October 31, 2016

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49 Superintendent State Associations Submit Joint Response to USED "Supplement, Not Supplant" Regulations

Earlier today, 49 superintendent state associations submitted a joint letter in response to USED's proposed regulations on "Supplement, Not Supplant" (SNS) within Title I of the Every Student Succeeds Act (ESSA). (The state of Hawaii does not have a superintendent state association.)

The signatories represent a nation-wide response to the proposal and a unified voice in expressing specific concerns with USED's proposal. The letter was submitted in an effort to inform USED's work in the hope that the final rule will be revised and improved. In signing the letter, each state association Executive Director wrote,:

"...We write to express our deep concern with the U.S. Department of Education’s (USED) proposed regulations related to the ‘Supplement, not Supplant’ (SNS) provisions of Title I in the Every Student Succeeds Act (ESSA). The regulations represent new, far-reaching federal mandates dictating how local school districts spend their state and local funds and are in conflict with the spirit and intent of the underlying statute, which is premised on state and local control. 

"ESSA’s reform of SNS should not be an opportunity for USED to exert unprecedented influence over the more than 90 percent of K-12 funding generated by state and local districts. It must be an opportunity for the flexible, but high expectations for equity in ESSA to drive improvement in our nation’s schools. 

"We are committed to working together with our state and local education agencies and associations to guarantee the success of this new law. This includes the important work our members have built their careers around (providing students with excellent educational opportunities) and the role of equitable resources in supporting educational achievement. We, as state association executives, came together to support ESSA in part for its continued commitment to equity, including strong bipartisan support for ensuring that Title I dollars continue to be in addition to—not in place of—state and local dollars. We come together again, now, in response to the USED regulations to ensure that the final rule supports the important work of ESSA and the SNS provision without unnecessarily disrupting existing efforts to improve resource equity.

"Our members are very familiar with education finance, an understanding that highlights how USED’s proposed SNS regulations run counter to the very goal they aim to address: ensuring students have access to equitable education resources. Because compliance with the proposed regulation would be based on spending thresholds, districts would have to centrally manage all decisions that affect costs. The proposal would force school personnel to make the difficult decision of compliance over meeting the needs of the students they serve...." Read the full letter.

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