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

Summary

A letter dated April 5, 2024 from the U.S. Department of Education, Office of Elementary and Secondary Education, to the Honorable Ryan Walters, State Superintendent of the Oklahoma State Department of Education. The letter states that the Department received Oklahoma's written plan for a reasonable level of tolerance when calculating whether it met State maintenance of equity requirements in fiscal year 2023 under the American Rescue Plan Act of 2021, applying only to a subset of local educational agencies. It states that OSDE considers LEAs with an average daily membership of fewer than 1,000 students to be small. It states that OSDE proposes two tolerance levels, including a nine percent reduction in per-pupil funding for LEAs with 200 or fewer students.

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Full text

                          UNITED STATES DEPARTMENT OF EDUCATION
                          OFFICE OF ELEMENTARY AND SECONDARY EDUCATION




                                          April 5, 2024

The Honorable Ryan Walters
State Superintendent
Oklahoma State Department of Education
2500 North Lincoln Boulevard
Oklahoma City, OK 73105

Dear Superintendent Walters:

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

OSDE considers LEAs with an average daily membership (ADM) of fewer than 1,000 students
to be small. OSDE asserts that calculated per-pupil funding amounts for these small LEAs are
significantly affected by minor changes in attendance rates and students’ educational needs. This
makes the per-pupil funding amounts in Oklahoma’s small LEAs an imperfect indicator of
whether the SEA has achieved the intent of maintaining equity in funding across LEAs.

Accordingly, OSDE proposes the following two tolerance levels:
   1) For LEAs with an ADM of 200 or fewer students, Oklahoma proposes to tolerate a nine
      percent reduction in per-pupil funding from year to year. This would impact nine LEAs


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      identified by the State as meeting the definition of high-need or highest-poverty in
      FY 2023 that collectively served 0.14 percent of Oklahoma’s students.
   2) For LEAs with an ADM between 200 and 1,000 students, Oklahoma proposes to tolerate
      a five percent reduction in per-pupil funding from year to year. This would impact 12
      LEAs identified by the State as meeting the definition of high-need or highest-poverty in
      FY 2023 that collectively served 0.8 percent of Oklahoma’s students.

After reviewing OSDE’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 Oklahoma has maintained equity for
small LEAs in FY 2023.

Data provided by OSDE indicate that Oklahoma may need to make additional payments to LEAs
that experienced disproportionate reductions in per-pupil funding in FY 2023 and are not
captured by this 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: Oklahoma.OESE@ed.gov.

                                                   Sincerely,

                                                   Laura Jimenez
                                                   Laura Jimenez
                                                   Director, Office of State and Grantee Relations


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