January 31, 2020

(THE ADVOCATE) Permanent link

The February Advocate

Each month, the AASA policy and advocacy team writes an article that is shared with our state association executive directors, which they can run in their state newsletters as a way to build a direct link between AASA and our affiliates as well as AASA advocacy and our superintendents. The article is called The Advocate, and here is the February 2020 edition.

This January, U.S. Agriculture Secretary, Sonny Perdue, announced newly proposed regulations to the National School Lunch (NSLP) and School Breakfast Programs (SBP) aimed at providing school districts with more flexibilities around the federal school meals’ administrative and nutritional requirements. The impetus for this decision comes from long-standing complaints that the NSLP and SBP are riddled with duplicative monitoring/reporting requirements, as well as burdensome nutritional provisions that contribute to excess food waste and hamper schools' operational capacity to provide students with access to healthy well-balanced meals.

Specifically, the proposed regulations fall under three main categories, (1) proposals to simplify monitoring, (2) strategies to simplify meal service, and (3) modifications to the Smart Snack in Schools Rule. Listed below is AASA's section-by-section analysis of the regulation, which will overview the major provisions of the proposal and its implications on school system leaders.

Proposals to Simplify Monitoring

With regards to the first element of the proposed regulations, USDA is suggesting offering states the option to return to a 5-year Administrative Review Cycle (ARC). For context, the original transition away from a 5-year ARC came as a result of the passage of the Healthy Hunger-Free Kids Act (HHFK), which mandated that USDA switch to the more comprehensive 3-year ARC – which included increased oversight responsibilities, such as the review of procurement practices and procedures – during the 2013-2014 school year. As an unintended consequence of this shift, some districts have reportedly struggled to complete reviews and corresponding oversight activities. Moreover, USDA also received feedback that the shorter ARC reduced the available time for technical assistance and training to districts, and consequently, unduly emphasized compliance over program improvement.

Additionally, under this section of the regulation, USDA would now require State Agencies to review districts– with histories of erroneous meal pattern and nutritional violations – to undergo targeted follow-up reviews to ensure high-risk SFAs comply with the administrative and nutritional requirements of the federal school meal programs.

Overall, AASA was pleased to see that USDA is proposing to move back to the 5-year ARC and to conduct targeted follow up with high-risk districts. Since the initial implementation of HHFK, school system leaders have consistently reported that the shorter 3-year administrative review cycle unnecessarily causes LEAs and SFAs to inefficiently allocate resources toward burdensome compliance-related activities, as well as limits USDA’s ability to build local and state institutions' capacities to properly administer the program. Effectively, this proposal balances the administrative flexibilities of the federal school meal programs with USDA's desire to improve program integrity, and consequently, will represent a victory for our members. Due to this, AASA will advocate for this section of the regulation to be implemented as written.

Strategies to Simplify Meal Service

Primarily, this section of the proposal relates to the nutritional standards that schools must offer children over the week. For example, current rules dictate the type and quantity of vegetables, and minimum and maximum calory counts, that districts' breakfast and lunch meals are required to contain under current law. Upon a comprehensive review of USDA's proposal to this part of the regulation, it is again clear that many of the agency's changes are intended to improve school systems' operation of NSLP and SBP by simplifying menu planning and providing more flexibilities around meal delivery across different grade spans.

Specifically, the agency is proposing to simplify meal planning by making some minor technical changes to LEAs ability to administer the federal school meal programs. For example, current nutritional provisions require that school districts serve at least 1/2 a cup of each of the vegetable subgroups listed in the American Dietary Guidelines over a school week and offer larger quantities of red/orange vegetables to students of all grades. USDA’s proposal would change this by allowing schools to serve the same weekly minimum amount (e.g., 1/2 cup) of vegetables regardless of subgroup designation. The proposed regulation would also enable school districts who use legumes – a consistently under-served and under-consumed vegetable with high protein – as a meat alternate to also count towards HHFK's weekly legume vegetable requirement.

Additionally, the proposal would enable schools with unique grade configurations to use the same meal pattern for a broader group of students; authorize SBP operators to offer students meats, meat alternates, and/or grains interchangeably; and reduce the amount of fruit required for reimbursable breakfasts served outside the cafeteria.

While policies like permitting schools to serve the same quantities of all vegetables and granting LEAs more flexibility in how they credit legumes toward meal pattern requirements may not seem like needle-moving changes, AASA was pleased to see USDA take appropriate steps to reduce operational complexity, support programmatic efficiency, and decrease food waste in schools. For our members, these proposals will ultimately lead to better strategies for serving students.

Modifications to the Smart Snack in Schools Rule

Under this proposal, USDA is also recommending to provide school districts with increased flexibilities around the Smart Snacks in Schools Rule, which establishes the nutritional standards for competitive foods sold to students outside of the school meal programs, on the school campus during the school day, and for entrées sold à la carte. If this proposal is implemented as written, then the agency will extend the entrée exemption timeframe – which applies to items sold as à la carte foods – for two days after that entrée is offered as part of a meal on the SBP or NSLP menu. In layman's terms, this would, for example, enable districts to sell pizza as a standalone item on the day the pizza is also served as part of the unitized school lunch and the following two days afterward. Moreover, this latest update of the rule proposes to permit LEAs to sell calorie-free naturally flavored waters, with or without carbonation, to students in all grade groups. 

For school system leaders, these changes represent long-overdue steps in the right direction that will simplify food procurement systems that will ultimately lead to reductions in food waste. For instance, as a result of this rule, many districts will no longer have to find multiple suppliers for identical food items that will be sold a la carte. This will enable districts to have increased discretion over how to use leftovers throughout weekly meal patterns.

AASA applauds USDA for adapting these tactics to improve local delivery of the NSLP and SBP.

Next Steps: Moving forward, AASA plans to support USDA’s proposed regulations by submitting public comments on the rule that will highlight the positive effects of the agency’s policy change on school system leaders. As part of this effort, we will be mobilizing our membership to show USDA that the regulation has broad support amongst school administrators. As of now, the public comment period for the rule is set to close on March 23, 2020. We'll need all hands on deck to get these regulations through the finish line, so stay tuned for details on how to make your voice heard in the coming weeks.

January 27, 2020

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IDEA funding is up, but federal share is down

Although Congress increased funding for special education grants to state (IDEA Part B) by $400 million for fiscal year (FY) 2020, the federal share of the “excess” cost of educating students with disabilities actually fell from 14.3 percent in FY 2019 to an estimated 13 percent in FY 2020.  (The FY 2019 estimate comes from the Congressional Research Service, and the FY 2020 estimate was provided to us by the Department of Education.)  This happens when the number of students needing services increases and/or as the intensity of needed services increases.  

When Congress enacted the first special education law in 1975, it pledged to provide up to 40 percent of the excess cost of educating students with disabilities but has never come close to this “full funding” percentage. Federal law mandates that school systems provide a free appropriate public education to all students, regardless of the federal contribution.  As a result, when the federal share of the costs declines schools need to use more of their state and local funding for special education.  If the federal government increased its share of the costs then more state and local education funding would be available to cover other education needs.  For FY 2020, Congress would have had to triple the $12.8 billion it provided to reach the full funding. Fully funding IDEA remains AASA's top advocacy priority. 

January 23, 2020(1)

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AASA Joins Letter of Support for Increased Investments to School Facilities

AASA was pleased to sign on to a recent letter to Speaker Pelosi and Majority Leader Hoyer supporting investing in our national infrastructure including local school facilities. AASA is a member of the Rebuild America’s Schools Coalition, which coordinated the letter. The letter comes in advance of an infrastructure finance hearing scheduled for January 29. We urge the committee to include schools in any infrastructure package, and urge our members to contact their Representatives and Senators to support the inclusion of school infrastructure including proven cost effective tax credit bonds to help finance building and repairing public school facilities which will generate local jobs.

 

 

January 23, 2020

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Guest Blog Post: Heads Up Administrators! Time to Help Count Kids

This guest blog post comes from our friends at Partnership for America’s Children.

The Census Bureau just sent its Statistics in Schools materials to every administrator, public and private, in the country. The mailout will contain three colorful large wall maps and a booklet containing information on the program including a take home letter for students to share with their family. They should arrive between January 21 and 31.

Now it’s your turn. Please ask all your teachers to use these materials and to send home the take home flyer. You can also check them out at census.gov/schools/get involved.

When schools use these materials in the classroom, it helps bring in more funding for the schools and money for programs that get kids ready for schools. How? Well, Title I funds for low income schools are allocated based on the number of k-12 children you have in your community, and special education funds are allocated based on the number of 3-21 year olds you have. Funding allocations for programs that help get kids ready to learn, like WIC, child care, Children’s Health Insurance Program, Medicaid, and many others, are also based on the census data in your community and your state. (Teachers and administrators are used to thinking about attendance data affecting funding, but that data is used to allocate money among schools in the district; counting kids brings more money to the district.) So making sure every child is counted helps get kids ready to learn, and helps schools have the resources they need to teach.

The Statistics in Schools materials teach children about the value of census surveys, which helps get young kids counted in three ways; many school children have younger siblings at home, some teens in school have babies, and children who are the only English speakers in their families will translate the information and help fill out the census.

The Statistics in Schools materials include a flyer kids can take home to their parents to teach them about the census and why they should count their kids. We know that in 2010, one of three households with children in school saw and remembered these materials.

You can also start planning for Statistics in Schools Week in your school; that will be the first week in March.

The first mailings for the census go out March 12, in less than two months. Now is the time to teach children about the census, so they and their families know it matters to count their kids when the census arrives.

 

January 17, 2020

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Lead and Copper Rule Extended Until February 12

Recently, the Environmental Protection Agency announced that the agency would extend the Lead and Copper Rule comment period until February 12, 2020, in response to a request by a group an allied group of water utility companies. Consequently, this gives us approximately one more month to let the EPA know loud and clear that this rule doesn't go far enough to ensure the safety of our schools drinking water, and should be accompanied by increased federal funding for districts to pursue lead remediation.

As part of this effort, AASA encourages you to comment on the rule. If you're looking for directions on how to make your voice heard, check out our call-to-action here, which provides a template and step-by-step guide on how to publically comment.

January 16, 2020

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AASA and Allied Organizations Offer Letter in Support to US ED NPRM on the TEACH Grant program.

On January 10, 2020, AASA and 17 other allied organizations submitted a letter in support of the Department of Education's proposed regulatory changes to the Teacher Education Assistance for College and Higher Education (TEACH) Grant Program in an effort led by the Learning Policy institute.

 

For context, The TEACH Grant is a federal service scholarship program targeted at addressing teaching shortages in high-need fields and communities. The TEACH Grant Program provides scholarships of $4,000 per year (for up to 4 years) to undergraduate and graduate students who are preparing for a career in teaching, and who commit to teaching a high-need subject in a high-poverty elementary or secondary school for at least 4 years within 8 years of completing a degree. This grant is converted to a Federal Direct Unsubsidized Stafford Loan (with interest accrued from the date each grant was awarded) if a teacher is determined not to have fulfilled his or her commitment. However, most importantly for school districts, the TEACH grant is an effective method for attracting and keeping teachers in education.

 

Specifically, the Department's proposed changes fall under three categories, which are qualifying positions and schools, the grant-to-loan conversion process, and program information for grantees. Each of these has come under heavy criticism over the past year for their bureaucratic red tape (e.g., outdated lists, erroneous grant-to-loan conversions, and lack of access to programmatic information). To address these concerns, the proposed regulation would do the following:

  1. Require a teaching candidates' high-need field to be enumerated in the Nationwide List for the state in which the grant recipient teaches at the time the recipient signed the agreement to receive the TEACH Grant, even if that field subsequently loses its high-need designation for that state before the grant recipient begins teaching in that field; or (2) at the time the grant recipient begins teaching in that field, even if that field subsequently loses its high-need designation for that state;
  2. Simplify the regulations specifying the conditions under which TEACH Grants are converted to Direct Unsubsidized Loans so that, for all grant recipients, loan conversion will occur only if the recipient asks the Secretary to convert his or her TEACH Grants to loans, or if the recipient fails to begin or maintain qualifying teaching service within a timeframe that would allow the recipient to satisfy the service obligation within the 8-year service period; and
  3. Expand the information that is provided to TEACH Grant recipients during initial, subsequent, and exit counseling, and add a new conversion counseling requirement for grant recipients whose TEACH Grants are converted to Direct Unsubsidized Loans.
 

AASA was proud to support these proposed regulatory changes, as they represent an opportunity for the Department to significantly improve the effectiveness of the TEACH Grant Program and are an important piece of the work toward ensuring that every student has access to a well-prepared and diverse teacher workforce. At this point, we are waiting for the final rule from Ed. That said, we will keep you up abreast of any developments.

January 14, 2020

(RURAL EDUCATION) Permanent link

New Application Process for Small Rural School Achievement Program

Last week, the Department of Education's Office of Elementary and Secondary Education announced a new application process for school districts applying for the Small Rural School Achievement (SRSA) Program. The impetus for this change stems from a review of the SRSA application, which determined that the applicant burden could be significantly reduced while maintaining appropriate accountability guardrails for the grantmaking process. As a result of these actions, a much simpler application will be open to districts on February 3, 2020.

Listed below are some noticeable highlights from the new 2020 SRSA application:

·   The new quick and easy process relies on a single platform – OMB Max Survey – to gather school district information. The previous process required school districts to navigate three sites and took three hours to complete an application. The new application process is estimated to take no more than 30 minutes to complete.

·   Eligible school districts will access the application through a unique link that the Department will send via email invitation to school district contacts, which will be provided to the Department by state educational agencies. The Department will also provide the approximately 2,500 school districts that are eligible for both the SRSA and Rural Low-Income School (RLIS) program enhanced guidance on how to choose between SRSA and RLIS, including award estimates for both RLIS and SRSA in the email invitation. This will help ensure that school districts are more informed when they choose between SRSA and RLIS

·   In order to complete the SRSA application, the school district contact will need to confirm or provide the following:

1.       School district name and contact information;

2.       Authorized representative contact information;

3.       Secondary contact information;

4.       Dun and Bradstreet (DUNS) number;

5.       General Education Provisions Act (GEPA) statement information; and

6.       Assurances.

·   After an application has been submitted, each school district will receive a confirmation email that includes the PR/award number and a summary of the school district’s SRSA application responses to keep for its records. Additionally, the school district contact will be directed to the System for Award Management (SAM) at SAM.gov to update its DUNS status.

·   The Department will conduct webinars for school district staff on February 4, March 19, and April 2, 2020 to determine the new quick and easy process for submitting the SRSA application (webinar invitations are forthcoming). The application process will also be demonstrated at the National ESEA Conference on February 6, 2020 in Atlanta, Georgia (for additional details click here)

 

January 13, 2020

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AASA Leads Group Letter to Congress on Vaping Legislation

Today AASA along with our partners at the National Association of Secondary School Principals led a letter to the House of Representatives urging support for HR 2339, The Reversing the Youth Tobacco Epidemic Act. 

We felt it was important to unite the education community formally around this major legislative proposal that would assist schools in addressing the vaping epidemic that is impacting one out of four high school students we educate. 

Specifically, this legislation would prohibit the use of all flavored tobacco product and extend advertising restrictions that currently apply to cigarettes to other tobacco products including e-cigarettes. 

You can read the letter here

January 5, 2019

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January Advocate: Federal Education Funding Set for 20-21 School Year

 Before the holiday break, the President signed H.R. 1865, the Consolidated Appropriations Act of FY20 into law. The bill and its provisions fund the federal government for F720 which runs from Oct 1, 2019 thru September 30, 2020. FY20 dollars will be in schools during the 2020-2021 school year. Congress has relied on a series of short-term continuing resolutions to keep government funded and running since September 30, 2019. The final continuing resolution was set to expire at midnight on December 21st meaning the timing of the bill forced an expedited floor vote schedule in both the House and the Senate. The President agreed to sign the funding bill as it provides some funding, $1.4 billion, for the border wall. He is expected to try and shift cash from other funding streams to bolster funding for the wall.

H.R. 1865 provides $1.4 trillion for FY20. The more than 2,000-page bill will appropriate $738 billion in FY20 funding for the defense discretionary spending and $632 billion for non-defense discretionary spending. Specific to education, the bill provides $40.1 billion for K-12 education programs which is an increase of $1.2 billion above the 2019 enacted level and $5.9 billion above the President’s budget request. This is the third largest increase for ED since FY11 (the year that ED funding started being cut or frozen). The bill rejects the draconian cuts to critical programs proposed by the Trump Administration as well as their continued efforts to further advance their flawed privatization agenda.  

Program Specific Details:

  • K12 Programs
    • ESSA Title I: $450m increase to $16.3b
    • ESSA Title II: $76m increase to 2.1b (first increase in 6 years)
    • ESSA Title III: $50m increase to $787 (first increase in 5 years)
    • ESSA Title IV: $40 m increase to $1.2b
    • IDEA State Grants (Part B): $417m increase to $13.9b (3% increase)
    • Impact Aid: $40m increase, to $1.4b
    • 21st Century Community Learning Centers: $28 m increase, to $1.2b
    • REAP: $5m increase to $186m
    • Career and Technical Education State Grants: $20m increase to $1.28b
    • Homeless Youth/Children: $8m increase to $105m
    • School Safety National Activities: $10m increase to $105m
  • Early Education
    • Head Start: $550m increase to $10.6b
    • Child Care and Development Block Grant (CCDBG): $550m increase to $5.8b
  • Funding and Policy Beyond The Labor-Health-Education Bill
    • STOP School Violence Act Grants: $25m increase to $125m
    • Secure Rural Schools/Forest Counties: The bill reauthorizes and provides two years of funding for the SRS program for FY19 and FY20
    • DC Voucher: Reauthorizes the program for 4 additional years
    • Raises the age for purchasing tobacco products including e-cigarettes to 21 from 18.
    • Provides $12.5m in funding for researching gun violence prevention
    • Adequately funds the Census to ensure it can be properly administered
    • Contains policy language instructing CMS and ED to work together to reduce administrative barriers for providing health services in and in coordination with schools and provide technical assistance to assist with billing and payment administration for Medicaid services in schools.
    • Repeals the Cadillac Tax from the Affordable Care Act

AASA is pleased to see that Congress prioritized increased funding for our key formula programs like IDEA and Title I. However, this funding is still short of what districts were receiving in FY11 when adjusting for inflation. Furthermore, while it’s true that IDEA received a 3.2% boost in this bill, which represents a slightly higher percentage increase than what the other key K12 programs received, this increase is only a little better than inflation, which is projected to be 2% in 2020. Effectively, this means that IDEA is only receiving a real increase of 1.2% while the number of children with disabilities districts are educating continues to increase. As we look ahead to FY21 AASA will continue to push Congressional leadership and appropriators to make greater investments in IDEA until it is fully funded.