Sincere Thanks on Behalf of VACEG

                First of all I want to thank you for the Virginia Board of Education’s leadership in the area of Gifted Education. That leadership is demonstrated by the existence of the regulations themselves. It is also evident in the presence of the Commonwealth’s many Governors’ schools and by the effectiveness of the position held by Dr. Poland and her predecessors. The VACEG thanks you for maintaining our gifted advisory committee and for the opportunity to address you today.

 Comments on the Proposed Regulations

                When the VACEG reviewed the proposed changes to the Regulations for the Education of the Gifted our discussion fell into two categories, praise and concerns. I want to begin by sharing some of the praise for parts of the regulations, old and proposed.  We appreciate the regulations’ emphasis on instruction. Words like “continuous and sequential “ send a clear message to stakeholders about our state’s high standards for services for the gifted. Phrases like “assessed learning needs” assures gifted students and parents that the local services will be targeted to their unique needs.    Our committee also commented on how helpful the proposed definitions of such terms as screening and referral are to new coordinators of which there are many. We are pleased with the directive that all gifted plans need to be published on the Web. And most of all we appreciate all the research on best practices that went into the creation of the current regulations and their supporting documents. We are well aware that Virginia’s current regulations have been hailed as some of the best in the United States.

                Of course we have some serious concerns about the proposed changes. We want to be assured that gifted education in Virginia will take a step forward, not a step back, when and if the proposed regulations are passed. Our first concern was the elimination of 8 VAC 20-40-70.  Funding. The old regulations assured everyone that the any funds that were available were to “be used to support only those activities identified in the school division’s plan”. We were told this was being removed because it was seen as redundant. The members of the VACEG see this removal as a problem. From practical experience we know that many new coordinators are given copies of the regulations but nothing else when they enter their new positions. This funding statement alerts these coordinators that funds are available and that it is their responsibility to see that these funds are directed into services for the gifted. For equity reasons we do not want such funds overlooked in areas of the state where gifted education is not a priority to the local board. Members of the VACEG also point out that this statement in the regulations is very reassuring to the parents who serve on local advisory boards. It is important for the leadership and the community to understand that the state is adamant about gifted funding being spent on gifted services exclusively.  If you read the many comments currently posted on the Regulatory Town Hall site you will see that the removal of this section has raised a red flag to many individuals. We feel that this section needs to remain in the regulations when they are revised.

Our second area of concern was a revision to section 8 VAC 20-40-60. Local plan. Our current regulations call for DOE approval and a peer review. The proposed regulations only call for local school board approval.   For the past two planning cycles the DOE has required local division to submit 5-year plans. Then these plans are subjected to a peer review overseen by the DOE. Updates on the progress of the 5-year goals are required at the end of each year. This process assures the citizens of Virginia that there is both equity and excellence in gifted education throughout the Commonwealth. No plan is simply rubber stamped. Instead each plan is critiqued by the standards set in the regulations and has to be in line with them before it is approved. Many local plans are sent back for revisions, some of which are small, others  of great significance.   The VACEG is very concerned about the changes in this section. We are concerned that many local school boards may not have the expertise to assure parents that their locality’s plan does indeed meet the standards set in the regulations. We are worried that inequities will take place, particularly in small school systems where one coordinator holds several positions. He or she may overlook some of the more challenging aspects of the regulations in his/her plan.

Another area of concern in this same section is its emphasis on annual rather than 5-year plans. The state‘s Economic Impact Analysis of the implementation of the proposed regulations refers to the amount of time and money saved by the DOE if the peer review is eliminated, 150 hours and $4,000. The VACEG felt that the cost of the changes, in time and money, to localities will be far greater than that indicated in the analysis. Local coordinators may feel the need to spend more time writing plans annually rather than keeping their focus in the implementation of improvements. The students thus would become the big losers.  Coordinators may also return to setting small, inconsequential goals rather than 5-year goals which make a powerful impact on the gifted students in Virginia. My own locality has set 5-year goals that have had a positive effect on our learning community.  Our first 5-year goal was to create a Fine Arts Gifted Program. We now have services in visual art, theatre and vocal music. Our second 5-year goal is to implement a Middle Years Programme of the International Baccalaureate Organization. We are now into our third year of serving students through that program and it has impacted all the high end learners K-12 in our division. Without the DOE’s directive to create and implement 5-year plans these instructional improvements never may have happened. My example is not an isolated one. It is echoed throughout the state. The VACEG feels that a return to one year rather than 5-year plans is a mistake. It also feels that an approval process that allows those plans to be approved locally by persons who may not be experts is a large step backwards for gifted education. We ask you to take a hard look at this and take the steps you know are necessary to restore the 5-year plan and its approval by DOE back into the proposed regulations.

                The VACEG discussed several other concerns, most of which appeared in our May minutes published on the web. Since we did not address them in our letter I will not elaborate on them here. I do call your attention to two of the public comments published on your Virginia Regulatory Town Hall website that summarize our other concerns. One is from the Virginia Association for the Gifted, (comment 6/24/08 1608) and the other from the Consortium of the Gifted (comment 6/24/08 1612). They detail these other significant concerns.  The VACEG felt in its discussions that the local economic impact of such well intention decrees as the 60 day identification window, the measurement of “intellectual and academic” growth, and the use of “and” instead of “or” between subject areas when serving students in the area of Specific Academic Giftedness would be crippling financially to many school divisions.   The implementation of these proposed regulations will have a negative rather than a positive effect on gifted services.

                Again I thank you on behalf of the VACEG and all of the stakeholders that we represent for allowing me to speak today. I look forward to significant revisions to the proposed regulations and I ask for your continued support for the gifted learners in Virginia. 

 

Sincere Thanks on Behalf of VACEG

                First of all I want to thank you for the Virginia Board of Education’s leadership in the area of Gifted Education. That leadership is demonstrated by the existence of the regulations themselves. It is also evident in the presence of the Commonwealth’s many Governors’ schools and by the effectiveness of the position held by Dr. Poland and her predecessors. The VACEG thanks you for maintaining our gifted advisory committee and for the opportunity to address you today.

 Comments on the Proposed Regulations

                When the VACEG reviewed the proposed changes to the Regulations for the Education of the Gifted our discussion fell into two categories, praise and concerns. I want to begin by sharing some of the praise for parts of the regulations, old and proposed.  We appreciate the regulations’ emphasis on instruction. Words like “continuous and sequential “ send a clear message to stakeholders about our state’s high standards for services for the gifted. Phrases like “assessed learning needs” assures gifted students and parents that the local services will be targeted to their unique needs.    Our committee also commented on how helpful the proposed definitions of such terms as screening and referral are to new coordinators of which there are many. We are pleased with the directive that all gifted plans need to be published on the Web. And most of all we appreciate all the research on best practices that went into the creation of the current regulations and their supporting documents. We are well aware that Virginia’s current regulations have been hailed as some of the best in the United States.

                Of course we have some serious concerns about the proposed changes. We want to be assured that gifted education in Virginia will take a step forward, not a step back, when and if the proposed regulations are passed. Our first concern was the elimination of 8 VAC 20-40-70.  Funding. The old regulations assured everyone that the any funds that were available were to “be used to support only those activities identified in the school division’s plan”. We were told this was being removed because it was seen as redundant. The members of the VACEG see this removal as a problem. From practical experience we know that many new coordinators are given copies of the regulations but nothing else when they enter their new positions. This funding statement alerts these coordinators that funds are available and that it is their responsibility to see that these funds are directed into services for the gifted. For equity reasons we do not want such funds overlooked in areas of the state where gifted education is not a priority to the local board. Members of the VACEG also point out that this statement in the regulations is very reassuring to the parents who serve on local advisory boards. It is important for the leadership and the community to understand that the state is adamant about gifted funding being spent on gifted services exclusively.  If you read the many comments currently posted on the Regulatory Town Hall site you will see that the removal of this section has raised a red flag to many individuals. We feel that this section needs to remain in the regulations when they are revised.

Our second area of concern was a revision to section 8 VAC 20-40-60. Local plan. Our current regulations call for DOE approval and a peer review. The proposed regulations only call for local school board approval.   For the past two planning cycles the DOE has required local division to submit 5-year plans. Then these plans are subjected to a peer review overseen by the DOE. Updates on the progress of the 5-year goals are required at the end of each year. This process assures the citizens of Virginia that there is both equity and excellence in gifted education throughout the Commonwealth. No plan is simply rubber stamped. Instead each plan is critiqued by the standards set in the regulations and has to be in line with them before it is approved. Many local plans are sent back for revisions, some of which are small, others  of great significance.   The VACEG is very concerned about the changes in this section. We are concerned that many local school boards may not have the expertise to assure parents that their locality’s plan does indeed meet the standards set in the regulations. We are worried that inequities will take place, particularly in small school systems where one coordinator holds several positions. He or she may overlook some of the more challenging aspects of the regulations in his/her plan.

Another area of concern in this same section is its emphasis on annual rather than 5-year plans. The state‘s Economic Impact Analysis of the implementation of the proposed regulations refers to the amount of time and money saved by the DOE if the peer review is eliminated, 150 hours and $4,000. The VACEG felt that the cost of the changes, in time and money, to localities will be far greater than that indicated in the analysis. Local coordinators may feel the need to spend more time writing plans annually rather than keeping their focus in the implementation of improvements. The students thus would become the big losers.  Coordinators may also return to setting small, inconsequential goals rather than 5-year goals which make a powerful impact on the gifted students in Virginia. My own locality has set 5-year goals that have had a positive effect on our learning community.  Our first 5-year goal was to create a Fine Arts Gifted Program. We now have services in visual art, theatre and vocal music. Our second 5-year goal is to implement a Middle Years Programme of the International Baccalaureate Organization. We are now into our third year of serving students through that program and it has impacted all the high end learners K-12 in our division. Without the DOE’s directive to create and implement 5-year plans these instructional improvements never may have happened. My example is not an isolated one. It is echoed throughout the state. The VACEG feels that a return to one year rather than 5-year plans is a mistake. It also feels that an approval process that allows those plans to be approved locally by persons who may not be experts is a large step backwards for gifted education. We ask you to take a hard look at this and take the steps you know are necessary to restore the 5-year plan and its approval by DOE back into the proposed regulations.

                The VACEG discussed several other concerns, most of which appeared in our May minutes published on the web. Since we did not address them in our letter I will not elaborate on them here. I do call your attention to two of the public comments published on your Virginia Regulatory Town Hall website that summarize our other concerns. One is from the Virginia Association for the Gifted, (comment 6/24/08 1608) and the other from the Consortium of the Gifted (comment 6/24/08 1612). They detail these other significant concerns.  The VACEG felt in its discussions that the local economic impact of such well intention decrees as the 60 day identification window, the measurement of “intellectual and academic” growth, and the use of “and” instead of “or” between subject areas when serving students in the area of Specific Academic Giftedness would be crippling financially to many school divisions.   The implementation of these proposed regulations will have a negative rather than a positive effect on gifted services.

                Again I thank you on behalf of the VACEG and all of the stakeholders that we represent for allowing me to speak today. I look forward to significant revisions to the proposed regulations and I ask for your continued support for the gifted learners in Virginia.