Washington — United States Department of Education to the Honorable Chris Reykdal (April 18, 2023)

Summary

A letter dated April 18, 2023, from the Department of Education Office of Elementary and Secondary Education to Superintendent of Public Instruction Reykdal of the Washington Office of Superintendent of Public Instruction. It responds to the written plan for a reasonable level of tolerance under State maintenance of equity requirements. The plan proposes two tolerance levels: a 25 percent reduction for LEAs with 100 or fewer students (Tier 1) and an 8 percent reduction for LEAs with between 101 and 700 students (Tier 2). Tier 1 would impact 16 LEAs and Tier 2 would impact 18 LEAs. The Department states it determined the approach reasonable.

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Full text

                           UNITED STATES DEPARTMENT OF EDUCATION
                                OFFICE OF ELEMENTARY AND SECONDARY EDUCATION




                                                    April 18, 2023

The Honorable Chris Reykdal
Superintendent of Public Instruction
Washington Office of Superintendent of Public Instruction
600 South Washington Street
Olympia, WA 98504-7200

Dear Superintendent Reykdal:

The U.S. Department of Education (Department) received your written plan for a reasonable
level of tolerance when calculating whether the Washington Office of Superintendent of Public
Instruction (OSPI) 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 Washington’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 OSPI, the State of Washington funds schools primarily
through a set of student-to-staff ratios that translate into an allocation for LEAs. There are two
facets of the school funding system that have particular implications for OSPI in meeting State
maintenance of equity requirements in small LEAs: (1) the impact of small school funding
factors; and (2) State funding allocations for students enrolled in Alternative Learning
Experience programs, including online learning. OSPI asserts that calculated per-pupil funding
amounts for small LEAs are significantly affected by small changes in student population,
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   The Department of Education’s mission is to promote student achievement and preparation for global competitiveness by
                               fostering educational excellence and ensuring equal access
particularly in LEAs where students have moved from brick-and-mortar schools to online
learning. This makes per-pupil funding amounts in Washington’s small LEAs an imperfect
indicator of whether the SEA has achieved the intent of maintaining equity in funding across
LEAs.

Accordingly, OSPI proposes two tolerance levels:
   1) For LEAs with 100 or fewer students, OSPI proposes to tolerate a 25 percent reduction in
      per-pupil funding from year to year (Tier 1).
   2) For LEAs with between 101 and 700 students, OSPI proposes to tolerate an 8 percent
      reduction in per-pupil funding from year to year (Tier 2).

Applying the tolerances outlined in Tier 1 would impact 16 LEAs that served 0.07 percent of
Washington’s students. Tier 2 would impact 18 LEAs that served 0.5 percent of Washington’s
students.

After reviewing OSPI’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 OSPI has maintained equity for small
LEAs.

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

                                                   Sincerely,
aura Jimenez
    L                                              Laura Jimenez
                                                   aura Jimenez
                                                   Laura Jimenez
                                                   Director, Office of State and Grantee Relations


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