As a parent of a gifted child in Virginia Beach City Public Schools, I do not support the proposed Gifted Program Regulations and advise the Virginia Department of Education and the State Board of Education to change the regulations to support current research and best practice in gifed education, to attend to the needs of large school divisions such as Virginia Beach and to develop new regulations that improve the qualify of gifted education.  I do not support:

• requiring school divisions to have assurances that testing and assessment materials selected and administered are free of cultural, racial and linguistic biases because there are not assessment materials that have been proven to be free of cultural, racial and linguistic biasis.  This is impossible and calls into question even those instruments that have been shown to be valid and reliable measures of student abilities.
• assessment of each gifted students' intellectual and academic growth because current practices of embedding gifed education in the regular education for sustained and ongoing development of students' gifts and talents is superior to an IEP like approach.  It is fiscally impossible to administer individualized intelligence tests to all gifted learners in a district the size of Virginia Beach Public Schools in order to report to parents and legal guardians on the intellectual growth of their child.
• the restricting time frame of 60 days for gifted referral, indentification and placement.  This regulation also suggest that a referral may be submitted at anytime and from the time it is submitted, the school division has 60 days to complete referral, identification and elegibility processes.  This is an unreasonable expectation for a large school division with a centralized gifted eligibility committee.
• annual review of achievement data on all chidren K-12 but recommend maintaining review of student achievement data at key points throughout the K-12 continuum.
• acceptance of referral beginning at kindergarten.  The proposed regulation fails to adequately ensure equity and excellence for all students with the potential for gifted identification.  In VBCPS, all students are identified for gifted services through the talent pool model at kindergarten and first grade.  This model ensures equity in access to all subgroups of the general population.  I recommend school divisions have the option of providing gifted services on a regular basis in the primary grades or beginning formal screening, referral and gifted identification processes.
• inclusion of a person on the eligibility committee who "knows the child" due to the costly nature of such a regulation in large school divisions with centralized eligibility committees as long as teach and parent input are provided.
• reporting of monitored and assessed outcomes of gifted learners.  This regulation suggests an IEP like approach to gifted services which would be detrimental to the existing high quality curriculum, instruction and assessment currently in place for gifted students in VBCPS.
• a shift from development of a five year local plan to an annual plan.  One year plans are not beneficial to the future growth and development of any gifted program.

In addition, I recommend that state funds administered by the Department of Education for the education of gifted students be used only to support those activities identified in the school division's Local Plan as approved by the School Board of the City of Virginia Beach and the Department of Education.  I recommend a change to REINSTATE:  State funds administered by the Department of Education for the education of gifted students shall be used to support only those activities identified in the school division's plan as approved by the Board of Education.