Wisconsin — United States Department of Education to the Honorable Jill Underly (March 31, 2023)

Summary

This is a letter dated March 31, 2023 from the Office of Elementary and Secondary Education at the United States Department of Education to Jill Underly, Superintendent of Public Instruction at the Wisconsin Department of Public Instruction (DPI). The letter states that the Department received DPI's written plan for a reasonable level of tolerance when calculating whether Wisconsin has met State maintenance of equity requirements under the American Rescue Plan Act of 2021, applying to a subset of local educational agencies. It describes DPI's proposal of a tolerance of up to a 5 percent decline in per-pupil funding for small districts. It states that, after reviewing the proposal and accompanying data, the Department determined that the approach includes a reasonable level of tolerance for small districts.

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                      UNITED STATES DEPARTMENT OF EDUCATION


                                         March 31, 2023

The Honorable Jill Underly
Superintendent of Public Instruction
Wisconsin Department of Public Instruction
125 South Webster Street
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 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 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 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 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, and 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 225 such
LEAs. For these 225 small LEAs, DPI proposes to implement a tolerance of up to a 5 percent
decline in per-pupil funding. Applying this tolerance would impact three small districts in FY
2022 that, together, served 0.22 percent of Wisconsin’s public school students. Wisconsin DPI
asserts that per-pupil funding amounts for small districts are significantly affected by small
changes in student population as well as the distribution of State general aid and local property
tax contributions. This makes the per-pupil funding amounts in Wisconsin’s small districts an
imperfect indicator of whether the SEA has achieved the intent of maintaining equity in funding
across LEAs.

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 districts.

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 JimenezLaura 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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