Congress urged to make further refinements to Title I

Congress urged to make further refinements to Title I

(District of Columbia) Despite the overhaul Congress imposed on the Elementary and Secondary Education Act in December, a noted educational economist has suggested simplifying Title I funding grants by eliminating some and removing complex eligibility mandates on others.

In a research paper released earlier this month by the Brookings Institute, Nora Gordon argues that Congress could take several steps to better ensure that federal resources are getting to the neediest students and that local school administrators have a better sense of what the rules are.

“These are first-order issues for improving high-poverty schools,” she said in her paper. “But they are so deeply mired in technical and bureaucratic detail that they have received little public attention.”

Gordon, who is an associate professor of public policy at Georgetown University as well as on the staff at the National Bureau of Economic Research, said that, rightfully, most of the attention by the public and by Congress during the ESEA reauthorization debate was focused on the well-known controversies surrounding testing, curriculum standards and teacher evaluations.

Although Title I stands at the center of the federal education law, it was largely overlooked as ESEA was being recrafted into the Every Student Succeeds Act – even though key elements have been amended.

As an example, she points to the changes ESSA makes to the long-standing rule that requires federal funds be used to supplement – not supplant – state and local money.

The rule dates back to the early 1970s and reports of widespread misuse of federal money. Under the rule, federal regulators used three presumptions of supplanting:

  • When Title I money was used to buy things when the same items were bought for other schools using other funds;
  • When Title I money was used to pay for items that in the past had been paid for with other funds;
  • Or when Title I money was used for anything that was specifically mandated by state or local law.

Gordon points out that the supplanting rule would make more sense if school districts had one big pot of discretionary money, spread that money across schools based on student needs, and then used separate Title I funds for high-quality interventions that integrated well with any existing programming. 

In reality, she said, “districts are dealing with multiple distinct pots of money, from both federal and state categorical programs.” She noted that reporting and compliance “regimes require them to document how each of these pots is spent on its respective target population or program.”

ESSA did away with the three supplanting tests, replacing them with “cost-by-cost” tests of specific Title I-funded spending with a revenue- based supplemental funds test. “This test requires  districts to document  how state and local resources are consistently distributed to schools in a locally defined way that is neutral with regard to Title I funds,” she said.  

As a result, she argues, the “transparent allocation process” in ESSA “holds districts more directly accountable to parents and other observers –districts will gain access to uses of funds previously ruled out by the three presumptions of supplanting.”

When it comes to the actual distribution of the Title I monies, Gordon has several suggestions – one is to retain the basic grants, but change the eligibility to only those schools with at least 5 percent of enrollment within the poverty limits.

She said Congress should do away with Concentration Grants:

“The existing Concentration Grants formula is exactly the same as the formula for Basic Grants, with just one difference: the eligibility requirements,” she said. “Concentration Grants are awarded to all districts with at least 6,500 eligible children or at least 15 percent children eligible; two-thirds of all districts are eligible for these grants. I propose eliminating this formula from the law and directing the 9 percent of Title I, Part A funds to LEAs allocated via Concentration Grants in 2015 to the modified Targeted Grants formula below.”

She said the freed up money should be funneled into the Targeted Grants but the federal government should use poverty rates, rather than student counts, to allocate those funds.

“In practice, with a fixed appropriation  to distribute, this directs funds toward districts with a large number, but not share, of poor kids and away from smaller, high poverty–share districts,” she said.

Gordon also wants to remove state-level spending per pupil from all remaining formulas.

She notes that ESSA specifies that eligible children are to be multiplied by “40 percent of the average per-pupil expenditure in the State, except that the amount determined under this subparagraph shall not be less than 32 percent, or more than 48 percent, of the average per-pupil expenditure in the United States.”

The problem here, she said, is that states with greater spending per pupil – and therefore higher Title I allocations – have less poverty. Thus, she wants to use a weighted system for awarding money using 6 percent of the national  average per-pupil current expenditure in the United States.