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Testimony of Mrs. Wanda
Rushing-Jones U.S. House of Representatives Hearing On: Brushy Creek Elementary School Mr. Chairman and Members of the Committee, I appreciate this opportunity to testify before you today on the implementation of the school choice and supplemental services requirements of Title I of the Elementary and Secondary Education Act of 1965, reauthorized by the No Child Left Behind Act of 2001. I would like to share with you the State perspective on implementation of these provisions as they relate to South Carolina. Numbers of Schools in School Improvement for the 2002-03 School Year – 27 total Number to implement choice only – 12 schools Number to implement choice and supplemental services - 15 schools School Improvement for the 2003-04 School Year Preliminary School Improvement List and Parental Notification South Carolina, as many states, does not receive test information from the test contractor in sufficient time to allow a final school improvement list to be available prior to the start of school. Therefore, our State’s accountability plan, as approved by the United States Department of Education (USDE), required the development of a preliminary school improvement list. The preliminary school improvement list was disseminated to districts on July 14, 2003. Districts and schools were required to proceed with notices to parents of choice and supplemental services options for the current school year based upon preliminary school improvement identification. Any school identified for improvement on the preliminary list, but not identified on the final school improvement list, was required to honor any commitments made to parents regarding choice and supplemental services which resulted from the school’s preliminary school improvement identification status. Final School Improvement List The districts and schools received final adequate yearly progress status charts based on the 2003 test results on August 28. Districts and schools were given time to review their data for accuracy. The final school improvement list was disseminated to districts on September 29. Schools and districts were given until October 8 to question their school improvement status. The school improvement list is currently being posted to the department’s web site. Number of Schools in School Improvement for the
2003-04 School Year – Number to implement choice only – Number to implement choice and supplemental services -
Dissemination of School Improvement Requirements to Local Districts The law, regulations, and guidance documents are posted on the department’s web site. Districts are sent e-mail updates immediately upon receipt of any new interpretation of the law, guidance, or information obtained through attendance at conferences/USDE meetings. Meetings have been held with districts. An initial meeting was held with all schools identified for improvement along with their district staff on April 23, 2002 to inform them of the new choice and supplemental services requirements, as well as the school improvement requirements. A follow-up meeting was held on February 20, 2003 to discuss new information and issues related to implementation of these requirements. Follow-up calls were made to each of the districts with schools identified for improvement on a bi-weekly basis for an extended period of months to determine the progress made in implementing both choice and supplemental services and to identify any areas of problems or concerns. Questions/issues were shared with the United States Department of Education for response as warranted. Presentations were also made to districts at both a fall and spring conference to update them on new interpretations of the law. A meeting was held May 15 and 16, 2003, with the first day being devoted to an overview of each component of the law, regulations, and guidance. The second day was spent in small group concurrent sessions providing hands-on activities and materials to assist the districts in implementing various new provisions of the law, specifically choice and supplemental services. Districts were provided with sample contracts to use for supplemental services. New draft guidance on supplemental services was received on August 22, 2003. A one-day meeting was held with all districts on September 23, 2003, to present the new guidance and to also discuss the process for school improvement plan development. At that time, information was also shared on how to complete a contract with supplemental service providers and parents. A training for new Title I Coordinators is also held on an annual basis. School Choice Process - As noted, districts were advised to notify parents of the choice option based upon the preliminary school improvement list. The recommended means of notice was by letter and newspaper, at a minimum. For the 2002-03 School Year: Numbers of Students Eligible – 11,744 Number of Students Opting for Choice - 519 Number of Choice Option Schools- 32 For the 2003-04 School Year: Number of Students Eligible – 38,463 Number of Students Opting for Choice – 1,345 Number of Choice Option Schools - 81 Issues and concerns related to choice: School capacity - Although this is not an exemption for choice, it still poses a problem that must be considered. Need for additional staff at receiving schools – With limited State and local resources, it is difficult to accommodate the staff needs of the students opting to transfer. Many of the transfer option schools are not receiving Title I funds. Concern for comparability among schools - Will the addition of staff for choice students result in the district not being able to meet comparability requirements under Title I of the law, whereby state and local resources must be demonstrated to be at least comparable on a per pupil expenditure or instructional staff per pupil ratio basis between Title I and non-Title I schools, or if all schools are Title I served, then among all Title I schools? Transportation – Although most of our districts have been able to establish new bus routes within their current system of operation, Greenville has been unique in having to lease buses to establish new routes. A response was received from USDE, after much deliberation, that a bus could be purchased for transporting choice students. However, issues for consideration were shared by USDE staff. The issues were: How will transportation be supplementary to the mileage the child would have been entitled to at his regular school; and If there is no longer a need for choice transportation, how will the district dispose of the bus? This information was shared with the district for their consideration. Supplemental Services For the 2002-03 School Year: Number of Applications Received: 58 Number of Approved Providers: 30 Number of Approved Providers for Greenville: 5 Number of Students Eligible for Supplemental Services Statewide – 9,662 Number of Students Statewide Receiving Supplemental Services: 297 For the 2003-04 School Year: Number of Applications Received: 64 Number of Approved Providers: 25 Number of Approved Providers for Greenville: 6 Number of Students Eligible for Supplemental Services Statewide – 30,921 Number of Students Statewide Receiving Supplemental Services: Yet to be Determined (Parent meetings and contracts are underway.) The South Carolina approval process for providers is an annual requirement. The rationale for this decision was to ensure the approval of quality applications. As we have learned more about the requirements of supplemental services and the challenges presented with implementation, we have tried to refine the application, rubric for scoring applications, and the monitoring process to address these issues. Monitoring of Supplemental Service Providers All approved providers for the 2002-03 school year that provided services to students eligible under this law were monitored. The monitoring instrument and technical standards were shared with the provider prior to the review. The monitoring was conducted by a team of individuals who brought their own expertise to the group. The knowledge base of the group included knowledge of the law, knowledge of state content standards, curriculum, and assessments, and/or experience in the process of audits, including both programmatic and fiscal. The monitoring was initially conducted by phone interview with the provider, parents and students served by the provider (to the extent of their availability), and district Title I coordinators in districts where services were rendered. A need was also seen for on-site visits to the providers to review instructional materials and instructional delivery. Monitoring included a review of compliance with the approved application, the contract with the parent and district, the integrity of the provider, satisfaction of parents and students, as well as other critical issues. The effectiveness of the provider was not reviewed this past year since the period of service delivery was limited, as a result of the mid-year implementation allowed by USDE. The monitoring results were posted on the department’s web site. Also, monitoring issues were taken into consideration in the new round of application reviews for approval of providers. Dissemination of Information to Providers and Parents Districts were asked to discuss the requirements of the law for supplemental services with the providers. General information regarding the law, regulations, and guidance was shared with providers in the mailing by the State notifying them of their status as a State-approved provider. Information has also been posted on the State department’s web site for providers and parents to reference. Districts were encouraged to go beyond notifying parents of the opportunity for supplemental services. It was recommended that they hold meetings at the school level to allow parents to hear presentations from the approved providers prior to making a selection of a provider for their child. This year as part of the application process, the State required a one-page summary of the provider’s services, qualifications, and demonstrated effectiveness, as required to be disseminated to parents to aid them in making their selection of provider. This summary page was lifted directly from the application of all approved providers and was shared with districts for dissemination to parents. To date, districts have begun the supplemental services process. Greenville, for example, has notified parents of their supplemental services option and they are currently holding school meetings to share with parents the services of providers, thereby enabling parents to make informed decisions. Issues Related to Supplemental Services Delay of implementation due to choice - As the law is written, the percent of funds set-aside to implement choice transportation must first be determined in order to know how much is available to fund supplemental services. This often delays the implementation of supplemental services. Per pupil allocation - Many providers have expressed concern about the formula used for determining the per-pupil cost rate for the provision of supplemental services. For-profit providers are often not willing to provide services for $800 or $900 per child, which is often the amount available in our State. Limited willingness to participate in monitoring - We found that many district staff and parents were hesitant to discuss with us problems/concerns with providers for fear of a legal challenge from the for-profit providers. Use of school facilities - Greenville, for example, has a Board policy that prevents the use of school facilities by outside groups after school. Although we have encouraged districts to cooperate with providers on facility use, and we have shared with them the option to charge rent of providers, districts are reluctant to allow the use of their space, often due to liability concerns. One provider has indicated already that they will not provide services in Greenville since they cannot offer their services on-site. Another provider has expressed a similar concern, however, they are attempting to look for a community partner to house their services. Last year, we had once such instance in one of our rural areas. As we worked with the provider, they were able to rent a community space where they could offer services. We are in the process of contacting the providers that are having difficulty finding space to see how we might assist them. Further, we plan to consider including some additional reference to this in our application. Providers for rural areas – Only a limited number of providers are willing to work in rural areas. The for-profit providers do not feel it is cost efficient for them to travel to those areas. Thus far, distance learning has not been a solution to this problem. Based on our prior year’s monitoring, we have concerns about both quality of services and privacy of students with distance learning. However, we are still open to appropriate distance learning options. Minimum number of students for service - In some of our large districts, we are encountering problems with providers that agree to provide services, but then refuse to go into the district unless they can provide services to a minimum number of students. Our office tried to address this problem through the application process this past review cycle, but we are already beginning to see this issue surface again. Required set-aside of funds for choice and supplemental services - Many districts are concerned about having to withhold up to 20 percent of their Title I funds for choice and supplemental services. Although we have shared with them our most recent information from USDE which allows them to reallocate the funds around early November after they have implemented these components of the law, it is difficult for the district to reallocate those funds in a meaningful way to benefit their schools at that time. It is too late to consider serving additional schools. In the recent guidance on supplemental services, a provision allows the use of other fund sources to meet the 20 percent requirement. This information was shared with districts at a meeting last month. The provision may offer relief for some districts, but not all because state and local funds are limited. Additionally, districts are faced with having to expend Title I funds in a timely manner in order to meet the 15 percent carryover provision of the law. Failure to meet this requirement will result in the loss of any excess funds above the allowed 15 percent. In closing, South Carolina initiated implementation of supplemental services and choice based upon our best knowledge and understanding of the law. We have worked through many of the issues related to choice, and we are anxiously awaiting the release of new guidance on choice in hopes that it will offer further insight into implementation. As for supplemental services, we began the process with a three page application for providers, based solely on the law. Now, we have a comprehensive 15 page application which reflects the latest guidance and seeks to address some of the issues that surfaced in our initial implementation of supplemental services. There are many issues that we are only beginning to learn about, and we are facing each new challenge as a learning opportunity that will help us to better serve our children. Mr. Chairman, this concludes my statement. I would be happy to answer any questions you or the other Members may have. |