Letter to the Louisiana Department of Education — Reasonable Level of Tolerance (June 12, 2023)

Summary

A letter dated June 12, 2023, from the Department of Education Office of Elementary and Secondary Education to State Superintendent of Education Brumley of the Louisiana Department of Education, responding to its written plan for a reasonable level of tolerance under State maintenance of equity requirements. It reports that Louisiana has 52 very small LEAs out of 124 statewide, defined as memberships of fewer than 1,000 students, and a proposed tolerance of up to a 10 percent decline in per-pupil funding. It states that the Department determined the approach reasonable and that Louisiana may need to make additional payments to other LEAs.

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                           UNITED STATES DEPARTMENT OF EDUCATION
                                OFFICE OF ELEMENTARY AND SECONDARY EDUCATION




                                                    June 12, 2023

The Honorable Cade Brumley
State Superintendent of Education
Louisiana Department of Education
1201 North Third Street
Baton Rouge, LA 70802-5243

Dear Superintendent Brumley:

The U.S. Department of Education (Department) received your written plan for a reasonable
level of tolerance when calculating whether the Louisiana Department of Education (LDOE) 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 Louisiana’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 LDOE, Louisiana’s State education funding formula
includes a base allocation for all students as well as weighted funding for students who require
additional services. In the context of the funding weights, LDOE asserts that calculated per-pupil
funding amounts for its very small LEAs are significantly affected by small changes in
enrollment. This makes the per-pupil funding amounts in Louisiana’s very small LEAs an
imperfect indicator of whether the SEA has achieved the intent of maintaining equity in funding
across LEAs. LDOE considers LEAs with memberships of fewer than 1,000 students to be very
small. Under this proposed threshold, Louisiana has 52 very small LEAs out of 124 statewide.
                                400 MARYLAND AVE. SW, WASHINGTON, DC 20202
                                               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
For its 52 very small LEAs, LDOE proposes a tolerance of up to a 10 percent decline in per-
pupil funding. Applying this tolerance would impact three very small LEAs identified by the
State as meeting the definition of high-need or highest-poverty in fiscal year 2022; together,
these districts served .28 percent of Louisiana’s students.

After reviewing LDOE’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 Louisiana has maintained equity for
very small LEAs.

Finally, data provided by LDOE indicate that Louisiana may need to make additional payments
to LEAs that experienced disproportionate reductions in per-pupil funding in FY 2022 and that
are not captured by this tolerance proposal. Please keep the Department informed as LDOE
resolves any supplemental payments.

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

                                                   Sincerely,
aura Jimenez
                                                   Laura Jimenez

                                                   Laura Jimenez
                                                   Laura Jimenez
                                                   Director, Office of State and Grantee Relations
                                                   Office of Elementary and Secondary Education


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