Minnesota — United States Department of Education to the Honorable Willie Jett (June 23, 2023)

Summary

Commissioner Willie Jett of the Minnesota Department of Education is told in a June 23, 2023 letter from Laura Jimenez that the Department finds Minnesota's tolerance proposal reasonable for maintenance of equity in fiscal years 2022 and 2023. Minnesota treats LEAs with fewer than 864 students as very small, which covers 321 LEAs in FY 2022 and 320 in FY 2023 out of 576, and tolerates a 10 percent decline in per-pupil funding. That would affect 31 such high-need or highest-poverty LEAs in FY 2022 and 38 in FY 2023, serving 0.95 percent and 1.23 percent of students. The Department adds that Minnesota must still make additional payments to four LEAs outside the proposal and report back.

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Full text

                           UNITED STATES DEPARTMENT OF EDUCATION
                                OFFICE OF ELEMENTARY AND SECONDARY EDUCATION




                                                    June 23, 2023

The Honorable Willie Jett
Commissioner of Education
Minnesota Department of Education
400 NE Stinson Blvd.
Minneapolis, MN 55413

Dear Commissioner Jett:

The U.S. Department of Education (Department) received your written plan for a reasonable
level of tolerance when calculating whether the Minnesota Department of Education (MDE) 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 Minnesota’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 MDE, Minnesota’s State funding formula includes a base
allocation for all students as well as weighted funding for students that varies by grade level. In
the context of the funding weights, MDE asserts that per-pupil funding amounts for its very
small LEAs are significantly affected by small changes in attendance shifts between grade levels.
This makes the per-pupil funding amounts in Minnesota’s very small LEAs an imperfect
indicator of whether the SEA has achieved the intent of maintaining equity in funding across
LEAs. MDE considers LEAs with memberships of fewer than 864 students to be very small.
Under this proposed threshold, Minnesota had 321 very small LEAs in fiscal year (FY) 2022 and
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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
320 very small LEAs in FY 2023 out of 576 total LEAs statewide. For its very small LEAs,
MDE proposes to tolerate a 10 percent decline in per-pupil funding in FYs 2022 and 2023.
Applying this tolerance would impact 31 very small LEAs identified by the State as meeting the
definition of high-need or highest-poverty in FY 2022 and 38 very small LEAs in FY 2023.
Together, these districts served 0.95 percent of Minnesota’s students in FY 2022 and 1.23
percent of students in FY 2023.

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 Minnesota has maintained equity for
very small LEAs in FYs 2022 and 2023.

Finally, MDE’s proposal indicates that Minnesota will need to make additional payments to four
LEAs that experienced disproportionate reductions in per-pupil funding in FY 2022 and are not
captured by this very small LEA tolerance proposal. Please advise the Department when these
additional payments have been made.

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

                                                   Sincerely,
aura Jimenez
                                                   Laura JimenezJimenez

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

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