Tennessee — United States Department of Education to the Honorable Lizzette Reynolds (April 5, 2024)

Summary

A letter dated April 5, 2024 from the U.S. Department of Education's Office of Elementary and Secondary Education, signed by Laura Jimenez, to Commissioner Lizzette Reynolds of the Tennessee Department of Education. It responds to Tennessee's written plan for a reasonable level of tolerance in calculating maintenance of equity under the American Rescue Plan Act of 2021 for fiscal year 2023. Tennessee treats districts with fewer than 1,500 students as small, counts 35 of 148 statewide, and proposes a tolerance of up to a 0.62 percent decline in per-pupil funding, which would affect one small district serving 0.15 percent of the State's students. The Department determines the approach is reasonable.

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Cite this document

“Tennessee — United States Department of Education to the Honorable Lizzette Reynolds (April 5, 2024).” Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-4-5-2024-used-response-to-tolerance-proposal-f-8352cfdab1/, SHA-256 c55bd2ea00de46a1e27804f5f7633b77ad01930713a54065bf5a19ddda809518.

Full text

                                UNITED STATES DEPARTMENT OF EDUCATION
                                     OFFICE OF ELEMENTARY AND SECONDARY EDUCATION



                                                    April 5, 2024

The Honorable Lizzette Reynolds
Commissioner of Education
Tennessee Department of Education
710 James Robertson Parkway
Nashville, TN 37243-0375

Dear Commissioner Reynolds:

The U.S. Department of Education (Department) received your written plan for a reasonable
level of tolerance when calculating whether the Tennessee Department of Education (TDOE) has
met State maintenance of equity requirements in fiscal year (FY) 2023 under the American
Rescue Plan Act of 2021 (ARP Act). This written plan applies only to a subset of Tennessee’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 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).)

TDOE considers LEAs with memberships below 1,500 students to be small. Under this proposed
threshold, Tennessee has 35 small LEAs out of 148 statewide. TDOE asserts that calculated per-
pupil funding amounts for these small LEAs are significantly affected by small changes in
attendance rates and students’ educational needs. This makes the per-pupil funding amounts in
Tennessee’s small LEAs an imperfect indicator of whether the SEA has achieved the intent of
maintaining equity in funding across LEAs. For its small LEAs, TDOE proposes to implement a
tolerance of up to a 0.62 percent decline in per-pupil funding. Applying this tolerance would
impact one small LEA in FY 2023 that served 0.15 percent of Tennessee’s students.


                                400 MARYLAND AVE., SW, WASHINGTON, DC 20202
                                              http://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.
After reviewing TDOE’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 Tennessee has maintained equity in
FY 2023.

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

                                                    Sincerely,

                                                    Laura Jimenez

                                                    Laura Jimenez
                                                    Director, Office of State and Grantee Relations




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Our copy: department-of-education-4-5-2024-used-response-to-tolerance-proposal-fy-2023-www-ed-gov-f3c8028d5d.pdf
Original: www.ed.gov