Massachusetts — United States Department of Education to the Honorable Jeffrey C. Riley (January 25, 2024)

Summary

Massachusetts Commissioner Jeffrey C. Riley is told in a January 25, 2024 letter from Laura Jimenez that the Department accepts the state's written tolerance plan for FY 2023 maintenance of equity. Because the funding formula follows prior-year enrollments, the Department of Elementary and Secondary Education proposes tolerating a seven percent annual reduction in per-pupil funding for LEAs of zero to 200 students, which affects two high-need or highest-poverty LEAs serving 0.04 percent of students. The Department finds the plan reasonable and consistent with the FY 2022 request, and says Massachusetts must still make additional payments to two LEAs outside the proposal.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

                      UNITED STATES DEPARTMENT OF EDUCATION


                                        January 25, 2024

The Honorable Jeffrey C. Riley
Commissioner
Massachusetts Department of Elementary and Secondary Education
135 Santilli Highway
Everett, MA 02149

Dear Commissioner Riley:

The U.S. Department of Education (Department) received your written plan for a reasonable
level of tolerance when calculating whether the Massachusetts Department of Elementary and
Secondary Education (DESE) has met State maintenance of equity requirements under the
American Rescue Plan Act of 2021 (ARP Act) in fiscal year (FY) 2023. This written plan applies
only to a subset of Massachusetts’ local educational agencies (LEAs).

The ARP Act State maintenance of equity requirements help ensure that State funding supports
LEAs with high concentrations of poverty and the students who have been subject to
longstanding opportunity gaps in our education system and experienced the greatest impact from
the COVID-19 pandemic. These requirements are vital for ensuring that States maintain funding
to address the impact of the pandemic on students’ education, and for protecting students in high-
need and highest-poverty LEAs from disproportionate cuts if reductions in State effort do occur.

The Department determined that it is consistent with the State maintenance of equity
requirements to allow a State educational agency (SEA) to calculate whether it has maintained
funding equity with respect to its very small high-need and highest-poverty LEAs within a
reasonable “tolerance level.” The Department’s determination is based on the possibility of
significant volatility in the calculated per-pupil funding amounts for very small LEAs caused by
small changes in student enrollment, which may be unrelated to whether an SEA has achieved
the intent of the requirements. (See Frequently Asked Questions, American Rescue Plan
Elementary and Secondary School Emergency Relief Program, Maintenance of Equity
Requirements, July 26, 2022, Question 21(a).)

According to materials provided by DESE, Massachusetts’ education funding formula is
determined based on LEAs’ prior year student enrollments. DESE asserts that calculated per-
pupil funding amounts for its very small LEAs are significantly affected by small fluctuations in
enrollments. This makes annual per-pupil funding amounts in Massachusetts’ very small LEAs
an imperfect indicator of whether the SEA has achieved the intent of maintaining equity in
funding across LEAs. For LEAs with enrollments between zero and 200 students, DESE
proposes to implement a tolerance of a seven percent reduction in per-pupil funding from year to
year. For FY 2023, this would impact two LEAs identified by the State as meeting the definition
of high-need or highest-poverty that served 0.04 percent of Massachusetts’ students.

After reviewing DESE’s tolerance proposal and accompanying data, the unique circumstances in
the State, and our further State-specific analysis, we have determined that DESE’s tolerance
proposal includes a reasonable level of tolerance when calculating whether Massachusetts has
maintained equity for small LEAs in FY 2023. Further, the proposal is consistent with DESE’s
FY 2022 tolerance request.

Information provided by DESE indicates that Massachusetts will need to make additional
payments to two LEAs that experienced disproportionate reductions in per-pupil funding in
FY 2023 and are not captured by this proposal. Please advise the Department as additional
payments are made.

We appreciate your diligence in developing this proposal. If you have any questions, please
contact your program officer at: Massachusetts.OESE@ed.gov.

                                                  Sincerely,
Laura Jimenez
                                                  Laura Jimenez

                                                  Laura Jimenez
                                                  Director, Office of State and Grantee Relations


File and source

File

department-of-education-1-25-2024-used-response-to-tolerance-proposal-letter-fy23-www-ed-gov-b830d062b7.pdf

Size

148,304 bytes

SHA-256

3d2e0c26f4faf4f28cad8f9f2c83848e7959cfcd5ae43849fc301fbd1caf60d9

Our copy

department-of-education-1-25-2024-used-response-to-tolerance-proposal-letter-fy23-www-ed-gov-b830d062b7.pdf

Original

www.ed.gov