As a parent of two children that have benefitted from gifted and talented education I urge you not to adopt these regulatory changes. As written, our students are at risk of receiving a significantly reduced level of services. When faced with budget shortages, these programs will be put on the table first. We have already seen this at the elementary school level in our local community. Suggest that a panel of experts be brought together to craft new regulations which ensure a baseline of G/T services to be provided to students throughout the state.
Specific Comments include:
The proposed new state regulations would make several significant changes to the operation of the ACPS Talented and Gifted program. In assessing this Provisions that would transfer a costly compliance review process from the state to the local level are in essence unfunded mandates. Given the current cost of existing unfunded mandates, the lower transfer costs of education funds to Northern Virginia, and budget shortfalls expected in the next few years, this is not sustainable.
The level of student testing and annual reviews of the program is also a costly burden in lean times. The current system of submitting plans works. Annual plans could be costly to implement.
Identification of students should be based on multiple sources including nationally recognized assessment tests, aptitude tests and classroom performance. Additionally, the timeline seems to be quite short given the various sizes of school systems in the state.
A concern with the new regulation is that formally reviewing students’ “intellectual growth” and unspecified “multiple criteria” and “multiple sources of information” essentially requires a special education IEP and annual review. The cost of administering this type of program is hugely expensive and seems to span the 13 years a child is in school.
It is critical that 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. This is necessary to ensure that at the local school level funding is available to provide services to the gifted children and cannot be redirected for other purposes.
In conclusion, please go back to the drawing board and draw upon experts across the state.
