Wisconsin — United States Department of Education to the Honorable Jill Underly (January 26, 2024)

Summary

A letter dated January 26, 2024 from the U.S. Department of Education's Office of Elementary and Secondary Education, signed by Laura Jimenez, Director, Office of State and Grantee Relations, to Jill Underly, Superintendent of Public Instruction, of the Wisconsin Department of Public Instruction. It responds to Wisconsin's written plan for a reasonable level of tolerance in calculating State maintenance of equity under the American Rescue Plan Act of 2021 for fiscal year 2023. Wisconsin counts 226 small districts out of 420 statewide and proposes a tolerance of up to a five percent decline in per-pupil funding, which would affect three districts serving 0.13 percent of the State's students. The Department determines that the approach is reasonable and consistent with the fiscal year 2022 request.

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                      UNITED STATES DEPARTMENT OF EDUCATION
                          OFFICE OF ELEMENTARY AND SECONDARY EDUCATION




                                        January 26, 2024

The Honorable Jill Underly
Superintendent of Public Instruction
Wisconsin Department of Public Instruction
P.O. Box 7841
Madison, WI 53707-7841

Dear Superintendent Underly:

The U.S. Department of Education (Department) received your written plan for a reasonable
level of tolerance when calculating whether the Wisconsin Department of Public Instruction
(DPI) has met State maintenance of equity requirements in fiscal year (FY) 2023 under the
American Rescue Plan Act of 2021 (ARP Act). This written plan applies only to a subset of
Wisconsin’s 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 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).)

Wisconsin DPI considers LEAs with a membership of fewer than 1,000 students or fewer than
77 students per grade level (to account for differences in grade-span configurations (e.g., K-12
versus K-8)) to be small districts. Under this proposed threshold, Wisconsin has 226 such LEAs
out of 420 statewide. Wisconsin DPI asserts that calculated per-pupil funding amounts for small
LEAs are significantly affected by small changes in enrollment and students’ educational needs.
This makes annual per-pupil funding amounts in Wisconsin’s small LEAs an imperfect indicator
of whether the SEA has achieved the intent of maintaining equity in funding across LEAs. For its
226 small LEAs, Wisconsin DPI proposes to implement a tolerance of up to a five percent
decline in per-pupil funding. For FY 2023, applying this tolerance would impact three small
LEAs identified by the State as meeting the definition of high-need or highest-poverty in
FY 2023 that served 0.13 percent of Wisconsin’s students.
After reviewing Wisconsin DPI’s tolerance proposal and accompanying data, the unique
circumstances in the State, and our further State-specific analysis, we have determined that this
approach includes a reasonable level of tolerance when calculating whether Wisconsin has
maintained equity for small LEAs in FY 2023 and is consistent with DPI’s FY 2022 tolerance
request.

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

                                                   Sincerely,
aura Jimenez
                                                   Laura Jimenez

                                                   Laura Jimenez
                                                   Director, Office of State and Grantee Relations


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