03.29.10: SSDA Working for Small School Districts on Federal Issues
By David Walrath
With Elementary and Secondary Education Act (ESEA) reauthorization (currently called No Child Left Behind) starting in Congress, SSDA, our national lobbying organization (National Rural Education Advocacy Coalition), the Rural School and Community Trust and the National Rural Education Association are proposing changes that will help small school districts and rural school districts.
When No Child Left Behind was enacted as the most recent version of the ESEA, urban school districts and their Representatives in Congress were able to tilt programs and funding toward themselves. NCLB was not rural or small district sensitive. SSDA and the other organizations are working to correct those problems and are advocating ESEA amendments for more fair funding distributions and changes that recognize small school districts should not have the same intervention procedures as large urban school districts.
The following letters were sent by SSDA as comments to provide amendments to ESEA. For more information on the formula fairness advocacy and facts please go to www.formulafairness.com and www.nreac.org for the most recent position paper on federal issues affecting small and rural school districts.
Formula Fairness
March 8, 2010
The Honorable George Miller
U.S. House of Representatives
2205 Rayburn Office Building
Washington, D.C. 20515
Dear Representative Miller:
The California Small School Districts’ Association (SSDA) represents almost 600 small school districts in California, most of which are rural. These districts, with 2,500 or fewer students, comprise approximately 60% California’s school districts.
SSDA requests your support to enact Title I formula fairness in the reauthorization of the Elementary and Secondary Education Act (ESEA). Attached is data developed by Marty Strange at the Rural School and Community Trust based upon Congressional Research Service Data.
Research done by Mr. Strange clearly demonstrates that the two number weighted formulas, that have received almost all the new Title I funding in the past decade, do not accomplish the initial ESEA goal of ensuring all students living in poverty are able to receive equal access to appropriate educational services. The number weighting provisions of the Education Finance Incentive Grant (EFIG) and the Targeted Grant effectively penalize small school districts with high percentages of poverty students. The formulas transfer funds needed by these districts to larger school districts with lower percentages of students living in poverty. SSDA has adopted the following positions on formula fairness for all new funds allocated through ESEA Title I:
- School districts serving students living in poverty should be provided the same dollar amount per student regardless of the state in which the student lives.
- School districts serving students living in poverty should receive the same dollar amount per student adjusted for higher percentages of students because of increased educational need when there are higher percentages of poverty students.
- The Census Bureau determination of the number of poverty students in school districts is seriously flawed for rural areas and needs to be corrected. Also, because the census data occurs once a decade, the census poverty data is not up-to-date for increases in poverty that occur rapidly based on employment and economic downturns.
Allocating any new Title I funds should be through a single new formula based on these three standards.
SSDA opposes taking current Title I funding from any school district. Every school district should be allowed to retain current funding. SSDA, however, advocates that any new Title I funding should be allocated pursuant to a fairer formula for education services to all students regardless of the state where they live and whether they live in urban, suburban or rural areas, or in large, medium or small school districts.
Attached is information on districts in California and a summary analysis indicating: 1) the flaws of the number weighting system based upon large urban and suburban districts; and 2) small high poverty rural districts compared to large suburban districts.
For more information, please contact me at dwalrath@m-w-h.com; or Mr. Marty Strange at the Rural School and Community Trust at marty.strange@comcast.net or visit www.formulafairness.com.
Thank you for your consideration.
Sincerely,
David L. Walrath
| Large Lower Poverty Suburban Districts do Better Under Number Weighting Than Smaller Higher Poverty Urban School Districts | ||
| Poverty | Benefit per Eligible Pupil from Number Weighting | |
| Capistrano | 5.16% | $91.57 |
| Corona-Norco | 9.58% | $158.03 |
| Elk Grove | 15.47% | $133.96 |
| Orange | 8.41% | $103.98 |
| Fresno | 35.41% | $51.99 |
| Compton | 32.50% | $25.72 |
| Small High Poverty Rural Districts Lose Significant Funds Transferred to Larger Lower Poverty Districts Due to Number Weighting | ||
| Poverty % | Gain per Eligible Pupil |
|
| Fremont USD | 8.80% | $39.65 |
| Newport- Mesa USD | 9.37% | $39.39 |
| Placentia Yorba-Linda | 6.66% | $5.87 |
| Loss per Eligible Pupil |
||
| West Fresno ESD | 53.60% | ($281.34) |
| Earlimart ESD | 48.84% | ($303.77) |
| Orange Center ESD | 47.67% | ($256.52) |
Elementary and Secondary Education Act
March 25, 2010
The Honorable George Miller
U.S. House of Representatives
2205 Rayburn Office Building
Washington, D.C. 20215
Dear Representative Miller:
The California Small School Districts’ Association (SSDA) previously sent comments regarding achieving better equity in allocating future Title 1 funds by ending the use of number weighting formulas. The comments in this letter reflect the SSDA recommendations on other Elementary and Secondary Education Act (ESEA) reauthorization issues. Specifically, SSDA is making recommendations on the following issues:
- Shift from Formula Grant Funding to Competitive Grants
- Rural Education Achievement Program for Small Rural School Districts
- Requirements for Highly Qualified Teachers in Rural Schools
- Requirements of Transportation for Students from Program Improvement Schools in Rural Areas
- Title I Minimum Allocations to Small, Rural School Districts
- Parental Opt-Out For Standardized Testing
- Statistical Accuracy for Subgroups
- Enhancing Education Through Technology (EETT)
- Development of a School Renovation and Repair Program
- 0) Other ESEA Program Issues
1) Shift from Formula Grant Funding to Competitive Grants
SSDA has met with and appreciates the United States Department of Education for being sensitive to the effects of competitive grants for small and rural school districts. Small school districts do not have grant writers on staff. Consequently, shifting more federal funds into competitive grants puts these districts at a disadvantage and provides larger school districts with a greater advantage for federal funding.
This problem is exacerbated if the competitive grant funds are carved out of existing formula grant funds. The effect of a carve out is that all districts have less funding. For small districts, “less of less” restricts their ability to offer quality programs. SSDA requests that if the federal government shifts more resources into competitive grants, then both the “less of less” issue and the competitive equity issues need to be addressed.
Competitive Equity
SSDA recommends that for all competitive grants, similar-sized districts should compete against similar-sized districts. Specifically, SSDA proposes that the competitive funds be set-aside for school districts between:
- 0 – 1,000 students
- 1,000-5,000 students
- 5,000-25,000 students
- Greater than 25,000 students
The school districts in each size category in each state would compete against each other for the funds set-aside for their size category in that state. This ensures that: 1) there are competitive grants and that the best grants are funded; and 2) the best projects are funded rather than the best grant writers. Without providing a more equitable competitive process, SSDA is concerned shifting to competitive grants will reward the grant writers in large districts, rather than quality program proposals made by smaller school districts.
“Less of Less”
SSDA recommends that all formula grants contain minimum allocations for eligible districts. Minimums already exist in the Rural Education Achievement Program, 21st Century Afterschool Program, and were proposed in the 21st Century Green Schools Program for school renovation and repair. SSDA believes the policy reasons for minimums in these programs are the same reasons for justifying extension of school district minimum grants to all formula grant programs.
2) Rural Education Achievement Program (REAP) Funding for Small Rural School Districts
SSDA encourages Congress to retain REAP and increase the minimum grants to better reflect the instructional funding requirements for small, rural school districts.
SSDA also requests that the definition of “rural” and school district size limits be reviewed to more accurately reflect rural districts in large urban counties and the assumption that rural areas in each county have the same population growth as that county’s urban areas.
SSDA strongly supports and appreciates that Congress established REAP and hopes it will continue as a significant part of ESEA reauthorization.
3) Requirements for Highly Qualified Teachers in Rural Schools
SSDA requests an amendment to ESEA regarding highly qualified teachers in small, rural schools; particularly small, rural high schools. The credentialing requirements and the economics of small high schools do not fit together. Small, rural high schools do not have enough money to hire all the teachers necessary to meet the instructional program requirements and also have highly qualified teachers in every subject area. The reality is when a teacher leaves a small, rural high school, that teacher may have been a mathematics teacher with a background in algebra and geometry, some trigonometry and limited calculus. That teacher may have also been required to teach an earth science class or an introduction to chemistry class, as well as the mathematics classes. There might not have been sufficient students in the high school to fully utilize the instructor’s time for six hours a day solely in mathematics.
The result is that many teachers in rural high schools teach in subject areas where they do not have a major or a master’s degree in that subject matter. These teachers, however, may be fully capable of teaching the assignment because of professional development and work in the subject area to improve their instructional skills.
SSDA believes that small, rural high schools and middle schools should be allowed to employ as highly qualified teachers, those individuals who pass state proficiency tests in subject matters in which they will be teaching.
4) Requirements of Transportation for Students from Program Improvement Schools in Rural Areas
SSDA requests that reauthorization eliminate the requirement that Title 1 funds be used to transport students to other school districts.
Currently, school districts must spend an amount equal to 15-20% of their Title I funds to provide transportation from program improvement schools to non-program improvement schools, if the students’ parents want such transportation. Often there is only one high school in the district. The next high school could be 40, 60 or 80 miles away. The transportation cost in such situations can be excessive. Twenty percent of the program improvement Title I funding could be significantly greater than the per pupil Title I amount being generated by the students being transported.
The effect of such a situation in rural areas is that the remaining students, who have chosen not to have transportation, will receive a lower level of Title I services in order to provide transportation for those students choosing to leave.
5) Title I Minimum Allocations to Small, Rural School Districts
SSDA requests changes to Title I eligibility to allow an alternative to the Census poverty count for the allocation of Title I funds.
Use of Alternatives to Census Poverty Count for Title I Allocation
Currently, states are able to request a waiver to using the Census poverty count for Title I funding eligibility. Not all states have applied for waivers, and different waiver provisions have been granted to different states. SSDA believes that, regardless of whether a state has or has not asked for a waiver, there ought to be a consistently applied alternative for all rural school districts.
SSDA believes that the ESEA reauthorization should include a provision where rural school districts can substitute their free lunch count students for Title 1 eligibility in lieu of the Census poverty count.
Rationale
The Census Bureau uses a sampling methodology to determine poverty counts. The Census Bureau concurs that it does not work well in small sample sizes. The effect for rural America is that the Census calculations are not accurate. Free meal counts more accurately reflect true poverty in these areas. A count of all the students who are eligible for free meals can be adjusted on an annual basis to reflect changes in pupil demographics. This will provide more accuracy and more statistically reliable validation of the poverty counts in each rural school district.
6) Parental Opt-Out For Standardized Testing
SSDA recommends students, whose parents have submitted valid requests to exclude the student from standardized testing requirements, not be counted as eligible to take the standardized test.
California allows parents to opt-out of standardized tests for their children. This provision ensures parental choice and control over the types of questions that are asked of their children. California law does not count these children within the calculation of those eligible to take the test.
Federal law, however, does count these students as eligible to take the test. This divergence results in many very small, rural schools not meeting the percentage of test taker requirements in the ESEA.
SSDA believes the students are the parent’s children and the parents ought to be able to determine whether or not they want their children taking government tests. For this reason, SSDA believes that school districts should not be penalized by being placed in program improvement if some students are excluded from standardized testing. For a very small school district, a change of two students could result in that district not meeting its 95% testing requirement. SSDA believes this is an unnecessarily rigid provision of federal compliance regulation and ought to be amended.
7) Statistical Accuracy for Subgroups
SSDA recommends adopting a three-year rolling average of subgroup and small sample size scores to accurately reflect academic achievement and be less subject to uncontrollable variations that occur because of small sample sizes.
SSDA is concerned that the current subgroup methodology does not contain sufficient statistical accuracy to be valid in small sample sizes. SSDA believes that a sample size of 17 per grade level is an appropriate sample size. For a school district or for a school, SSDA believes that this ought to be the factor for determining whether there is or is not a subgroup subject to the requirements of the ESEA adequate yearly progress requirements. SSDA also believes this because of the variations that can occur with a few students moving into or out of a school district or a few students having difficulties at home because of economic circumstances, such as the mill closing or other economic factors that frequently impact rural America.
For these reasons, SSDA recommends reauthorization include three-year averaging for any school district that has fewer than 600 students and for all districts in Frontier Counties.
8) Enhancing Education Through Technology (EETT)
SSDA supports EETT reauthorization, at a minimum of $500 million per year, with formula changes to allocate a greater amount of funds through formula grants with small school minimums and increasing the percentage for professional development.
Courseware for Rural Schools
SSDA requests that a pilot program be developed to test the delivery of high speed broadband courseware by highly qualified teachers that would meet the academic standards of the state in which the rural school district is located.
The provision of high quality coursework taught by highly qualified teachers will assist small, rural high schools in meeting the curriculum requirements for students to meet state and federal standards. SSDA believes this type of program would address many of the concerns with ensuring fully credentialed highly qualified teachers in the ESEA required subject matters.
The American Recovery and Reinvestment Act provided significant funding for expanding access to high speed broadband. That funding, $7 billion, was intended to ensure that all citizens have access to broadband internet services. That investment will not be as valuable or useful if school districts do not have the access to education technology funding to best use the broadband internet. It is particularly important to rural school districts that need to have courseware and technology to level the playing field with larger more wealthy school districts that are able to provide much broader based courses to their students.
Most rural high schools do not provide more than two advanced placement classes. The students in these high schools compete for college entrance with students going to suburban schools which have 10-20 advanced placement classes. Because advanced placement gives a weighted grade point advantage, acceptance at four year institutions is more difficult for high school students who do not have access to advanced placement through highspeed broadband courses.
The reauthorization of the Telecommunications Act should address many issues within adequacy of funding for the E-Rate. However, there is no expectation this E-Rate funding will be sufficient to provide the educational technology needs of school districts. The Enhancing Education Technology program is the primary program for rural school districts to use for acquiring such technology services.
For this reason, SSDA recommends that the ESEA reauthorization include funding authority of no less than $500 million per year for enhancing education through technology programs.
9) Development of a School Renovation and Repair Program
Small, rural school districts do not have access to the same level of property taxes as larger districts to meet local school renovation and repair needs. Last session’s HR 3221 would provide grants to state and local school districts to renovate, repair and modernize schools for the fiscal year 2010. HR 3221 would allocate the same percentage of funds to states and school districts as they receive under Part A of Title I of the Elementary and Secondary Education Act with a guarantee that each district receive a minimum of $5,000. SSDA believes this program should be an ongoing program within the ESEA reauthorization.
10) Other ESEA Program Issues
- Title III: Bilingual, Immigrant and English Language Learner Students
SSDA believes it is each state’s responsibility to determine the assessment tools and requirements for bilingual, immigrant and English Language Learner (ELL) students.
SSDA believes the role of federal government – as it pertains to bilingual, immigrant and English Language Learner students – is limited to supporting states and districts with rapidly increasing diversity. This could include support for local instructional methods, financial assistance for tutors and help in recruiting ELL instructors and tutors for geographically isolated areas.
- Title IV: SSDA supports legislative efforts to create and expand opportunities for after school programs in rural areas. SSDA believes any after school programs operated from the federal level must consider the needs of rural schools and ensure equitable distribution of those programs to maximize participation by students in rural communities.
- Title V: SSDA supports the Education Innovative Block Grant as a critical source of flexible money for local districts to nurture new programs and test ideas.
SSDA recommends increasing the percentage of funding that flows directly to school districts under the Education Innovative Block Grant, as well as establishing a minimum guaranteed grant size.
Thank you for your consideration.
Sincerely,
David L. Walrath
Legislative Advocate
Come to the SSDA Annual Conference for more on SSDA advocacy on federal issues, ESEA reauthorization and federal issues. For information on the schedule, agenda, workshops and how to register please go to www.ssda.org.
