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California created a policy directing the grantee organizations responsible for the state’s more than 4,500 publicly funded afterschool programs to implement continuous quality improvement (CQI) focused on quality standards for expanded learning developed in support of CQI. We conducted case studies of grantee organizations and afterschool sites across California to investigate how the CQI policy has been implemented and explain patterns in implementation. Preliminary findings suggest that CQI planning, practice, and knowledge are shaped by the loosely coupled nature of the system in ways that counteract policy goals. We explain these findings using the complex systems theory concepts of self-organization, emergence, and downward causation.