Letter to the Alaska Department of Education and Early Development — Reasonable Level of Tolerance (March 18, 2024)
Summary
Alaska Commissioner Deena M. Bishop is told in a March 18, 2024 letter from Laura Jimenez that the Department finds reasonable the amended small-LEA tolerance plan Alaska submitted for FY 2022 and FY 2023 maintenance of equity. The tiers, built on average daily membership and population density, tolerate year-to-year per-pupil reductions from 60 percent down to five percent. Alaska must still make additional payments for shortfalls such as $7,186,852 at Kenai Peninsula Borough School District in FY 2022 and $204,309 at Juneau Borough School District in FY 2023. The letter says Alaska's FY 2022 compliance plan, due January 22, 2024, is outstanding and asks for resolution by March 22, 2024.
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Cite this document
“Letter to the Alaska Department of Education and Early Development — Reasonable Level of Tolerance (March 18, 2024).”
Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-3-18-2024-used-www-ed-gov-59ecb2ab03-97472d6709/
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UNITED STATES DEPARTMENT OF EDUCATION
March 18, 2024
The Honorable Deena M. Bishop
Commissioner of Education
Alaska Department of Education and Early Development
P.O. Box 110500
Juneau, AK 99811
Dear Commissioner Bishop:
The U.S. Department of Education (Department) received your amended plan for a reasonable
level of tolerance when calculating whether the Alaska Department of Education and Early
Development (DEED) 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 Alaska’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 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 DEED, Alaska’s Public School Funding Formula works on a
per‐student basis and guarantees each LEA a minimum “basic need” using a combination of
State funding, required Local Effort, and 90 percent of eligible Impact Aid funding received
from the Federal government. Alaska’s 54 LEAs include single-site remote municipalities and
multi-site rural LEAs—some of which are geographically larger than many of the lower 48
States—that lack a road system or other key infrastructure. Because total average daily
membership (ADM) is the main driver for determining a district’s Public School Funding
Formula allocation, DEED asserts that calculated per-pupil funding amounts for its small LEAs
are significantly affected by small changes in attendance rates. This makes per-pupil funding
amounts in Alaska’s small LEAs an imperfect indicator of whether the SEA has achieved the
intent of maintaining equity in funding across LEAs.
On March 12, 2024, DEED submitted a revised small LEA tolerance proposal to reflect their
updated SEA-level data submission that proposes the following tiers:
1) For LEAs with ADMs of 16 or fewer students per square mile and regular ADMs below
55, DEED proposes to tolerate a 60 percent reduction in per-pupil funding from year to
year. This would impact one LEA identified by the State as meeting the definition of
high-need or highest-poverty in fiscal year (FY) 2022 that served 0.04 percent of
Alaska’s students and another LEA in FY 2023 that served 0.01 percent of Alaska’s
students.
2) For LEAs with ADMs of 0.10 or fewer students per square mile and regular ADMs
between 200 and 300, DEED proposes to tolerate a 47 percent reduction in per-pupil
funding from year to year. This would impact one LEA identified by the State as meeting
the definition of high-need or highest-poverty in FY 2023 that served 0.20 percent of
Alaska’s students.
3) For single-site LEAs with ADMs between 100 and 725, DEED proposes to tolerate a 30
percent reduction in per-pupil funding from year to year. This would impact four LEAs
identified by the State as meeting the definition of high-need or highest-poverty in FY
2022 that served 0.9 percent of Alaska’s students and seven LEAs in FY 2023 that served
1.7 percent of Alaska’s students.
4) For LEAs with ADMs of 16 or fewer students per square mile and regular ADMs below
1,000, DEED proposes to tolerate a 20 percent reduction in per-pupil funding from year
to year. This would impact nine LEAs identified by the State as meeting the definition of
high-need or highest-poverty in FY 2022 that served 2.65 percent of Alaska’s students
and 11 LEAs in FY 2023 that served 2.30 percent of Alaska’s students.
5) For LEAs with ADMs of 0.15 or fewer per square mile, regular ADMs between 1,800
and 3,950, and that experienced a one percent or greater reduction in ADM, DEED
proposes to tolerate a five percent reduction in per-pupil funding from year to year. This
would impact one LEA identified by the State as meeting the definition of high-need or
highest-poverty in FY 2022 that served 1.4 percent of Alaska’s students and another LEA
in FY 2023 that served 2.9 percent of Alaska’s students. (For these LEAs, it is generally
not feasible for a student to travel to the closest neighboring school in the same LEA or in
the next nearest LEA. These LEAs have seen particular enrollment volatility in recent
years.)
After reviewing DEED’s tolerance proposal and accompanying data, the unique circumstances in
the State, and our further State-specific analysis, we have determined that this amended plan
includes a reasonable level of tolerance when calculating whether Alaska has maintained equity
for small LEAs in FYs 2022 and 2023. Data provided by DEED indicate that Alaska will need to
make additional payments to LEAs in tables 1 and 2, below, that experienced disproportionate
reductions in per-pupil funding in FY 2022 or FY 2023 and are not captured by this proposal:
Table 1. Amount of State funding reductions considered disproportionate under the
FY 2022 maintenance of equity requirement
LEA FY 2022 Maintenance of Equity
Shortfall
Kenai Peninsula Borough School District $7,186,852
Anchorage School District $15,202,289
Table 2. Amount of State funding reductions considered disproportionate under the
FY 2023 maintenance of equity requirement
LEA FY 2023 Maintenance of Equity
Shortfall
Juneau Borough School District $204,309
Anchorage School District $1,391,681
Kenai Peninsula Borough School District $2,494,871
Fairbanks North Star Borough School District $3,097,911
Please advise the Department when these additional payments have been made. Alaska’s
compliance plan to address FY 2022 maintenance of equity compliance was due on January 22,
2024, and is still outstanding. Please resolve this matter by March 22, 2024. If you have any
questions, please contact your program officer at: Alaska.OESE@ed.gov.
Sincerely,
Laura Jimenez
Director, Office of State and Grantee Relations
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