As a gifted coordinator of the gifted in Virginia Beach City Public Schools (VBCPS), 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 reflect current research and best practice in gifted education, to attend to the needs of large school divisions such as Virginia Beach, and to develop new regulations that improve the quality of gifted education. I do not support:

·         Assessment of each gifted student’s intellectual and academic growth because current VBCPS practices of embedding gifted 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 VBCPS 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, identification, and placement. This regulation also suggests 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 eligibility processes. This is an unreasonable expectation for a large school division with a centralized gifted eligibility committee;

·         Annual review of achievement data on all children K-12, but recommend maintaining review of student achievement data at key points throughout the K-12 continuum;

·         Acceptance of referrals and formal gifted identification 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 (K-2) 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 teacher 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; and

·         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.

Additionally, because there are no assessment materials that have been proven to be free of cultural, racial, and linguistic biases, requiring school divisions to assure that testing and assessment materials selected and administered are free of cultural, racial, and linguistic biases is impossible.  Further, this requirement calls into question even those instruments that have been shown to be valid and reliable measures of student abilities. I continue to support sensitivity to such biases and the eradication of them.

In conclusion, 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 Virginia Beach City Public Schools School Board 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.