Letter to the Michigan Department of Education — Reasonable Level of Tolerance (April 5, 2024)

Summary

In an April 5, 2024 letter to Michigan Superintendent of Public Instruction Michael F. Rice, the Department of Education accepts the Michigan Department of Education's written tolerance plan for FY 2023 maintenance of equity, under the name of Laura Jimenez, Director of the Office of State and Grantee Relations. Michigan treats LEAs with memberships under 400 students as very small, which covers 230 of its 832 LEAs and 3.1 percent of students, and proposes tolerating up to a 10 percent decline in per-pupil funding. Applying that tolerance would affect seven very small LEAs serving 0.1 percent of students, and the Department finds the approach reasonable.

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Cite this document

“Letter to the Michigan Department of Education — Reasonable Level of Tolerance (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-l-f357af8450/, SHA-256 e603bd0e1aa09e80d6566e5de5a764415e0f049ea66ae745b750bba2298bb2ba.

Full text

                          UNITED STATES DEPARTMENT OF EDUCATION
                          OFFICE OF ELEMENTARY AND SECONDARY EDUCATION




                                         April 5, 2024

The Honorable Michael F. Rice
Superintendent of Public Instruction
Michigan Department of Education
608 West Allegan Street
Lansing, MI 48933

Dear Superintendent Rice:

The U.S. Department of Education (Department) received your written plan for a reasonable
level of tolerance when calculating whether the Michigan Department of Education (MDE) 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 Michigan’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).)

MDE considers LEAs with memberships of fewer than 400 students to be very small. Under this
proposed threshold, Michigan has 230 very small LEAs, out of 832 total LEAs statewide, that
serve 3.1 percent of Michigan’s students. MDE asserts that calculated per-pupil funding amounts
for these very small LEAs are significantly affected by small changes in attendance rates and
students’ educational needs. This makes per-pupil funding amounts in Michigan’s very small
LEAs an imperfect indicator of whether the SEA has achieved the intent of maintaining equity
in funding across LEAs. For its 230 very small LEAs, MDE proposes to implement a tolerance
of up to a 10 percent decline in per-pupil funding. Applying this tolerance would impact seven
very small LEAs that served 0.1 percent of Michigan’s students in FY 2023.
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After reviewing MDE’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 Michigan has maintained equity for
very small LEAs in FY 2023.

We appreciate your diligence in developing this proposal. If you have any questions, please
contact your program officer at: Michigan.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-letter-fy-2023-www-ed-gov-1d4dfc8c76.pdf
Original: www.ed.gov