Idaho — United States Department of Education to the Honorable Debbie Critchfield (January 27, 2023)

Summary

Idaho Superintendent of Public Instruction Debbie Critchfield is told in a January 27, 2023 letter from Laura Jimenez that the Department finds Idaho's tolerance plan reasonable for maintenance of equity. Idaho's State Department of Education treats LEAs with 500 or fewer students as very small, which covers 71 of its 178 LEAs, and proposes a 15 percent tolerance because per-pupil amounts swing with small enrollment changes. The Department reviewed the data and the State's circumstances and applies the plan only to those very small LEAs.

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Full text

                                UNITED STATES DEPARTMENT OF EDUCATION



                                                       January 27, 2023

The Honorable Debbie Critchfield
Superintendent of Public Instruction
Idaho State Department of Education
650 West State St.
Boise, ID 83720-0027

Dear Superintendent Critchfield:

The U.S. Department of Education (Department) received your written plan for a reasonable level of
tolerance when calculating whether the Idaho State Department of Education (DOE) has met State
maintenance of equity requirements under the American Rescue Plan Act of 2021 (ARP Act). This
written plan applies only to a subset of Idaho’s local educational agencies (LEAs) that the State defined
as very small.

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

The Department determined that it is consistent with the maintenance of equity requirements to allow a
State educational agency (SEA) to calculate whether it has maintained 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 to maintain equity in funding. (See Frequently Asked Questions,
American Rescue Plan Elementary and Secondary School Emergency Relief Program, Maintenance of
Equity Requirements, July 26, 2022, Question 21(a).)

The Idaho DOE considers LEAs with enrollments of 500 or fewer students to be “very small LEAs.”
Under this proposed threshold, Idaho has 71 very small LEAs out of 178 LEAs statewide. The Idaho
DOE asserts that the calculated per-pupil funding amounts for very small LEAs in Idaho are
significantly affected by small changes in student enrollment, which makes these data an unreliable
indicator of whether the SEA has achieved the intent of maintaining equity in funding across LEAs.




                                     400 MARYLAND AVE. SW, WASHINGTON, DC 20202
                                                    www.ed.gov

   The Department of Education’s mission is to promote student achievement and preparation for global competitiveness by fostering
                                         educational excellence and ensuring equal access
For its 71 very small LEAs, the Idaho DOE proposes to implement a 15 percent tolerance. After
reviewing the Idaho DOE’s tolerance proposal (including the data submitted), 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 Idaho has maintained equity for very small
LEAs.

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

                                                  Sincerely,

                                                  Laura Jimenez

                                                  Laura Jimenez
                                                  Director, Office of State and Grantee Relations
                                                  Office of Elementary and Secondary Education
                                                  United States Department of Education


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