July 25, 2022
Last week, state board members had the opportunity to discuss the department’s proposed rules for the Tennessee Investment in Student Achievement (TISA) Act funding formula. Board member discussion focused on district-level implementation processes related to each type of funding within the formula (base, weights, direct, outcomes bonuses) as well as distribution of funds and accountability measures.
The department emphasized the statue-driven nature of the rules and acknowledged that the outcomes bonuses portion of the rules offer the most flexibility for changes. What follows are areas of the proposed rules that public education advocates and parents may wish to consider when drafting public comment submissions.
Considerable attention was given to the process of identifying students for Unique Learner Needs levels (ULNs). ULNs for students with disabilities (including students with 504 plans, gifted students, and students with characteristics of Dyslexia) must have corresponding assessments and individualized education plans designating specific direct services to be eligible for ULN funding. Medical diagnosis alone will not qualify students for ULN funding.
The Education Trust presented feedback urging the department to reconsider time-based funding. Instead, ULNs should be funded through a multiple weight system based on specific disabilities. They urged that funding based on hours alone fails to accurately capture the cost variances between different types of interventions and accommodations – which could negatively impact funding for additional staffing needs at school level.
The Education Trust also urged for a more holistic and consistent identification process for English learners (Els). Level of English proficiency (WIDA scores), amount of time in formal education settings (domestic or abroad), and time in the United States should drive ULN funding, not grade level alone. Additionally, individualized learning plans for English learners must be standardized statewide to ensure consistency of services and funding.
State board members discussed CTE program funding at length. Prior to TISA, all CTE programs were funded equally. To incentivize program completion (not just participation) TISA will rank levels of progression in increasing value throughout the program of study as well as additional funding for in-demand and high-wage career pathways.
The department explained the new leveling process by which CTE programs will be ranked to determine funding eligibility. The leveling process utilizes the Jobs4TN platform data to determine the number of open positions statewide as a proxy for job demand. The state board acknowledged that data from Jobs4TN is not an exhaustive measure for job demand since many employers do not utilize the site to post jobs. The department should instead utilize a different data source to calculate job demand.
The board also cautioned that the proposed course leveling process may give priority to occupations in larger cities to the disadvantage of programs needed in rural and suburban areas. The CTE program leveling process needs to be regionally specific to ensure increased accuracy of in-demand and high-wage occupation data for each district. Accurate data is essential for informed program planning at the district level.
Outcomes bonuses are a new concept in K-12 public education funding in Tennessee. For this reason, the goals for outcomes bonuses should be kept simple to ease the implementation process statewide. Tennessee SCORE presented public comment asking the board to keep student outcome measures as consistent as possible across all student groups to ensure school districts understand how funding will be generated. Tennessee SCORE also recommended that the state use consistent growth measures to reward districts for all progress that exceeds expectations, not just on-track or mastery proficiency scores.
Tennessee SCORE asked the board to limit the high school outcome bonuses measure to utilize only the Ready Graduate indicator already in place to simplify eligibility requirements. They also encouraged the board to add a post-graduate readiness outcome measure to reward schools that effectively help students transition to career or higher education opportunities after graduation.
Additionally, Tennessee SCORE recommended that the rules should specify how outcomes bonuses are allocated within the district, to empower local leaders to make decisions that benefit them most. Currently the rules do not specify if the funding must go to the school where funds were generated or if those funds can stay at the district level.
Requiring outcomes bonuses to flow to the schools where they were generated would immediately benefit at-risk, vulnerable, and high-need students populations at public charter schools and alternative schools.
TSS encourages the general public to continue to submit comments and suggestions to the department by email or letter by mail to the address listed on the department website. The public comment period continues until August 2, 2022.
Following the public comment period, the department will utilize feedback to amend rules where possible. TSS will continue to follow the public comment hearing on Thursday and state board formal recommendations at the special called meeting held on August 11, 2022.