Letter to the Ohio Department of Education — Reasonable Level of Tolerance (January 26, 2024)

Summary

Ohio State Superintendent of Public Instruction Paul Craft is told in a January 26, 2024 letter from Laura Jimenez that the Department accepts the Ohio Department of Education's FY 2023 tolerance plan for maintenance of equity. The plan sets three tolerance levels for small LEAs: a 14 percent reduction in per-pupil funding for LEAs of 500 or fewer students, 2.8 percent for 500 to 1,100 and one percent for 1,101 to 1,500. They would affect 159, 213 and 99 high-need or highest-poverty LEAs serving 2.1, 1.0 and 0.2 percent of students, and Ohio must still make additional payments to LEAs outside the approval.

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Full text

                      UNITED STATES DEPARTMENT OF EDUCATION
                          OFFICE OF ELEMENTARY AND SECONDARY EDUCATION



                                        January 26, 2024

The Honorable Paul Craft
State Superintendent of Public Instruction
Ohio Department of Education
25 South Front Street
Columbus, OH 43215

Dear Superintendent Craft:

The U.S. Department of Education (Department) received your written plan for a reasonable
level of tolerance when calculating whether the Ohio Department of Education (ODE) 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 Ohio’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).)

ODE asserts that calculated per-pupil funding amounts for small LEAs are significantly affected
by minor changes in student population. This makes per-pupil funding amounts in Ohio’s small
LEAs an imperfect indicator of whether the SEA has achieved the intent of maintaining equity in
funding across LEAs. Accordingly, ODE proposes three tolerance levels:
   1) For LEAs with an enrollment of 500 or fewer, ODE proposes to tolerate a 14 percent
       reduction in per-pupil funding from year to year. For FY 2023, this would impact 159
       small LEAs identified by the State as meeting the definition of high-need or highest-
       poverty that served 2.1 percent of Ohio’s students.
   2) For LEAs with an enrollment from 500 to 1,100, ODE proposes to tolerate a 2.8 percent
      reduction in per-pupil funding from year to year. For FY 2023, this would impact 213
      small LEAs identified by the State as meeting the definition of high-need or highest-
      poverty that served 1.0 percent of Ohio’s students.
   3) For LEAs with an enrollment from 1,101 to 1,500, ODE proposes to tolerate a
      one percent reduction in per-pupil funding from year to year. For FY 2023, this would
      impact 99 small LEAs identified by the State as meeting the definition of high-need or
      highest-poverty that served 0.2 percent of Ohio’s students.

After reviewing ODE’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 Ohio has maintained equity for small
LEAs in FY 2023.

ODE’s proposal indicates that Ohio will need to make additional payments to LEAs that
experienced a disproportionate reduction in per-pupil funding in FY 2023 and that are not
captured by this small LEA tolerance approval. 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: Ohio.OESE@ed.gov.

                                                   Sincerely,
aura Jimenez
                                                   Laura Jimenez

                                                   Laura Jimenez
                                                   Director, Office of State and Grantee Relations


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