TSS Blog

TISA Draft Rules Public Comment Period Now Open

The Tennessee Department of Education recently released draft rules of the newly adopted Tennessee Investment in Student Achievement (TISA) funding formula. The public is encouraged to comment on these draft rules by emailing the department directly or sending letter by mail to the address listed on the department website. Comments will be collected until August 2, 2022.

This spring, the department provided helpful TISA explainer resources breaking down the pieces of the funding formula into different funding types – base funding, direct funding, weighted funding, and outcomes funding. These pieces work together to give predictable funding framework for state and local administration. What follows are helpful suggestions to inform parents and community advocate involvement in the public comment process.

Unique Learning Needs Weighted Funding – Students with Disabilities

The process by which students are identified for Unique Learning Needs (ULN) should be consistent and transparent, following existing state board requirements and school-based frameworks.

  • Draft rules should include 504 plans as an eligibility option.
  • Draft rules should incorporate Special Education Option Codes into ULN definitions.
  • Draft rules should align with Dyslexia Resource Guide screening procedures.

Current draft rules specify the use Individualized Education Plans (IEPs) as an eligibility requirement. Including 504 plans as an eligibility requirement would ensure that students not eligible for IEPs receive funding for needed accommodations. The current rulemaking draft assigns students to ten different levels of need (known as Unique Learning Needs) based on hours of service per week. Referencing Special Education Option Codes in ULN definitions would add clarifying details to calculate services more accurately. There is concern from dyslexia advocacy groups that draft screening requirements are too stringent. Screening processes should be realigned with existing dyslexia screening framework found in the department’s Dyslexia Resource Guide.

Unique Learning Needs Weighted Funding – English Learners (ELs)

The process for identifying English learners should be consistent and transparent, across all ULN levels.

  • Draft rules should specify the use of WIDA or TCAP assessments across all levels.
  • Draft rules should add consideration of previous formal learning in native language.
  • Draft rules should create a minimum threshold for ELs funding for staffing at scale, and additional funding for students whose native languages are less common.

Under current draft rules, ELs can be categorized into three ULN levels, with each level having varying screening processes. All three levels should use the same screening process for consistency of administration and tracking. Rules should also weigh previous formal native language learning experience. Students proficient in reading and writing in other languages have very different needs than ELs that have been transient or experiences fewer opportunities for formal education. Districts with fewer ELs and those with numerous, less common languages, need minimum thresholds of funding to scale staffing for school-specific learning needs.

Direct Funding and Outcomes Funding

Unlike weighted funding, which comprises of shared state and local contributions, direct funding and outcomes funding are comprised solely of state-level contributions. These contributions are dependent on yearly allocations agreed upon by the State Board of Education, Department of Education, and the General Assembly.

  • How will stakeholders be involved in direct funding allocation discussions, to ensure equitable funding?
  • How will the General Assembly determine outcomes funding every year? How will stakeholders participate? Will annual funding availability and district performance be published each year?
  • Growth scores should be used to determine outcomes funding for students with disabilities, not just highest achievable scores, to ensure equity and inclusivity.

The necessity of transparency and accountability were overriding themes during legislative committee discussions surrounding TISA. It is of the utmost importance that direct funding and outcomes funding processes clearly explain how allocations will be monitored and adjusted, by whom and in what time frame.

Public Comment Period – When and Why it Matters

Public comment is a powerful tool to shape the new funding formula processes and procedures at the state and local level. We encourage parent and community advocates to make your voices heard. Public comment can be given by an individual or facilitated by a group of likeminded parents or community members. Submit your comments on the TISA draft rules by email or mail by August 2, 2022.

TSS will continue to monitor the rulemaking process with regular blog updates. Sign up to receive update notifications by email.

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