ERS Comments on ESSA Supplement, Not Supplant Regulation

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 a district should receive a significant exemption from the supplement, not supplant requirement if it demonstrates 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.