Ed Trust in Tennessee Submits Public Comments on Student-Based Formula Draft Framework

Dr. Penny Schwinn, Commissioner
Tennessee Department of Education
710 James Robertson Parkway
Nashville, TN 37243

RE: Tennessee’s Funding for Student Success: Student-Based Formula Draft Framework Public Comment

Dear Commissioner Schwinn and Department staff,

Thank you for the opportunity to submit a written public comment regarding Tennessee’s Funding for Student Success: Student-Based Formula Draft Framework. We submit the following comments, framework analysis, and school funding evaluation tool on behalf of The Education Trust in Tennessee (Ed Trust), a non-profit, non-partisan research and advocacy organization. We are committed to improving educational outcomes for all students in our state from pre-K through postsecondary learning, with an explicit focus on closing the achievement and opportunity gaps that persist for students of color, from low-income backgrounds, with disabilities, in rural schools, and English learners.

For more information, please see our resources linked below:

Dollars & Sense Website with: 

• Basic Education Program Review Guide 
• Funding fact sheets by student group:
  • Funding for Students with Disabilities
  • Funding for English Learners
  • Funding for Rural Schools
  • Funding for Students from Low-Income Backgrounds
• School Finance Glossary 
• Dollars & Sense Learning Series  (with recordings, readings, & slides for all sessions)

Sincerely,

The Education Trust in Tennessee

The Education Trust in Tennessee: Tennessee’s Funding for Student Success: Student-Based Formula Draft Framework Analysis

OVERVIEW

The Education Trust in Tennessee is encouraged to see the draft framework include the following components: 

• Framing that federal relief funding provides a distinct opportunity and resources to transition to a new funding formula and supplement local need  
• Student-weighted funding formula with weights for students from low-income backgrounds, including for concentrated poverty; in rural school districts; with disabilities; and English learners 
• Commitment to transparency, accountability, and reporting 
• Interest in universal 4-year-old pre-k 

Also, it is crucial to consider the following components that need further details or clarification:  

• Weight sizes and initial calculations
  • Specific data sources and weighting differentiation for English learners and students with different disabilities and needs
• Base funding allocation and initial calculations 
  • How the State will calculate future inflationary increases or increases in proportion to state budget growth
• Additional and total funding amount the state will commit to the revised funding formula 
• Outcomes-based funding’s goal, rationale, allocation amount, initial calculations, and proportion 
• Outcomes-based funding literacy component 
• Inclusion of the local fiscal capacity and contribution
• Specific strategies the State will use to ensure transparency and accountability in reporting 

ANALYSIS

Base: 

• Ed Trust is excited to see counselors, nurses, and educator salaries included in the base list based on funding town hall feedback.
• Does the draft list include all components in the proposed base, or are they examples?
• How will these components be calculated to determine the base funding allocation?
• Will each student in Tennessee receive the same base amount? How will the State measure district-specific needs? Ed Trust recommends allocating the same base to all students and differentiating through various weights. 

Weights: 

• Poverty and Concentrated Poverty 
  • Ed Trust supports the proposed weight for students from low-income backgrounds and agrees to identify students using direct certification, but recommends expanding direct certification to include TennCare to more fully capture students from low-income backgrounds.
  • In addition to a weight for students from low-income backgrounds, Ed Trust recommends a sliding-scale weight based on a district’s concentration of students from low-income backgrounds to increase consistency and transparency between the two measures and leverage a more direct proxy for poverty instead of Title I Status to measure concentrated poverty.
  • See our Funding for Students from Low-Income Backgrounds Advocacy Guide for more details.
• Rural 
  • Ed Trust is encouraged to see a weight for students in rural schools to support communities that face higher transportation and other costs. Ed Trust recommends a sliding-scale weight, as defined by the number of students per square mile, instead of the enrollment size threshold proposed to more precisely target funds to districts facing unavoidable diseconomies of scale, staff attraction, and retention challenges.
  • See our Funding for Students in Rural Schools Advocacy Guide for more details. 
• Unique Learning Needs 
  • Ed Trust recommends separating the Unique Learning Needs category into distinct weights for English learners and students with disabilities to ensure student groups have their specific needs met. 
  • Ed Trust is encouraged that the framework mentions students in the Unique Learning Needs category will qualify for each service. Does this also extend across the Poverty and Concentrated Poverty and Rural categories? (e.g., a student with a disability in a high-poverty rural school would receive the rural, students with disabilities, and concentrated poverty weights)
  • Tiered weights are essential in meeting differentiated student need. How many different tiers will the State use? Ed Trust recommends five different tiers for students with disabilities and three tiers for English learners to meet different students’ needs. 
  • What specific assessment data will Tennessee use to assess the levels of weights applied to English learners and students with disabilities in a new formula? 
    • For students with disabilities, Ed Trust recommends assigning students to different levels based on their specific abilities and skills listed in their IEP, 504, or other official documentation. For more details, see our Funding for Students with Disabilities advocacy guide. 
    • Ed Trust recommends using existing English language proficiency levels or other characteristics for English learners. For more details, see our Funding for English Learners advocacy guide. 

Direct Funding:

• We are encouraged to see that the draft framework includes a student-weighted funding formula. However, it is critical to ensure that the vast majority of funding goes through the formula to promote transparency and its long-term success. 
• How will the State determine which initiatives will be funded through direct versus formula funding? For example, how will the State ensure that any direct funding initiatives do not create barriers to stakeholder engagement and evaluation or reward districts with more significant proportions of students from wealthier districts and communities?

Outcomes:

• Ed Trust does not recommend a performance-based funding component due to the lack of peer-reviewed research that this is an effective strategy to improve student experiences or outcomes in K-12 settings. 
• If proposed legislation includes outcomes-based funding, Ed Trust recommends the following considerations: 
  • How much funding will be allocated towards outcomes-based funding relative to the base and weights portion of the funding formula? 
  • Will the bonus for the performance-based measure growth to account for students and schools with less access to resources and programming? Ed Trust recommends using growth to ensure that students who would most benefit from this funding can access it. 
  • How much will the additional weight be for students from low-income backgrounds relative to their peers?
  • In addition to students from low-income backgrounds, will the State also include students in rural schools, with disabilities, and English learners to include all student groups with additional needs?
  • Ed Trust does not recommend using FAFSA Completion within performance-based funding because there is not a demonstrated positive connection between it and strong positive postsecondary outcomes. 

Additional Considerations Supported by Subcommittees:

• PK-3rd Grade Band
  • Ed Trust does not support grade-level weights because it is rare for districts to have significant differences in enrollment size from grade to grade, which makes funding differences often not consequential. Additionally, each stage of school presents unique strengths and challenges. 
  • Ed Trust recommends a high base allocation and comprehensive weights for students with additional needs to ensure they receive critical resources at each stage of their education. 
• Universal PK4
  • Ed Trust is highly supportive of efforts to implement universal pre-k. However, increasing access could be addressed by making pre-K a funded grade in the new formula rather than through a separate funding stream to increase formula transparency. 

Transparency, Accountability, and Reporting in the New Framework

• Ed Trust is encouraged by the State’s commitment to transparency, accountability, and reporting in the new framework. However, more details are needed to ensure these efforts are successful. Therefore, Ed Trust recommends: 
  • Aligning the student categories specifically targeted for supplemental funding in the formula with student categories in the outcomes-based funding and 

accountability system to assess the success of its targeted investments and adjust the policy accordingly.

• Reporting longitudinal and comparative school and district-level funding and district, state, and federal-level per-pupil expenditure data in multiple, transparent, and interactive formats, including on the State Report Card (e.g., spreadsheets, visualizations, dashboards, and written explanations).

Additionally, the Education Trust will base its evaluation of any upcoming funding formula legislation using the following tool: 

Criteria:

• Meets criteria 
• Mostly meets criteria 
• Partially meets criteria 
• Does not meet criteria 
• Outstanding questions

Dimensions:

Formula:  

1. Adopt a simplified, student-weighted funding formula that is guided by students’ different levels of need with weights robust enough to support student needs​
2. Increase the level of funding allocated through the state formula to support a rigorous, high-quality education program for all students.
3. Ensure fairness by providing funding to districts with a lower-value tax base to make up the difference between what the district needs and what it is reasonably able to contribute based on fiscal capacity.

Process:

1. Ensure that dollars are used well to improve student learning outcomes while providing enough flexibility to allow districts to respond to their local needs and context.
2. Report school, district, and state-level spending data in transparent and accessible ways, including comparative spending data and contextual information, to empower stakeholders to engage in ongoing conversations about how the state’s funding meets students’ needs. 

School Funding Evaluation Tool