As an educator of the gifted in Virginia Beach City Public Schools, 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 the needs of large schools divisions such as VIrginia Beach, and to develop new regulations that improve the quality of gifted educaiton. 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.
• The restricting time frame of 60 days for gifted referral, identification, and placement. 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. 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 identificaiton processoes;
• 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.
• 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 and the Department of Education. I recommend a change to reinstate: State funds administered by the Department of Education for the educaiton 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.