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ERS Submits Comment on ESSA

Summary of comments submitted on ESSA's "supplement, not supplant" requirement

We recognize that the future of ESSA’s "supplement, not supplant" regulation is unclear. No matter what happens, states and districts will need to make sure that schools with the neediest students get the resources and support they need, and understanding resources will be a part of this. We hope our detailed work to understand how to make sense of spending data in ways that inform action will be useful in any scenario.

At ERS we have supported district leaders nationwide to align their limited resources with a system-level strategy for improving performance so every school succeeds for every student. As part of this work, we analyze spending across schools to understand whether schools with similar student needs get similar resources, and whether they spend them in ways that are likely to make a difference for student performance. Most recently, we partnered with several large, urban Local Education Agencies (LEAs) to analyze the impact of the compliance tests proposed under ESSA, focusing on whether these tests illuminate challenges related to equity and excellence. Drawing on these experiences, we offered comments on the ESSA regulation that aim to:

    • Ensure that the regulation focuses LEAs’ attention on strategies that will engender equity and excellence
    • Reduce the compliance burden on LEAs

We believe that the proposed regulation is an important first step toward meeting its goals, but that there are critical opportunities to improve it.

Promoting Equity and Excellence

Our comments target strategies that promote both equity and excellence—in other words, how many resources schools receive and how well they use them. We argue that while it is indeed important to measure per-pupil spending at the school level, that metric alone gives us imperfect information about resource equity. We propose that districts should receive a significant exemption from the supplement, not supplant requirement if they can demonstrate that high-need students are achieving excellent outcomes across the board, or that they have equitable access to high-quality educational resources that aren’t tied to funding.

Additionally, we suggest the following modifications to the supplement, not supplant requirement to clarify reporting and better embody the spirit of the law:

  1. Clarify what resources should be included in the per-pupil calculation: The regulation should state more explicitly what should be reported at the school level. This ensures comparability across districts and captures the full set of school-level resources.  Currently, districts may report their per-pupil number in many different ways. For instance, staff who actually work in schools may be paid out of central budgets, rather than school accounts. If districts use different practices or do not fully report school level staff, this practice can mask inequity.

  2. Encourage a variety of strategies to indicate that students receive equitable resources: The regulation should make it clear that districts have multiple avenues to guarantee that Title 1 schools receive a fair level of resources. Currently, the regulation could be interpreted to suggest that raising the average salary level of teachers in the building is the only available strategy for achieving financial equity. By using language that includes multiple strategies—like providing extra coaching resources, additional staff, stipends for highly effective teachers to work in high needs schools—the regulation will recognize important equity strategies in addition to increasing average teacher salary levels.

  3. Recognize that certain types of spending can be mistaken for resource inequity: The two biggest causes of significant per pupil spending differences are total student enrollment (school size) and the number of special education students. The spending variation that results from these two factors are not accurate indications of an “equity and excellence” problem. We propose a strategy for adjusting reporting results to account for these potentially misleading results.

The Department of Education is striving to create safeguards for high-need students while reducing the compliance burden on LEAs. We think the best way to do this is to (1) clearly define equity and (2) focus district strategies on achieving equity while giving them as many avenues to meet it as possible.

Download Our Comments on ESSA (PDF)

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