 Okay, we are going back to the student waiting equity bill. And Secretary French. Welcome. And we thought we'd give you a chance to comment. We've been taking testimony on the, I got to check my notes. I'm going to take a look at this property. Education finance advisory committee and. Yeah, education fund advisory committee. Which kind of take some things that you do now and just. This is your chance to. Tell us what you think about the whole thing. Well, I appreciate that. Good afternoon. Dan French, Secretary of Education also had Brad James from the agency listening in. It's good to see you all. Yeah, thank you. I provided a written summary of my testimony. And I'm reacting to the drafting request that I saw. What I, and there's so many different elements. And I think that's the first, first observation I'd make it's, it's nice to see all this coming together into a single bill. Because there's so many different interrelated policy pieces relative to education specifically. You know, we have the waiting study, which was commissioned. Largely as a result of act 173. And the question. If we were to move from a reimbursement model and special ed funding to a block grant. To what extent should there be some consideration in the calculation of that block grant. And I think that's a good point. I think that's a good point for districts that have higher numbers of students with disabilities than others. And part of the answer in the waiting study was. Well, actually maybe not if the pupil waits were working properly. And if, and by mean by properly, if particularly the poverty weight was functioning. In a basis that was. Attributed to cost in an irrational way, I think that's a good point. Again, I think these pieces are coming together now at this point in the legislative session, which is really good to see. And there's also a piece here relative to our, the policy interests and universal meals. So the issue of the poverty weight. And how that's determined now versus how we'd like to see it calculated in the future. All these things are coming together and they do. You know, do require some. Thinking on our part to react to. So. I think that's a good point. I think that's a good point. I think that's a good point. I think that's a good point. I think that's a good. Normal. Exemplary narrative that I often produce, but it's, it's kind of point by point. And I'll speak to it. In an outline basis and it would be open to questions. Certainly if you have any. Outlines are really good. Okay. Chair likes bullets. I really wanted to say I've been busy with other stuff, but I'll take it. But now I think it's great to see these pieces coming together. Because they're these things are interrelated. And I think we see that clearly at the agency, the interrelationship between 173 waiting study and issues of universal meals. They have common denominators. So firstly, I'll start right off on page six. This idea of universal income, income declaration form and moving for towards a different way. To leverage a poverty indicator. I think this is long overdue. I think people have been struggling on this, the national level for a while. We know. The idea of free and reduced lunch has been a proxy for poverty, but not necessarily a tightly accurate one. So this is a, this is a really important undertaking. I just want to call out, I appreciate in the preamble to the, the drafting requests through the bill. There's some acknowledgement agency would need additional staff. This is an area and I'll speak to it at the end of my outline. Where we will need additional staff because basically what goes on now in terms of the determining of free and reduced lunch eligibility takes place in each school district around the state. We audit that at the state level, but we're not directly involved in that certification. This, this process is an entirely new one. We'll require us to not only stand up a form to do that, but there's different ways we could do this depending on how much assurance you'd want us to provide. But this was an area where you did not specify position support. It's one I would argue we do need position support depending on how we set it up. But I just, I'll speak to that again towards the end, but was that going to the universal declaration? Yes. Okay. And that. Can you kind of fill us in a little bit on what that would look like? Is this something that every family would fill out? Is this something. Yes. I think so. I mean, again, there's a couple of different ways we could do this. And the devil's in the details relative to the demand on the agency. But, you know, to speak of how we do this now, again, we have this, what we'll call a proxy for poverty and the eligibility of free and reduced lunch. So at the beginning of every school year, we ask parents to sign up for this to determine if they're eligible. And there's a couple of ways one can become eligible. If you're already eligible for other state programs, you're automatically what's called direct certified for eligibility. And then there's some, there is some income screening eligibility. There's a way you can, you can, when I used to do this as a principal, there's, there, the USDA gives us like criteria to use. We'd ask parents to provide an estimate of their pay. And if it fell, you'd look it up on a table and you determine whether they were eligible for free or reduced lunch. Then we've had policies like community eligibility where entire school populations have become eligible for free and reduced lunch. So it, the point is over time, this has become less and less an accurate description of actual levels of poverty. And it's sort of baked into so many different indicators. It's hard to pull it apart. I mean, like we use free and reduced lunch levels for e-rate reimbursement levels and stuff like that. So it's, it's a hard one to unpack. At any rate, this would move to a basically an income basis. And my understanding is families would declare this form on an annual basis. And this would largely be processed at the state level, as opposed to the local level. And that's the big shift. So there's a couple of different ways we could do that. I think we've, you know, we've worked on that with the task force over the summer. There's a lot of support again, coming from the universal meals approach. But there's acknowledgement that this is, there are some data issues here that need to unpack. And I think it's a good idea, but the agency would have to, it would be a fundamental new shift in how we do this and would require us to stand up some new processes. There's some, there's some ways we could do that that would be lighter on the need for new positions than others, but, you know, it's still going to be a new process. Next point I'd make on page seven. And this, these two, next two items are kind of together, which is the actual weights that are being articulated in the draft bill. And also the trans, you know, then the transition aspects. I think it's great to see this coming together. You know, Brad James has been deployed with the task force to provide that technical assistance relative to modeling and to working with JFO to do that and so forth. Now that we're getting closer to understanding what the weights would be, I think it's, it's a good moment to pause for a second and specifically take a look at the intersection between the weights and the proposed special ed block grant. So we need to understand on a district by district basis, how would be people be affected? Because that leads us into the transition, you know, like what's going to be required to sort of soften that, that integration, but the two are directly related. So I think it's important that we look at not only the weights, but also the implementation of the special ed block grant, which coincidentally is also coming online from a policy perspective. So we do have an opportunity to do that analysis. And I think it's one, at this point, I'm not prepared to say, oh, these weights are good or bad. I think we need to admire the whole package, if you will, and on a district by district basis and ensure that's going to work, but also ensure that transition would work. And that gets me to my next point on the transition aspects, which are on page 21 specifically, there's a proposal to suspend both the excess penalty threshold for several years, as well as the whole harmless provision on equalized pupils. I don't know yet if that's needed to what extent both are needed or just one. But again, I think if we did the modeling on the, on the implications of the weights on a district by district basis in conjunction with a special ed block grant that we'd then be able to consider any kind of suspension of the cost containment mechanisms to allow that transition to happen in a thoughtful way. Okay. I guess we've got to have this bill out if it's going anywhere two weeks. So I'm trying to find a way that we can move it forward. Cause this committee has not touched. Special ed block grants. Yeah, I just, I would say by design, they're directly, they're directly related. I mean, that was the impetus behind the way. Yeah. So it's. And we have, it was during my transition time from back here. Yeah. And I think, you know, honestly, I think most districts have accepted that the, it's likely the block grant will go forward. But part of that is we were committed to ensuring that, that people are not experiencing an abrupt adjustment and understanding how they would also then be affected by the weighting change is going to be an important consideration. You know, so if a district was suddenly going to see an abrupt decline in special ed funding through the block grant, but then could be reassured, they're going to pick up more equalized pupils through the revision to the waiting system. That would go a long way to smoothing their transition. Yes, it would. Yeah. So yeah, and, you know, Brad and I had a chance to connect Brad. You know, Brad's been deployed on this topic on almost a daily, if not hourly basis for several weeks. You know, in terms of the rapidity by which we could do that modeling, I deferred him on that, but we're, we've been actively involved. So we can start to pull these things together fairly quickly. I think. I'd make, I've made some comments about the evaluation of reporting mechanisms, which I, it just struck me as very significant. Honestly, I was, I was, yeah, I believe the auditor is largely charged for doing this, but that's also going to have significant impact on school districts. No doubt who are going to be requested to provide data. So I just, I, it wasn't hard for me to write several sentences there about this. I'm concerned that it is a significant undertaking. It would be significant even if we were not coming out of the pandemic, or even if we weren't also contemplating significant changes to the funding system. But I think as you're aware, there's a lot of instability in school districts right now. And particularly in the financial aspects, we don't, we don't have a really sought understanding of how, what the patterns are. Cause districts are able to leverage their federal dollars to a certain extent. We know their staffing shortages. We know there's upward pressure on some of the staffing arrangements as appropriately there should be. So there's a lot of, a lot of variables at play right now. So it's going to be really hard to do this. But I think importantly, we're also coincidentally or unfortunately seeing a huge demand now for additional reporting requirements, you know, because there's been a lot of federal dollars pushed out. I was on a national call last night with some of my colleagues from around the country. And this was the topic that came up almost immediately that. A lot of concern about the reporting requirements, but then more specifically the ability of school districts to actually do the reporting because there's staffing shortages. And we're also pointing districts to really, really try to get into the recovery work and education. So there's a lot of new work that has to happen. And it's not clear to me how we're going to be able to accomplish, you know, sort of thread the needle both on the reporting requirements and in actually doing the work. And we, we saw that as a, you know, we were trying to stand up some data reporting on vaccination rates in schools, which is, it's actually fairly simple reporting. But we, we couldn't get people the time to do the reporting because they were particularly school nurses were so involved in doing contact tracing and everything else. We just, we couldn't get, we only had a 50% response to that. So we had to come up with another way to come up with the information. So I'm afraid that type of reaction is going to be happening. If people don't have the capacity. I think the auditor is on the same page with you. He said his experience that some data, which you think should be readily available. It is very difficult to get. And you have to get it. And that was before the schools. And I think we all understand that schools are. Under real stress. Personally, I'd like them to be focusing on helping. The kids get caught up on the. Two years they've missed. In regular school attendance. Yeah, we have data quality issues in our education system due to its decentralization. And we just accept that. But it's in the auditors. Very familiar with that. As we've worked with them closely on other projects. This. This one's going to be really challenging. I think in this one. I mean, it's very comprehensive too. I mean, it really asks like everything. Yeah. And we may need to find a middle ground, but I think. You know, he said to be happy to do the audit, but he needs some criteria and a baseline. Yeah. And to measure against. And that really falls into your. Valid lick. How do we measure it? I know there's some concerns about. Standardized tests just with any student right now, given the. Yeah. Disruption. And, but how do we know all these changes have made. Any difference in the lives of students. And that's, that's a challenge. Yeah. No, it is. It's going to be a challenge to create a good evaluation model in this context. I think the solution is probably a simplification and looking for some, I'll say, dipstick indicators. Like if we could think about a few indicators as opposed to 20. And they'll be imperfect, but we'll be able to do that. I think that's always been a key takeaway for me in my career, that, you know, what happens in a kingdom isn't necessarily the same thing that's happening in Chittenden County. We need to understand that. Right. Okay. So. Senator Brock, Senator Brock has a question. Sure. Just a comment in terms of looking at how you measure things. One of the key things it seems to me. Is to divide. You're part of your measurement system. Try to identify. What change. Or what factor. Is. Is in my career that, you know, what happens in a kingdom isn't necessarily the same thing that's happening in Chittenden County. We need to understand that. Right. Okay. So. Senator Brock has a question. Sure. Just a comment in terms of looking at how you measure things. You know, you know, what happens in a kingdom isn't necessarily the same thing that's happening in a kingdom. But what happens in a kingdom is that the factor. Is. Is impacting a particular result. Otherwise, you know, you blend things together and you have something that's absolutely adverse to what you're trying to do. Whereas something else is positive to it. To cancel each other out and unless. And that's why there's a real trick. And challenge. I would assume the education establishment has. Is working with the audit to, to identify what things to measure. And how does that actually make the difference? Yeah, I mean, there is, as you're speaking to a sort of causality, right? And it's oftentimes like, if you look at the waiting study itself, it's a mixture of qualitative research and quantitative research. So we often in education have to go to the quantitative interviews to confirm. Some of the variability we see in the qualitative analysis. And, you know, we did a project with the auditor on purely financial. So I mean, if there's a qualitative area that's fairly stable, you think the financial data would be pretty stable. And as you know, we've had difficulty implementing uniform chart of accounts, but the project we worked on directly recently had pertain to. Costs related to independent schools, you know, so we have that financial data and it does vary in quality. But then there's so many different types of independent schools. So immediately, you know, you start to introduce all this variability, you know, St. Jay Academy is not the same of a small therapeutic school with 12 kids, you know, so you have all these different types of schools. And then, you know, when we start thinking about outcomes, which is really where a lot of folks like to go in terms of logic models or measurement, you know, like did the input actually cause the output? You know, I've heard Dr. Mathis, you know, who's a well regarded national researcher say something like, you know, 50% of that input is attributed to things outside of the school. So then you run into the issues like, well, what's going on in home life, what's happening in communities, you know, and it's hard to nail down the value added, if you will, of what happens inside the schoolhouse. But anyway, I digress. Fascinating topic. Okay. My next comments pertain to the education fund advisory committee, which is something I support. This is the first time we really start to see a description of what the duties are. My first bullet, I made an error. So I wanted to point that out. I was taking issue with the January 15th date. I thought that would be too late, but then as I read further into it, unfortunately I didn't have time to go back and correct myself that that was pertaining to a report to the general assembly that the committee was charged to do. That's fine. I thought the January 15th date was what's my second bullet, which gets into the December 1st letter of tax commissioner would typically do. So I think we've decided that we need to do a little word. Okay. You know, I think there's also a page break there. So maybe that's it. Maybe that's what does it. Yeah. I just wanted to point out, I don't support the idea of trans, you know, we get into specific responsibilities, advisory committee. I think it would still be prudent to have the executive branch and the tax commissioner be charged with making that proposal. So I think that's the first layer letter over the years being on the receiving end of that as a superintendent. There's a formulaic requirement in the law about what goes into that letter. Certainly every governor and tax commissioners used that to make political statements over the years, but I think it's useful to keep it as a formulaic proposal. It's certainly, you know, the deliberative aspects of that, the general assembly always works on. So I didn't see a lot of value add coming into making that a deliberative process at the very end. I think that's the first layer. I think that's the first layer. I think that's the first layer. My preference would be to keep it clinical and technical. And put it as a responsibility. The executive branch, maybe parallel to how the budget process unfolds. If governor proposes a budget. And then the legislature says, thank you very much and works on that. So I think there's value to keeping how it is. I'm not sure this would improve the context of the quality of that letter. So I make that comment. And I think that's the first layer. And I think that's the first layer. I think that's the first layer. And I think that's the first layer. And I think that's the first layer. And I think that's the first layer. And this again, I think from my perspective gets to the intersection of a number of these policies, which are, you know, we're looking at the whole body of work that's emerging relative to the pandemic and so forth. And they're, I definitely think six positions are needed here. I don't necessarily agree with how they've been aligned in the preamble, the bill. For example, I don't think. That's not how we had run that program at the state level. We basically the positions at the state level currently we have one is responsible for ensuring compliance with the federal program. We buy into a larger national consortium of districts to provide the technical support and so forth. So that's been, I would say the pattern of most rural states in this area. I don't know if the, the additional positions were thought of as a, they wanted more boots on the ground from the agency to provide direct service, but that's not how we see the program being administered. So I think, you know, we could talk about the specifics here. I think the ed quality standard one is also name and that's not really needed. I think we have strong consensus in the agency. We have a robust series of teams that do the continuous improvement work. But as I pointed out earlier, an area that is missing is the, the work related to the poverty indicator. And certainly working with the weights. You know, Brad James, who you all know and have affection for is really our sole person who manages those, the weights that was, we know them now. And that's a point of vulnerability for the agency. And it's one of the reasons I support the idea of creating the advisory committee. Cause I think there should be more eyes on the ed fund, but internal to the agency, it's important to acknowledge that this revision to weights creates more complexity. We have new weights here, such as the sparsity indicator. There's new reporting requirements with that. And there's going to therefore be additional technical support to school districts to implement it. Not to say Brad hasn't done a phenomenally good job over the years, but you know, we need, we need to have more boots on the ground monitoring this and doing it right with districts. So I suspect all in all six positions are appropriate. I would just, I can come back at some future date. If you'd like and provide more specificity on how I, I think this initiative should be staffed, but I expect it won't be as heavy an ELL. It won't be needed in the edge quality, but will be needed and implementing the poverty indication, the weight and also the related verification process necessary for the universal meals that that gets enacted. But then importantly, we just need bodies on the weight process itself and the financial management oversight of the function with school districts. And that's pretty much all in it. This might be another place where we're going to have to put a piece holder for the other body to work on it. Yeah. And we have some, you know, depending on how these pieces come together, because we've been thinking about certainly the special education in our budget proposal, we have additional federal funded positions and special education oversight as a result of 173 going live. We need to administratively assess all these pieces being enacted at the same time, so that make sure they can be implemented. Yeah. It's, it also, I think is a, it's a moment in time as we're contemplating coming out of the end of the pandemic. Is it a time where the agency is going to have a more direct role with operations or schools or let, are we snapping back to more of the local control? I think what we've learned is that the agency will be having a more direct role in school operations going forward. Okay. Okay. Questions committee. We do have your testimony and writing at least outline, which is good. And we'll be working through this. I think we'll try and get. At least, you know, not the fine details, but just given our timeframe. An outline that the other body can, can take. Just assuming they'll accept all the fine work we've done. I'm sure they will. Yeah. You know, and whatever we can do to help this is, this is arguably one of the most important policy issues in education right now. So we're, we have it on our radar as well. Do you want to chime in at all? And I see him smiling. Correct. No, no, I don't have anything really to add. I thought you covered things quite well. I mean, I would prefer you to do the policy pieces. I have some technical questions, but I'll talk to you about those first and we'll come back with those. I don't know. At just, nothing that you guys need to be concerned with at the moment. Maybe never. Don't worry about it. We got it under control. I like that thought. All right. So am I hearing kind of a consensus. I think I've heard it from you in the tax department that. We really should leave. The. December 1st letter as it is, it's working. It's a technical thing. And then we do need extra staffing in ed to carry this all out. And we could use. More an advisory committee, but I think that's a good idea. I think it's a good idea to work on things to bring recommendations to the legislature. Yeah. And I think, you know, in that one, you know, it's again, I look at it as, I don't think the. And I never, when talking with representative cornheiser on this, I never envisioned that the council would be taking over the December 1 letter. I don't. I don't see what value a deliberative group would bring to that. That's really a mechanical sort of analysis. But I think the point with attracted me with a council is this is the. The public has to make sure that it's not a insurmountable, or a financial aid fund in particular, you know, these weights haven't been evaluated since they basically were plucked from the sky and implemented in 97. So, you know, to really, to make sure the system is working. And I think this is where the interests of having the order involved as well. To monitor the weights to make sure they're, So just the surprise kind of moments popping up and or a lawsuit and so forth. Yeah. We were not familiar with those things. Let's see. So we really need. Just an advisory committee to look at the Ed fund to look at the forecast, look at perhaps more the way the money is going out. We look at how it's coming in, but not how it's going out. We need to be able to evaluate and that's where it's going to be really challenging is how do we set up in the timeframe we've got now or how do we set up a way in the near future to get curriculum or get criteria that and I've had discussions with some of my schools and given the mental health issues and the, you know, that we're anticipating being able to keep a child sitting in his seat for more than 10 minutes or not throwing things that the teacher might be progress. But it's not going to show up on a test and we might want to, you know, put the evaluation out. Yeah, we have, this is a key part of what my testimony has been throughout this, you know, it's to really focus on the quality piece because the inputs can be adjusted, but we need, you know, part of the challenge here or point of vulnerability is we haven't had a robust quality assurance process. And, you know, that all comes back to regulation. So our first step in doing this, we actually, we met today, the State Board of Education, we've were charged by the legislature to do some analysis of our relative roles and responsibilities. The State Board signed off on that today so that report will be coming to the policy committees in the General Assembly. We have some foundational work to do first to decide who's going to be in charge of the rules because that's part of the problem now is that the agency of education, which is held responsible with the quality assurance piece doesn't have the responsibility for the rules. The State Board does. So we've been working on how to make that more explicit. Once we figure that piece out, and this can happen very quickly, don't get me wrong, we have to open the rules on education quality to ensure that the quality standards are described in regulation appropriately, but more importantly or equally important is the quality assurance process needs to be described as well. So we have some work to do in that area that's, we've been heating up in conjunction with this other work. So don't get me wrong. It's, we're ready to bring that online. But the first piece of that is the roles and responsibilities of the State Board. Okay. So maybe in the end. We'll just kick this can down the road and charge you with coming back with a proposal. I think that's been tried. I mean, that was last year. Like, why doesn't the agency come back with weights? You know, but you know, it's not weights, but when we put the weights in, right? What's a fair way, given that some of these schools have been underfunded for years. Yeah. I'm still concerned about my inner city school that looks like they're not, but I haven't figured special ed in there. Yeah. And that my. Yeah. We got sped. We've got school facilities issues. All these things are sort of from my perspective, like tertiary issues. We need to get the foundation right on defining quality. You know, you're working on a piece here that's foundational as well, which is the funding piece, but we have some things to do in regulatory space that, you know, we're bringing online for you to consider at the same time. So this, you know, maybe we should just lay out a big project of how it all looks like, you know, but these, these are elemental issues that are going to help us get through the pandemic as well. So if we don't have these things organized well, we're, you know, basically it's pointing to making stronger school districts from an organizational perspective. If we have weak school districts from an organizational perspective, they're not going to begin to be able to address some of these complex needs. Yeah. That's the challenge before us. No, they're all dealing with the pandemic too at home. And yeah, the boards are right in the middle of it. Not to mention all the present political climate. Which is very challenging. Very challenging. Okay. So stay in touch. It might, since this is not the education committee, but they have kindly given this to us. And I think any report you're doing will come back to them. But some kind of a, I'm thinking it's not actually a flow chart, but just the list of what's in play here. I mean, we're focused on weights and you're the first time it's dawned in me. Oh yeah. There's another big source of funding that's in play. And changing. And, and then you need evaluation pieces for all of that. And then we have the tools, you know, which are like the accounting standards, the SS CDMS project, you know, the tools by which we would manage and make sense of these things and improve the data quality, you know, all these things are being. Managed right now. And so it's, it's not an. Simple environment. No, it is not. But we have plans to. Okay. Good. All right. So committee, any questions? Or is everybody kind of as overwhelmed as I'm feeling at this point. And I thought I couldn't get any worse than Brad's. Spread sheets. We see that off and not only when Brad spreadsheets are introduced, but anytime education topics. I'm still trying to explain to the Barry school board what's going on, but right. Okay. Thank you. This has been helpful. We're here to help. Good. All right. Committee. That's it for the agenda.