Letter to the Arizona Department of Education — Reasonable Level of Tolerance (December 27, 2022)

Summary

This is a letter dated December 27, 2022 from the United States Department of Education to Kathy Hoffman, Superintendent of Public Instruction at the Arizona Department of Education (ADE). The letter states that the Department received ADE's written plan for a reasonable level of tolerance when calculating whether Arizona met State maintenance of equity requirements under the American Rescue Plan Act of 2021 for a subset of its local educational agencies. It states that ADE proposes a tolerance of up to a 5 percent decline in per-pupil funding for very small LEAs, defined as those with an Average Daily Membership of fewer than 100 students. It states that the Department determined the approach includes a reasonable level of tolerance for very small LEAs.

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Issuer: Congressional materials
Document type: Department Of Education 12 27 2022 Used Response To Tolerance Proposal Letter Fy22 Www Ed
Case: Department Of Education 12 27 2022 Used Response To Tolerance Proposal Letter Fy22 Www Ed Gov 49059Ab846

Cite this document

“Letter to the Arizona Department of Education — Reasonable Level of Tolerance (December 27, 2022).” Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-12-27-2022-used-response-to-tolerance-proposal-letter-fy22-www-ed-gov-49059ab846/, SHA-256 a5b77942e5b31429d6ac4a3ed875d8ce0e17e1c573c5ff46607eefcbcecad6da.

Full text

                      UNITED STATES DEPARTMENT OF EDUCATION



                                       December 27, 2022

The Honorable Kathy Hoffman
Superintendent of Public Instruction
Arizona Department of Education
1535 West Jefferson Street
Phoenix, AZ 85007-320

Dear Superintendent Hoffman:

The U.S. Department of Education (Department) received your written plan for a reasonable
level of tolerance when calculating whether the Arizona Department of Education (ADE) 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 Arizona’s local educational agencies
(LEAs).

The ARP Act State maintenance of equity requirements help ensure that State funding supports
the students in LEAs with high concentrations of poverty who have often been subject to
longstanding opportunity gaps in our education system and have also experienced the greatest
impact from the COVID-19 pandemic. Moreover, the ARP Act State maintenance of equity
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-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
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).)

ADE considers LEAs with Average Daily Membership (ADM) of fewer than 100 students to be
“very small LEAs.” Under this proposed threshold, Arizona has 112 such LEAs. The State’s
equalization formula provides add-on funding of up to $37,949 per student for qualifying special
education needs. According to ADE, the gain or loss of this add-on funding as students with
qualifying needs enroll and withdraw in very small LEAs may distort year-to-year per-pupil
funding comparisons and confound determinations of whether ADE has maintained equity for
these LEAs. For example, for one very small LEA, the ADM of students receiving add-on
funding decreased by 2.8, but the LEA’s total funding was reduced by almost $60,000 or over
$1,100 per pupil. For its 112 very small LEAs, ADE proposes to implement a tolerance of up to
a 5 percent decline in per-pupil funding. ADE states that, combined, its very small LEAs make
up 17.6 percent of all LEAs in the State and educate .6 percent of the total State ADM.

After reviewing ADE’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 ADE 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: Arizona.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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