The Talented and Gifed Advisory Committee of the School Board of the City of Alexandria unanimously adopted the following recommendations opposing proposed changes to state regulations for gifted education.  The recommendations were unanimously adopted by the School Board of the City of Alexandria on June 23, 2008.

RECOMMENDATIONS TO ALEXANDRIA SCHOOL BOARD

The proposed new state regulations would make several significant changes to the operation of the ACPS Talented and Gifted program. In assessing this 16-page document, we have focused on several issues we believe are important to promote a strong TAG program without significantly increasing local costs. We are supportive of provisions that better define public input, including a commitment to opportunities for public review and accessibility. Many of our concerns focus on provisions that would transfer a costly compliance review process from the state to the local level. Additional comments focus on student testing and annual reviews of the program. In all cases we have suggested the change or removal of certain language and use of other wording.

State / local authority for gifted programs: Page 12, Paragraph A

Remove: …review and approve annually a comprehensive plan… (requiring local Boards to review and approve a TAG plan each year)

Reinstate: Each school division shall submit to the Department of Education for approval a plan for the education of gifted students…

Rationale: The TAG Advisory Committee is not opposed to greater local authority per se. However, requiring a local Board to annually approve a comprehensive TAG plan, without the benefit of peer review, is problematic. The Alexandria School District has struggled for more than two years to finalize a 2006-’11 five-year plan. Given the community’s well-documented interest in this issue, it is likely that annual approval of a comprehensive TAG plan would consume even more of the School Board’s time. Lack of peer review from the state also may add to politicization of the process, regard-less of the composition of the School Board. TAGAC believes that state-funded peer review provides important checks and balances for the system. The only way it would continue under the proposed regulations is if ACPS funds peer review with its own funds – an added expense – on an annual basis.

Due to these concerns, the committee recommends reinstatement of the current language. TAGAC does believe the state process needs improvement. Ideally, one state- and Board-approved plan should begin as another ends. That is not a current issue up for debate, however. In addition, the committee strongly recommends one or more public hearings before submitting future draft local plans to the state. The Board has the ability to convene such hearings at any time under the current regulations. The proposed new regulations do contain constructive language in Paragraph A to guarantee opportunities for public input and review.

The Identification Process: Page 9, Section 3e and Paragraph 4

Change: Uses of the phrase “norm-referenced aptitude tests” should be changed to “nationally norm-referenced aptitude and/or achievement tests.”

Rationale: The changes ensure that the regulations maintain an emphasis on both achievement and aptitude testing. Using both tests in the identification process is vital, since there are scenarios in which using only one type of test could result in an incomplete or inaccurate view of a student's TAG readiness. In particular, using only aptitude tests in the identification process could create an inadvertent bias against twice-exceptional students (in need of special education and gifted services) or students from other special circumstances, who would benefit from the use of multiple measures.

Student Referral Process: Page 9, Paragraph E

Change: Within 60 business days of the receipt of a referral…   To: Within 90 instructional days beginning with the receipt of a parent/guardian consent for assessment…

Rationale: While ACPS strives to complete action as quickly as possible, TAG referrals are a highly cyclical process. In Alexandria, there are approximately 100 referrals at the start of the school year and 250-300 in the spring. Alexandria has only one TAG Curriculum Specialist, and it is important that identification panels take the time to conduct testing, collect student work products, receive input from parents and teachers, and provide a thorough review. Staff report that narrowing the process to 60 days, particularly in the spring, may require shortening identification committee meetings on individual students to 15 minutes from the current 30 minutes. Currently, a TAG referral in ACPS typically is completed in 65 to 85 school days. Another concern with the proposed change is that it involves “business days,” when a district’s instructional days are a much better target for a goal.

It should be noted that ACPS is considering changes in the day-to-day responsibilities of its TAG Curriculum Specialist, but that process is only a goal at this point. It is not known as yet whether any change would shorten the expected length of time to complete referrals.

Student Outcomes and Intellectual Growth -- Page 15, Paragraph 14

Remove: Procedures for the annual evaluation of the effectiveness of the school division’s gifted education program, including review of student outcomes and the intellectual and academic growth of gifted students. Such evaluations shall be based on multiple criteria and shall include multiple sources of information for gifted students.

Insert: Procedures for the annual review of the effectiveness of the school division’s gifted education program, including a procedure to identify and evaluate outcomes based on the initial and ongoing assessment of students’ cognitive and affective needs.

Discussion: Our concern here is not the importance of outcomes but with potential costs and unfunded mandates. There are currently many ways that ACPS reviews outcomes and assesses the progress of gifted students. Quarterly and annual tests examine the skills of TAG students. The Talented and Gifted specialist makes regular classroom visits in schools to monitor service delivery and attends every eligibility meeting for placement of new students into the program. Classroom and TAG teachers conduct regular parent/teacher conferences that focus on outcomes, and teachers also send out mid-term notices to students and parents about significant academic concerns.

A concern with the new regulation is that formally reviewing students’ “intellectual growth” and unspecified “multiple criteria” and “multiple sources of information” would require additional, regular and individual meetings with up to 1,500 TAG-identified individuals. ACPS teachers in particular have cited concerns with this section, noting it may require them to develop a document not unlike a special education IEP. We believe that ACPS could accomplish this task and be in full compliance with the regulations only if it adds significantly to its TAG staff.

Funding – Page 16

Insert / 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.

Rationale: The proposed deletion of this language was likely a formality in keeping with the proposed elimination of state-supported peer review and approval. Our recommendation to reinstate the above language is in keeping with our prior recommendation to retain the state approval process. The rights of gifted students under the law are best protected when funds cannot be redirected for other purposes.