of the MPCP, including the hope that it could serve as a panacea for Milwaukee's education struggles, had disappeared.
However, voucher policy continued to exist, and evolve, after the policy window first enabling its enactment had closed.The closing of the policy window for the MPCP was, and still is, problematic.Despite the diversity of hopes and expectations for the MPCP, various interest groups and audiences at the time of its inception were, at the very least, united in their belief that the program should exist, and could be a vehicle to solve various policy woes.The collapse of the alliances leading to the original MPCP splintered its original supporters into camps with differing views on program regulation, size, structure, and even existence.To put it another way, rather than working collectively to make the MPCP work in a fashion that addresses an unsatisfactory education status quo, its original supporters began to work at odds with one another in ways that, as will be described in the following section, ensured the continuation of the unsatisfactory education status quo.

Why the MPCP Outlived its Policy Window
The elimination of the conditions that first opened the policy window for vouchers in Milwaukee was not enough to open the new policy window necessary for legislative action ending the MPCP.That window was nailed shut by several factors.The first was growing enrollment.The Wisconsin State Supreme Court ruled in 1998 that religious schools could participate in the MPCP (Witte, 2000).As can be seen in Figure Two, MPCP enrollment greatly increased after religious schools were first allowed to participate.The number of schools accepting vouchers more than doubled, from 23 to 83.This large increase in enrollment created a facts-on-the-ground argument against eliminating the MPCP; it was difficult for legislators to support outright eliminating the MPCP because doing so would disrupt the lives of thousands of their constituents.

Figure 2. MPS and MPCP Enrollment History
The second factor that allowed the program to grow and evolve after the closing of the initial policy window was politics.The MPCP is heavily supported by Republican legislators who, aside from the years 2009 to 2011, controlled at least one branch of Wisconsin government, and were thus able to block any proposal to eliminate the MPCP (LRB, 2014).The MPCP's place as the first urban voucher program also created a strong local and national advocacy movement that made the Wisconsin school choice lobby one of the most powerful actors in Wisconsin politics (Lueders, 2011;Associated Press, 2014).Today, the school choice lobby is influential in supporting conservative politicians in elections all across Wisconsin, and engages in issue advertising unrelated to education (Lueders, 2011).The importance of the Wisconsin school choice lobby to Wisconsin's Republican political infrastructure continues to help protect the MPCP from possible elimination.
The third factor was the voucher program's popularity with parents.Enrollment in the MPCP has grown steadily over time, and surveys of participating parents shows a high level of satisfaction with the voucher program (Teske, Fitzpatrick & Kaplan, 2007;Witte et al., 2008;Kava, 2013).Focus groups of Milwaukee parents in both voucher schools and MPS revealed that Milwaukee parents in general see both the MPCP and MPS as viable schooling options for their children (Carlson, Cowen, & Fleming, 2013;Howell, 2013).The MPCP's popularity with parents ensured that efforts to eliminate the MPCP would be met with significant backlash.
Only once in MPCP's history did a policy window for eliminating vouchers appear to open.In 2009, Democrats generally opposed to the MPCP, took control of all three branches of Wisconsin government (LRB, 2014).Both school choice advocates and opponents in Wisconsin predicted the MPCP would be targeted for elimination in the 2009-2011 biennial Wisconsin budget (Miner, 2009).A coalition led by activist Howard Fuller and several school leaders, however, worked with Milwaukee State Senator Lena Taylor and others to develop a set of proposals they hoped would protect the program from elimination (Miner, 2009).The efforts were successful.The 2009-2011 Wisconsin state budget increased the regulatory and accountability requirements for participating schools, but did not eliminate the MPCP.
As of 2014, Republicans supportive of school choice control all three branches of Wisconsin government which, combined with the factors discussed in the previous paragraphs, makes it unlikely that a policy window enabling the elimination of vouchers will open again in the foreseeable future (LRB, 2014).Instead, as will be demonstrated in the following section, Milwaukee's education policy finds itself in a state of paralysis because the policy window enabling decisive legislative action on the MPCP closed, despite the program's failure to solve the various issues that spurred its creation.Today, the MPCP and MPS face similar challenges, and similarly few prospects for addressing them.

Policy Evolution, and Paralysis
It has been demonstrated that the policy window enabling the MPCP closed shortly after the program's inception, and that a new policy window for eliminating the MPCP has not yet, and is unlikely in the near future, to open.Because of this situation, Milwaukee's voucher program has evolved incrementally from a dramatic free-market-based reform, to a system that mirrors Milwaukee's traditional public school sector (Lindblom, 1959).The policy evolution began in 2003 in response to the stories of two troubled schools: Mandella Academy and Alex's Academics of Excellence.Both schools had well-documented deficiencies (including one with a convicted rapist as the principal); however, DPI lacked statutory authority to close either school.The crisis resulted in 2003 Act 155, which mandated that schools undergo an annual independent financial audit certified by an independent accountant, submit on occupancy permit to the state prior to opening, show financial viability, show evidence that the school's administrator underwent state financial training, and empowered the DPI Superintendent to cut off funding to a school "if he or she determines that conditions at the private school present an imminent threat to the health or safety of pupils" (Act 155, 2003).
The new law had a significant impact.DPI quickly closed both Alex's Academics of Excellence and Mandella Academy.Since its passage in 2003 and the year 2013, Act 155 was used to cut off public funding to 31 schools (DPI, 2013).Most important, with the enactment of Act 155, the idea that a market-based regulatory approach to the MPCP could be sufficient was permanently undermined.
The The modern MPCP is a decentralized parallel system of public education with aggregate challenges, needs, and outcomes similar to the traditional public school system it was created to reform.Policy makers in Milwaukee and Wisconsin face a policy paralysis--neither eliminating nor expanding the voucher program is likely to have an impact on the overall academic performance of Milwaukee pupils.Instead, policy makers are faced with the difficult task of improving both MPS, as well as the parallel system of the MPCP.

Conclusion
John Kingdon (1995) concluded that policy windows close when advocates feel an idea does not solve their problem, supporters run out of steam, turnover in political leadership occurs, or a crisis ceases to exist.The presented case of the MPCP demonstrates how public policies can exist and evolve long after the policy window that enabled their creation has closed.Simply, the MPCP did not dramatically change the unacceptable status quo defined by various audiences at the time of its creation, but its creation nonetheless nailed shut the policy window that might lead to its elimination.Thus, there are several lessons from the Milwaukee voucher experience.First, public policy concepts can have life cycles independent of actual public policy programs.Vouchers still may exist in Milwaukee, but the voucher policy enacted in 1990 does not.Second, policy initiatives without clearly articulated goals and accepted methods of measuring those goals are likely to evolve at the whim of legislators and public opinion.The changes to voucher policy in Milwaukee have all been incremental and driven by the political realities of the moment.Third, under certain conditions, the survival of a policy after the closing of a policy window can lead to policy paralysis.But what are those conditions?
First, the MPCP was ambitious.Early voucher policy entrepreneurs saw the MPCP as a panacea for the struggles of urban education.Second, the goals of voucher policy in Milwaukee varied, depending on the audience.Third, voucher policy was new and untested, making it impossible to learn from previous experiments.Fourth, the MPCP was, and still is, a highly politicized public policy.Lastly, the MPCP directly impacts the lives of thousands of families, making it a policy that is likely to elicit strong emotions.The author cautions that the experience of the MPCP is just a single case.However, the conditions surrounding the enactment and evolution of voucher policy in Milwaukee are nonetheless instructive for identifying potential characteristics of public policies at risk for paralysis.Ambitious public policies that elicit emotions among citizens, that are experimental, highly politicized, and that are borne of diverse fleeting coalitions may become, as the MPCP demonstrates, entrenched and polarizing, even if they are ineffective or underwhelming in obtaining their original goals.
Today, Milwaukee's education system struggles much like it did in 1990, yet, the possibility of constructive reform to address the struggles of both MPS and the MPCP is all but impossible.The policy window for bold collective education reform in Milwaukee has been effectively nailed shut.Hence, there are no easy answers for fixing Milwaukee's struggling and complex publicly funded education system.The parallel education systems are likely to continue in their current form, with limited aggregate academic improvement for Milwaukee pupils.However, the Milwaukee experience does provide lessons for policy makers considering policies under conditions similar to the policy window that enabled the MPCP.First, the goals of new untested policies should be clearly articulated at the time of their passage.Second, policy sunset provisions attached to clearly articulated goals should be included in untested policy initiatives.Third, and most important, policy makers must consider the role that facts on the ground realities (such as large program enrollment and politics) play in complicating actionable program evaluations.The MPCP demonstrates how rational, evidence-based policy making becomes more difficult when certain conditions are met.Further research on the experience of other similar education policies can strengthen the conclusions of this study by exploring in other similar settings what happens when public policy initiatives outlast the complex and unique set of conditions that first led to their creation.

Figure 1 .
Figure 1.MPCP Per-Pupil Payment and MPS Per-Pupil State and Local Cost (2013 Dollars) (Witte et al., 2012) with the previously mentioned accountability and regulatory provisions enacted in the 2009-2011 biennial budget.Those provisions required that MPCP schools provide an array of written policies and transparency information to parents and DPI, namely, that all teachers in MPCP schools have college degrees, that all MPCP pupils take the Wisconsin Knowledge and Concepts Exam in the same grades and subjects as public school pupils, that test score results be released publicly by school, and this created a new preaccreditation entity empowered to approve new schools.Aside from the notable exceptions of adherence to open records law and the possibility of sanctions under the federal No Child Left Behind Law, private schools in the MPCP are now regulated in a manner very similar to public schools.The new pre-accreditation requirement in particular provided a barrier to program entry that killed any last illusions that the MPCP was still a market-based education policy.In 1990 the MPCP was revolutionary.It held limitless potential to greatly improve academic outcomes in the city of Milwaukee.The potential envisioned in 1990 failed to materialize.Today's MPCP is not a free market experiment, but a well entrenched part of Milwaukee's K-12 status quo.The MPCP enrolls about 21% of Milwaukee's publicly funded students, is open to most Milwaukee children, and parents and policy makers can access the policies and test scores of both MPS and MPCP schools.MPCP schools, like those of MPS, are serving a primarily low income minority population.Most important, achievement levels for students in the voucher program are almost identical to MPS(Cowen et al., 2013).Both the results of a five-year longitudinal study of the program and the release of school level results of the Wisconsin Knowledge and Concepts Exams indicate a program producing academic outcomes very similar to MPS(Witte et al., 2012).Like MPS, there are several outlier MPCP schools with extremely high levels of achievement, but also like MPS, most schools educate students with achievement levels well below state averages.