Public Comment by Arlington Public Schools Gifted Services Office of Arlington, VA to Recommended Changes to

Proposed Revisions (Chapter 40)

Regulations Governing Educational Services for Gifted Students

Arlington Public Schools respectfully responds to the Proposed Regulations:

1. Local school division plans should be developed on a 5-year basis in order for school divisions to have the opportunity to develop long-term goals, implement changes, and evaluate before updating the plan. Having plans developed on an annual basis is not sound educational practice.

2. The Department of Education should retain authority for approval of local 5-year plans to ensure compliance to minimum requirements of identification and programming across the Commonwealth. The present system of peer review is not only an accountability measure, but a teaching and learning process for school division coordinators of gifted education.  The removal of the state from the process of approval of the gifted 5-year plan introduces potential for inconsistencies and non-compliance with the regulations and places the burden for alignment on the local school divisions.

3. Reinstate the Criteria for Identification Option permitting “individual or group achievement test” for identification of students in specific academic areas with the suggested revision of “individual or group nationally norm-referenced aptitude and/or achievement tests.”  The proposed revision moves to total reliance on aptitude tests for identification of Specific Academic Aptitude areas (SAA). There are cost implications for resources and time for administering aptitude tests for SAA and concerns about the quality and availability of national normed aptitude tests in all subject areas, especially science and social studies.  There is also concern in meeting the expectation of finding aptitude tests that are “free of cultural, racial, and linguistic biases” rather than “sensitive to cultural, racial and linguistic biases.”  

Change to: If a program is designed to address specific academic aptitude, an individually administered or group-administered, nationally norm-referenced aptitude/or achievement test shall be included as one of the three measures used in the school division’s identification procedure.

4. Permit school divisions to outline an eligibility process timeline within their 5-year local plan rather than the proposed revision which specifies that the identification process must be completed within 60 business days of receipt of referral.  Identifying a specific number of days doesn’t recognize the variety of programs for which eligibility processes are used.  Arlington Public Schools agrees with the Consortium’s recommendation that the time line be “within 90 instructional days beginning with the receipt of parent/guardian consent for assessment.”   This would initiate the process with the parental consent for assessment rather than the referral and permit a semester timeline, still allowing for two eligibility windows per school year. 

Arlington Public Schools is sensitive to the concerns of larger Virginia school divisions that provide both county-wide and school-based programs that would be unable to execute a valid or reliable process within 60 business days.  APS also supports the language revision “within a time-line set by the school division.”  

      Finally, there is concern about cost implications for additional staff resources and time devoted to a 60-business day eligibility process as well as taking the focus of gifted education staff away from the delivery of gifted services and focusing more time and resources on expediting the eligibility process.

5. Arlington Public Schools objects to the definition of student outcomes within the Proposed Regulations including other specific outcome language within the document including
   1. “monitored and assessed student outcomes that are reported to the parents and legal guardians;
   2. Parents and legal guardians shall receive assessment of each gifted student’s intellectual and academic growth;” 
   3. and any language related to individual documentation of student instructional plans, performance expectations and goals, outcomes, and measurement of students’ intellectual and/or academic growth in addition to standard reporting systems used for the general student population.

            The Proposed Revisions introduces language more in-line with IDEA without the financial or personnel support needed to engage in individual           monitoring or documentation of students’ outcomes.  This would encumber an economic burden on school divisions who would need to redirect personnel and resources away from student services to data  collection, assessment, and outcome reporting.

6. Reinstate gifted funding section directing that funding administered by the DOE for the education of gifted students be used only to support those activities identified in the school division's plan as approved by the Board of Education (BOE).

Additionally - Arlington Public Schools concurs with the specific changes proposed by both the Virginia Association of the Gifted and the Virginia Consortium of Gifted Education Administrators.