I’ve been very bad about posting recently but we’ve been busy! After the State Board meeting last week, we spent a lot of time reviewing the CDE’s selection of schools to receive SIG grants. We were very distressed by both the selection process and the “reform” strategies outlined in the applications of the low performing schools recommended by CDE for funding. Based on these concerns, we sent the following letter to Ted Mitchell, President of the State Board of Education.
On behalf of the Education Trust—West, I am writing to express our concerns about the California Department of Education’s (CDE) funding recommendations for the 2009-10 School Improvement Grant (SIG). Our concerns are focused on two primary areas: the grant award process and the school improvement strategies selected for funding. We strongly encourage the CDE and the State Board of Education (SBE) to revisit the grant award process to reconsider the applications of those districts and schools that did not receive funding, and to only fund the portions of SIG applications that are directly related to reform.
First, we believe that the grant award process used by the CDE was flawed. Current recommendations would provide SIG funding to only 66 schools serving some 60,000 students, leaving dozens of schools serving tens of thousands of students without funding. The intent of the SIG program is to fund high-impact reforms in as many eligible schools as possible. By prioritizing the applications of only those Local Education Agencies (LEAs) that applied on behalf of all eligible Tier I and II schools, the CDE artificially restricted the pool of districts and schools eligible to receive funding. This selection process unfairly penalized large, mostly urban school districts with many eligible Tier I and II schools, resulting in a disproportionate benefit for districts with a small number of eligible Tier I or II schools.
According to CDE, “the priorities for funding established by the U.S. Department of Education (ED)” were based on the proportion of eligible schools that LEAs committed to serve. This interpretation does not appear to conform to either the letter or the intention of the SIG guidance from the ED. Additionally, the CDE’s Request for Applications (RFA) does not indicate that LEAs would be penalized for failing to apply on behalf of all of their eligible Tier I and II schools. In fact, the CDE’s scoring rubric encourages LEAs to make decisions based on their capacity to implement reforms at each of their schools applying for funding. It also asks LEAs to identify the barriers that would preclude them from serving all of their Tier I and II schools. We were encouraged that the federal SIG regulations repeatedly mentioned the need for districts to consider their overall capacity and the capacity of individual schools to implement reforms when submitting applications. It is unfortunate that this positive aspect of the application process led to such a negative outcome for so many schools and their students.
Indeed, rather than creating artificial restrictions, we believe that the SIG guidance provides states with the flexibility to fund as many Tier I and II schools as possible. For example, the guidance notes that if a state does not have sufficient funding to serve all Tier I and II schools, it can consider the distribution of eligible schools among LEA’s to ensure that the full range of Tier I and II schools in the state can be served. This should similarly allow California to consider other factors in the distribution of funding such as the proportion of elementary, middle and high schools, their geographic distribution and the poverty level of their students.
Lastly, the federal requirement that states carry over 25% of grant funds if all Tier I schools do not apply may not be relevant to California, where there are insufficient dollars to fully-fund all Tier I schools that did apply. We are pleased that the SBE has appealed for a waiver of this requirement from the ED because we believe that these dollars should be distributed to schools as soon as possible.
In regards to our second concern, we are outraged that the CDE did not pursue a more selective process in reviewing the “reform strategies” in the applications submitted by LEAs. In our May 2010 report, “Keeping the Promise of Change: Why California’s chronically underperforming schools need bold reforms,” we called on the CDE to adhere to the pledge included in the RFA, that it would “only consider awarding funds to those LEAs that develop and submit a comprehensive and viable application likely to improve student achievement.” We see little evidence of these bold reform strategies, particularly in areas such as recruiting, evaluating and retaining the best teachers and leaders. With SIG, California had an unprecedented opportunity to establish a rigorous and selective application review process that prioritized high-impact reforms that are different from the turnaround strategies previously utilized in so many of these persistently underperforming schools. It was disappointing to see so many of the same recycled reforms and interventions in the applications selected for SIG funding.
We do not believe that SIG money is intended to fulfill wish lists or plug budget holes for a few lucky schools. The CDE should have only recommended funding for those elements of schools’ intervention plans that are likely to result in improved student achievement. SIG dollars should not be funding certain “interventions” that appeared in the SIG Application Profiles, such as leasing bus drivers, sound systems, or funding longevity stipends. Our recommendation does not imply that reforms do not cost a lot of money or that they should instead be done on the cheap—just the opposite. SIG dollars should be used to fund transformative reforms, and not to backfill budget cuts. The CDE had both the discretion and obligation “reduce award amounts if it determines that an LEA can implement its planned interventions with less than the amount of funding requested in its budget.” When only 66 Tier I and II schools out of 113 applicants are funded due to limited funds, it is incumbent upon the CDE to use that discretion versus funding every “intervention” placed in an application.
As we noted in “Keeping the Promise of Change,” Einstein states that the definition of insanity is “doing the same thing over and over again and expecting different results.” The hundreds of thousands of students in poverty and students of color in California’s persistently underperforming schools deserve great neighborhood schools that will prepare them for college and enriching careers. We hope that the State Board of Education will ensure that the School Improvement Grants are used to end the cycle of underperformance that has widened the achievement and opportunity gaps for so many of our state’s neediest students.
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