I do not see a need to amend the current regulations regarding gifted education.  As I understand this proposed amendment, it could result in a watering down of the progress made in gifted education.  Gifted students have special needs just as special education students or students who speak English as a second language.  Programs for those students are closely monitored by federal and state regulations whereas gifted programs are not.  Therefore, Virginia has an obligation to be the single advocate in funding and regulating what gifted education should look like.

This proposed amendment would allow districts to set their own criteria for identifying gifted students and could eliminate funding to provide teachers for these children.  It may make it to easy for various districts to make the regulations suit their budget needs rather than the needs of the students.  I urge you to carefully reconsider this amendment and choose to leave the current plan for gifted education in place as it is.

I am writing as a public school teacher who teaches children of all abilities and needs.  I am writing as a taxpayer.  I am writing as a parent with children that have graduated from the Virginia public schools.

These proposed regulations will eviscerate the gifted education program in Virginia.  Allowing each locality to set its own standards with no statewide supervision will render the Virginia Gifted Education Program meaningless and erode our students' place in the national educational marketplace.  This type of reversion to local supervision and funding is nothing more than an attempt to eliminate the program entirely.  Our children have a right to demand more from our state and our lawmakers. 

Please do not adopt the new resolution.  It is important for the divisions to submit their plans to the DOE rather than just to their own school boards.  The state needs to have regulatory and supervisory powers over the plans so all students receive the same level of services through the commonwealth.  There also needs to be accountability for the funding for gifted students.

• Change the last sentence to: Such students demonstrate or have the potential to demonstrate superior reasoning; persistent intellectual curiosity; advanced use of language; exceptional problem solving; rapid acquisition and master of facts, concepts, and principles; and creative and imaginative expression beyond their age-level peers in selected academic areas as defined by one or more of the following: English/ language arts, mathematics, history/social science, or science.

• Change to: “Referral” means the formal and direct process that parents/guardians, teachers, professionals, students, peers, self, or others use to request that a kindergarten through twelfth-grade student be assessed for gifted education program services.

• Change to: Screening is the annual process of creating a pool for potential candidates K-12 using multiple criteria through the referral process, review of current assessment data, or information from other sources. Screening is the active search for students who are then referred for the formal identification process.

• Change to: Service options means the instructional approaches, settings, and staffing selected for the delivery of appropriate service or services provided to eligible students based on their assessed needs in their areas of strength.

• Paragraph A, change to: If the school division elects to identify students with specific academic aptitudes, it shall include procedures for identification and service in one or more of the following: English/ language arts, mathematics, history/social science, or science.

• Paragraph A, change to: School divisions may identify and serve gifted students in career and technical aptitude or visual or performing arts aptitude.

• Paragraph B, change to: Some data used in the screening process may be incorporated into multiple criteria reviewed by the designated identification and placement committee to determine eligibility, but those data shall not replace norm-referenced aptitude test data.  

• Paragraph C, change to: These uniform procedures shall permit referrals from school personnel, parents/guardians, teachers, professionals, students, peers, self, or others.

• D.  An identification and placement committee …change to: A designated identification and placement committee…

• Paragraph 2, change to: The committee shall determine the eligibility of each referred student for the school division’s gifted education services.

• Paragraph 2, change to: Students who are found eligible by the identification and placement committee shall be offered service options with appropriately differentiated curriculum and instruction by the school division.

• Paragraph 5, change to: If a program is designed to address either the visual or performing arts or career and technical aptitude, a portfolio or other performance assessment measure in the specific aptitude area shall be included as part of the data reviewed by the identification and placement committee.

• Paragraph E, change to: Within 60 school days of the receipt of a referral, the identification and placement committee shall determine the eligibility status of each student referred for the division’s gifted education program and notify the parent or guardian of its decision.

• Paragraph A, remove: Each school board shall review and approve annually a comprehensive plan for the education of gifted students that includes the components identified in these regulations.

• Paragraph A reinstate: Each school division shall submit to the Department of Education for approval a plan for the education of gifted students that includes the components identified in these regulations.

• Paragraph 3, change to: Procedures for the early and on-going screening, referral, identification and placement of gifted students; beginning with kindergarten through twelfth-grade in at least a general intellectual or a specific academic aptitude program; and, if provided in the school division, procedures for screening, referral, identification, and placement of gifted students in visual or performing arts or career and technical aptitude programs;

• Paragraph 14, remove/delete: …including review of student outcomes and the intellectual and academic growth of gifted students.

• Paragraph B (ii) add: …to review annually the local approved plan …

• 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.

The Standards of Learning set a benchmark that eventually all students in the Commonwealth must reach to graduate from high school.  The SOL's enhance our credibility with the public and help satisfy compliance with No Child Left Behind federal legislation. 

Virginia's continued commitment to gifted education aims our sights above the minimum bar established by NCLB and indicates our intention to produce students for the Commonwealth and the nation's universities who, by being challenged to fulfill their potential, will lead the way confronting the challenges before us in this century.  Never before have so many demanded so much from our public schools; in Virginia, our response should clearly be, whenever possible, "Yes, we will achieve that............and more." 

Research clearly indicates that gifted learners require challenge beyond the regular classroom, that they need intellectual stimulation from their gifted peers, and that  giftedness not nurtured will not develop.  There are gifted children spread throughout our Commonwealth, and quite a few of them do not live in prosperous communities whose greatest efforts can be directed toward providing for their needs.  To serve these "diamonds in the rough," and really all of Virginia's gifted learners, it is essential that the following sections of the revised Regulations be reconsidered:

8VAC20-40-60 Assurance of gifted funding was omitted on the grounds it was redundant because funding is assured in the Appropriations Act. 

Parents, teachers, and administrators can easily find the assurance if it is repeated in the Regulations.  If the wording is repeated exactly, nothing in the Regulations will contradict the Appropriations Act.  Repeating the wording provides enough clarity to stakeholders that the repetition outweighs any concern over redundancy.

8VAC20-40-70 Language was stricken regarding current five-year local plans (replaced by a mandate for annual plans) and the exculsion of our current peer-review process. 

The format of a five-year plan allows yearly goals, and fulfillment of these goals is monitored by each locality's advisory committee and reported to the locality's Superintendent and School Board.  The five-year plan is superior to the annual plan because it allows local gifted programs to take a long-range view of their services, to set goals for improvement, and to build programs that are modified and enhanced through research and development that are real, adequately considered, and meaningful. 

The current peer-review process allows coordinators from different school systems to meet and see the components of other localities.  The benefits of this process are two-fold:  firstly, peer-review ensures that all localities are in compliance and allows coordinators not in compliance to spot trouble spots and correct them; secondly, peer-review is a "meeting of the minds" that allows coordinators to share best practices and expand the basics of quality services throughout the Commonwealth.  Under the peer-review process as it exists, coordinators are exposed to each other's innovative ideas, learn from one another's experiences, and serve as a "sounding board" for one another.  Peer-review is a process that costs little and provides a valuable service to coordinators and, indirectly, to the students served by their programs.  We can't afford to lose it.

Thank you for the opportunity to share my opinion.

It is critical to the education of gifted students that the DOE have regulatory power over funding and plans.  Five year plans are far more effective than annual plans.  Having local school boards be the regulators for funding and plans will only lead to lack of funding for gifted education and inconsistency in the quality of programs throughout the Commonwealth.  I urge you to value our gifted students and allow them to achieve to their highest potential by rejecting the current regulations under consideration.

The proposed regulations to change Virginia's gifted state program should not be implemented.  Allowing local school authorities to have autonomy over the gifted programs will be a death sentence for every identified gifted child.  The state needs to step up to the plate and continue to oversee to the welfare of each and every gifted child. 

The state of Virginia should be overseeing the education and welfare of EVERY child. Not including gifted children in this equation would have a terrible effect on Virginia's excellent education record. 

Please be an advocate for these children and continue to oversee to their well-being and education. 

To Whom It May Concern:

I am a concerned gifted education resource teacher who strongly supports keeping our current Gifted Regulations as opposed to implementing the proposed changes.  I believe that a period of five years is necessary to present a Local Plan and that our plan should be submitted for peer revision before a final copy is approved.  I also firmly support having funds earmarked for gifted services only so that the money intended for gifted students is directed to each district's Gifted Department.  Further, I support keeping the approval of local plans in the hands of the current evaluators, and feel that approval of district plans should not be the responsibility of local school boards.

Respectfully submitted by,

Beverly Preisser

My career in gifted education spans two decades and two states.  As a teacher of the gifted in Virginia, and previously as a teacher and coordinator for the gifted in Mississippi, I am familiar with the importance of good regulations which govern the delivery of gifted services and support the continuity and reliability of those services for students who need them.  Additionally,  I am the mother of two sons who were early-identified as gifted and who benefited enormously from these services.  I now have grandchildren (residents of Virginia) who may or may not benefit in the future from gifted services.  All of these facts give me a great interest in gifted education. 

Because of my personal and professional history with gifted education, I realize the importance of dedicated funding for gifted services and the necessity of having 5-year plans.  No entity, either in the private or public sector, can function optimally without the assurance of time to make and implement plans, and without the security of funding which is associated with that well-defined purpose.  A fair and consistent method of determining eligibility is also necessary in order to insure the integrity of gifted education. 

Please continue to support a rigorous and consistent identification process, the ability to make 5-year plans, and dependable, dedicated funding.  Please reinstate funding for the gifted which can be used ONLY for gifted education.  Please allow school districts to develop 5-year plans.  Please require districts to comply with minimum standards for gifted identification. 

The future of this nation depends on our youth.  Please do not do them the disservice of bowing to the political whim of the moment!

As the mother of two gifted students and a teacher with more than twenty-five years of experience, I do not want to see the proposals enacted.  Both proposals have the potential to significantly weaken the education of the gifted.  Giving local school boards sole jurisdiction over the Local Plan is not the best course of action because most members of most school boards have no training in educating gifted students therefore they will not have the experience nor the expertise to adequately critique the plan and offer constructive suggestions.  In addition to these concerns, enacting the second proposal which will take away the language that funds gifted education will enable local school boards to shift funds from gifted students to any other group that they feel needs the money.  Already No Child Left Behind and making AYP, dictate too much of how funds are allocated and what curriculum is taught.  In our efforts to meet the dictates of the government, we are leaving behind another group of students.  Without funding, programs for the gifted could be eradicated.  We must oppose these proposals.

I would like to ask that local school division plans be developed on a 5-year basis in order for school divisions to have the opportunity to develop long-term goals, implement changes, and evaluate before updating the plan. Having plans developed on an annual basis is not a sound educational practice.

The plans should be submitted to the Department of Education for approval to ensure compliance to minimum requirements of identification and programming across the Commonwealth. The present system of peer review is not only an accountability measure, but a teaching and learning process for school division coordinators of gifted education. 

Please reinstate gifted funding section which states that funding administered by the DOE for the education of gifted students be used only to support those activities identified in the school division's plan as approved by the Board of Education (BOE). 

While I understand these are changes that are being proposed - I caution that there are many children in our shool systems who really need to be the beneficiaries of these requests. Just as our handicap students need state support, our gifted also need to be challenged and to succeed as well and they often don't when they aren't stimulated. Without the appropriate system in place to ensure all children will learn and grow in our school system - gifted children won't have the structures in place to provide enough learning stimulation which will result in acting out and rebellion. Only our local schools know what is best for their specific area and to take this away from them is doing a disservice to not only the students but to the community at large as well.

Thank you for your consideration.

Royanne Dell

I urge our officials to support Gifted Education in Virginia to the fullest extent possible, and then some.  Particularly in this period of the mediocritization of our public education, enforced by the No Child Left Behind (i.e., the No Child Pushed Ahead) policies and the draconian standardized tests that force our best teachers to limit their creativity and their teaching strategies, we desperately need programs that will allow children to grow, flourish, expand, and challenge themselves.  I have been SO impressed by our Virginia teachers at all levels, and I urge our officials to support all their efforts, particularly by making Gifted Education rich, accessible, and transparent in its funding. 

I support the following requests:

(1) that local school division plans be developed on a 5-year basis in order for school divisions to have the opportunity to develop long-term goals, implement changes, and evaluate before updating the plan. Having plans developed on an annual basis is not a sound educational practice.

(2) that the plans be submitted to the Department of Education for approval to ensure compliance to minimum requirements of identification and programming across the Commonwealth. The present system of peer review is not only an accountability measure, but a teaching and learning process for school division coordinators of gifted education.

(3) for reinstatement of gifted funding section which states that funding administered by the DOE for the education of gifted students be used only to support those activities identified in the school division's plan as approved by the Board of Education (BOE).

As a taxpayer, parent, and educator in the great Commonwealth of Virginia, I am compelled to remind my fellow citizens how successful the Virginia Department of Education has been in preparing Virginia’s youth for future challenges.  For this reason, I am extremely alarmed to learn of proposed revisions being considered for regulations governing gifted programs.  With the great degree of success experienced by Virginia’s students national and global arenas, I am shocked at the lack of forethought these proposed revisions contain.  In order to safeguard the education of our most talented youth, it is critical that the Department of Education retain the following regulations governing gifted programs:

1) Local school divisions must continue to develop plans on a 5-year basis in order to have the opportunity to develop long-term goals, implement changes, and evaluate their success before updating the plan for another cycle.  Having plans developed on an annual basis does not allow time for this process in a manner that permits meaningful input from taxpayers, parents, and educators.  It is not sound educational practice.

2) Plans must continue to be submitted to the Department of Education for approval to ensure compliance to minimum requirements of identification and programming across the Commonwealth. The present system of peer review is not only an accountability measure, but a teaching and learning process for school division coordinators of gifted education. The standards set forth by the Vir ginia Department of Education have been the bedrock of our success in education in the Commonwealth. Removal of the review process will create discrepancies in gifted program services across the Commonwealth. Educators will lose a valuable learning process. Taxpayers will no longer be able to check with the Department to see if their local school division's plan for education of gifted students officially complies with the state regulations. 

3) Please reinstate the gifted funding section of the regulations governing gifted education which requires that funding administered by the DOE for the education of gifted students be used only to support those activities identified in the school division's plan as approved by the Board of Education (BOE).  This is necessary to ensure that standards and best practices for educating our most intellectually talented students can continue to be maintained, and that taxpayers’ money will not be frittered away on frivolous or unnecessary distractions that don’t enhance the preparation of our youth to meet future challenges. 

Any changes to the regulations governing gifted programs that do not include these safeguards will compromise a fiscally responsible program that is proven successful in placing Virginia at the forefront of education in our country.  Why current suggestions are being put forth to undermine this success is completely mystifying.  Please prevent damaging proposals from going forward.

I have three children who benefit from the gifted program.  Their needs cannot be met in the "regular" classroom.  Not because they don't have wonderful, capable teachers, but because of the pressures teachers and schools face with the No Child Left Behind testing climate.  As a result, the standard curriculum is leaving our gifted children behind. 

The gifted program provides them with a needed respite from a curriculum that is not designed to meet the needs of gifted children.   These children need and deserve to have their rights to an appropriate education protected.

Giftedness is not something you do, it is what you are.  Do not punish these children for what they are by taking away the gifted program funding.

Under no circumstances should the "Propsed Revision of Gifted Program Regulations" be made. If these revisions  are implemented, gifted education in Virginia will take many steps backward in meeting the needs of gifted and talented students. The great state of Virginia should be looking for opportunities to increase, not decrease, support of this student population.

Gifted and talented students will make positive changes in our country and our world by: discovering cures for diseases; serving as diplomats; finding alternative energy sources; creating symphonies; or inventing things that haven't yet been imagined.

This will continue only if students have an excellent K-12 education which meets their academic needs, keeps them engaged, challenged, motivated, and focused on an academic path toward higher education. There are published studies indicating a significant percentage of high school drop-outs are identified gifted students. 

It's a sad reflection on our values as a nation that there is still no federal mandate to meet the real needs of gifted and talented students; and it is even sadder that Virginia is considering removing the positive steps made by the state in support this unique population.

A five-year plan for the gifted and talented offers the opportunity for a committee to become familiar with state requirements, create both long and short-term goals, analyze and evalutate progress, and have the plan reviewed by educational peers outside of the division. This committee has input from educators, parents, and administrators, which allows for many points of view, thus making the plan stronger. 

Having the proposed plan submitted to the Department of Education for approval assures that it meets state requirements and students are being treated fairly across the Commonwealth. It is important to have uniform standards and regulations in place statewide.

Funds allocated by the state for gifted education should be approved by the Board of Education to ensure that these funds are used to support activities approved by the BOE.

Virginia should take a leadeship role in gifted education - to be recognized for innovation - not noted for taking away support from gifted and talented programs. Our society needs these students and the contributions they will make through their gifts and talents to our state, country, and world.

Please do not make these proposed changes to the gifted education program.  

Gifted Education in Virginia is very much a balancing act between local school boards, localities, and the willingness of teachers to go above and beyond for our children.  I am very pleased that my child has flourished in our county program for gifted education.  As a concerned parent I was very disappointed to hear about proposed changes to the guidelines for gifted education in Virginia.  Specifically, I am opposed to the changes to 8VAC20-40-60 (Local plans) and 8VAC20-40-70 (the repeal of the funding language) listed below.

The proposed revision of 8VAC20-40-60 (Local plans) states that the local plan will  no longer be submitted to the Department of Education (DOE) for approval, and will instead be approved annually by the local school board.  This change is detrimental for several reasons:

1.  The only quality control and outside review of a division plan is through the approval process by the DOE.  Without DOE apporval, no central authority will be responsible to confirm that the plan is in compliance with regulations.

2.  Educators and community stakeholders invest significant time and effort to create a 5-year plan and in the process seek peer review from other gifted education colleagues.  To shift this process to the local level will eliminate the productive insights that emerge from this peer review.

3.  It is not productive to develop a plan on an annual basis.  The local advisory committee is given  the responsibility to review annually the local plan to determine effectiveness and submit recommendations in writing to the superintendent and school board.

4.  As a whole, school board members are not considered experts in the field of gifted education and will not be able to provide feedback for gifted program plans.

The proposed revision of 8VAC20-40-70 (State Funds) states that repeal of the funding language which previously stated "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" is seriously problematic for the following reasons:

1.  Currently, Standards of Quality (SOQ)  Basic Aid Funding for gifted education supports the state share of one full-time equivalent instructional position (FTE) per 1,000 students in adjusted average daily membership (ADM) of a school division.

2.  What happens to the funds that were intended for gifted program services?  In the absence of this regulatory language protecting the funding for gifted program services, funds could be used for other purposes which could reduce the quality of gifted programming in many school divisions.

I ask that you look at these two extremely pivotal issues in gifted education in Virginia and ask yourself if you would want your gifted learner to be shortchanged by these two changes in policy.  Please vote "NO" on these two revisions and continue to keep gifted education in Virginia a priority. 

Thank you for your time.

To Whom It May Concern:

I would like to express my concerns about the proposed changes in legislation regarding Gifted Education Programs in VA public schools.  Both of our daughters had the opportunity to participate in gifted programs in Hanover County Public Schools, graduated in 1996 and 1998, excelled in their undergraduate education and now are contributing businesswomen.  In a time of complaints that American public education languishes behind other global education programs and when many are choosing to educate their children at home or in private institutions due to poor discipline and achievement in public classrooms, it seems ill advised to weaken the very programs that seek to elevate the quality of education for those able to achieve and make outstanding contributions.  I urge you to revise the changes proposed and to certainly include:

(1)       Each local school division shall submit to the Department of Education for approval a plan, developed on a 5-year basis, for the education of gifted students to ensure that the regulations are being followed.

(2)       State funds administered by the DOE for the education of gifted students shall be used only to support those activities identified in the school division's plan as approved by the Board of Education (BOE).

It was my experience, as an active parent in the public school and as a part-time school employee, that MORE NOT LESS needs to be done to address excellence and ensure that every student, both special education and gifted, reach their full potential.  It is also essential that professionally trained educators and experts be involved in policy-making and oversight of programs.  Our local school board is NOT composed of such and should not have sole oversight of gifted or other programs.  

Education is also a process that does not happen in year increments.  It is imperative that plans for gifted (and other) programs are developed for the long-term and not be subject to changes, and possible omission, each year in the budget process as the revision under consideration allows.

In short, it is imperative that Gifted Programs continue to be approved by the Department of Education, be long-term (‘developed on a 5-year basis”) and that the funds be designated solely for that purpose in language that will not allow diversion of state funds to other local programs.

July 1, 2008

Mark Emblidge, Chairman, Ph.D. 

State Board of Education

413 Stuart Circle, Suite 130

Richmond, VA  23220

Dear Dr. Emblidge:

I am writing to express my concern regarding suggested changes in appropriations and planning for gifted education in Virginia.  I am concerned about the repeal of funding from regulation 8VAC20-40-70.  Even though I understand that this language is included elsewhere, it should be included with the educational regulations for clarity and accessibility to parents.

I am also concerned about the repeal of language requiring oversight by the State Department of Education.  This is critical to ensuring high quality throughout the Commonwealth of Virginia. 

I am furthermore concerned about the proposal to reduce the current five year program to an annual report. This limits the ability of school districts to develop long range plans.  In my private practice of medicine, I tend to think of business strategy on a rolling five year plan.  Plans are developed annually but very few plans have such short-sighted objectives that they can routinely be completed within the first year.  I recommend that all local school division plans include a five-year proposal, even if these plans are refreshed on an annual basis and I ask that these plans be reviewed at the state level. 

I have been most grateful that two of my three children have been selected for gifted education in Henrico County.  In my previous experience, I have seen significant resources expended for those who are struggling but fewer resources available for those who have the opportunity to become leaders.  I hope that the state will continue to see the great value of developing tomorrow’s leaders among our children today.

Sincerely,

Michael Armstrong, Jr., M.D.

MA/bp 

CC:    Donna Poland, Ph.D.

          Dr. Billy K. Cannaday, Jr.

I am writing as a parent of two children who have graduated from Richmond Public Schools and who benefitted greatly from programs for gifted learners.  During their years in RPS, I also served as a member and chair of the RPS Parents Advisory Committee for Programs for Gifted.  

Having helped to edit several 5-year plans, I can attest to the advantage of having one.  During my tenure on the Parents Advisory Committee, we were able to put needed improvements, staff positions and new programs before the RPS Board through the 5-year plan and see them implemented over time. Our Gifted Coordinator spoke often of the many positive aspects of having our 5-year plans reviewed by peers in other systems and of the valuable information that was afforded to staff and the Board through this process.  Personally, I would like to comment that if I planned my school finances on an annual basis, my children would never make it to or through college!

In recent years, I have seen state funds for gifted education threatened when proposals were made to include them in block grants to districts.  I believe the elimination of "redundant" language in the funding regulations would have a similar effect in that the information would be difficult for parents and taxpayers to find and promote.  I ask for the reinstatement of the gifted funding section which states that funding administered by the DOE for the education of gifted students be used only to support those activities identified in the school division's plan as approved by the Board of Education.

My thanks to the Board for this opportunity to comment.

I am writing to request that you do not pass the proposed changes to gifted regulations in the state of Virginia.  Gifted services are already given short shrift due to the massive spending needs of NCLB.  The assumption is that gifted children will somehow succeed without special support.  Those of us who have worked with and parented gifted children know that this is far from the truth.  Gifted children have quite extraordinary special needs.  Without having their needs met, they turn into unmotivated under-achievers who all too often drop out of school!  As a nation and as a state, we should be doing everything in our power to ensure that gifted programming, with its focus on critical thinking and authentic learning (as opposed to the fill-in-the-bubble tests that characterize NCLB), receives our support and that its methodology be inclusive of every ethnic group.  There is simply too much pressure at the local level, without the oversight of state regulations, to divert scarce funding to meeting the needs of NCLB.  The risk is that, instead of raising the quality of education for all by meeting the needs and potential of gifted learners, we will reduce every learner to the bottom line minimal expectations of the SOLs.

Specifically I am asking that:

1. Local plans continue to be developed on a 5-year basis.  Developing plans on an annual basis is wasteful of time and does not allow for the effective implementation of plans nor for taking a longer term view in terms of goals.

2. Five-year plans continue to be approved by the state Department of Education to ensure minimal and uniform compliance for the provision of gifted services across the State.  The local school board in my school system is a dedicated and hard-working body, but they are not trained in best practices in gifted education and are therefore unqualified to know whether or not a plan truly meets the needs of the gifted.

3.  The language about gifted funds being used only to provide services identified in the approved 5-year plan should be restored to the regulations.  I am only too aware of the phenomenon of trying to spread too few funds to meet too many (legitimate) needs.  Without this language, gifted funds will undoubtedly be diverted to more politically pressing needs, not through bad intention by the locality, but simply due to the fallacious belief that gifted (and potentially gifted) students will take care of themselves.

Thank you for your consideration of my comments.  Please be an advocate for the future of this nation.  Please advocate for effective education of our future!

Anne Geraty, Gifted teacher, parent, and citizen

Cc: Dr. Mark Emblidge; Dr. Billy Cannaday; Dr. Donna Poland

I'm principal of an elementary school in Bedford County with a large population of gifted students and even larger population of "want-to-bes".  We need standards for identification that are regulated and monitored often.  Funding is also an important part of a successful gifted program.

Please continue to require districts to develop goals for gifted students through a 5 year plan.

Thank You!

Two parts of the proposed regulations must be changed in order to support the needs of gifted learners in VIrginia. I am concerned with the following changes:

(1) 8VAC20-40-60: Without DOE approval, there is no central authority to confirm that local plans are in compliance with regulations. Elected school board members are not experts in the field of gifted education and can not provide feedback for gifted program plans.

(2) 8VAC20-40-70: Repealing regulatory language protecting funds for gifted services could lead to these funds being used for other purposes. Staute fund administered for the education of gifted students should only be used to support the activities identified in each school division's plan.

I strongly urge the review and revision of these two particular parts of the regulations!

Please do not make the proposed changes to the gifted program.  We need to make positives steps forward, not backwards, in educating our students.

Do not adopt these proposed regulations.

The propsed revisions are unsatisfactory.  In particular:

(1) Regarding  8VAC20-40-60, each local school division should be required to submit to the Department of Education for approval a plan, developed on a five-year basis, for the education of gifted students to ensure that the regulations are being followed.  School board members are not necessarily experts in gifted education.

(2) Regarding 8VAC20-40-70, state funds administered by the Department of Education for the education of gifted students should be restricted to be used only to support those activities identified in the school division's plan as approved by the Board of Education.  Otherwise, funding intended for gifted services may be diverted and degrade the qualty of gifted programming at our schools.

I am so tired of loca, state, and or federal agencies taking money from forums that is wasoriginally scheduled to be used.  The US education system has already fallen behind that of other countries to such a degree that we can not afford to have the truly gifted children limited in their education to that equivelentof the masses.  We need to show excellence once again in our education.

.Do NOT make these changes!

Please consider the ramifications related to this decision as Gifted/Talented students will suffer the consequences related to annual planning and budgetary cuts from localities that continuously grapple with financial hardships.   Moreover, the lack of regulatory oversight will lead to the inconsistent practices as well as varied provision of services regarding this population of students.  In addition, demographic challenges combined with School Board agendas will significantly stagnate current/future services and resources allocated for these programs.  In short, impact our children with positive and well devised plans of action and the Commonwealth will be the beneficiary of our efforts.   These are our leaders of tomorrow; thus, let us make better decisions - today!

Please do not accept the proposed changes to the gifted program.  As a parent of a bright student, I feel strongly that our schools program challenges her and keeps her engaged in learning.  The proposed changes will negatively affect the program. 

I strongly believe there must be consistent standards for identification of gifted students in Virginia schools.  Adopting new plans each year is not a sound educational practice.  Funding of the gifted program is vital and shows a strong commitment to the students participating in the program.  We should be moving forward to provide all students with the best possible education, not backward!

Under no circumstances should the "Proposed Revision of Gifted Program Regulations" be made.  Placing this control at the local level is detrimental to gifted students state-wide.  Local school board members DO NOT have the expertise in understanding the needs of gifted students.  School Boards are faced with a myriad of decisions in a very limited amount of time.  They do not have the time, in addition to addressing the other needs of the local schools, to provide constructive and productive feedback for gifted program plans.  Secondly, decisions made at the local level can become political in nature and often, very time consuming potentially damaging the educational needs of the gifted students.

On a state-wide level, there can be single authority with oversight and control along with the needed expertise to consistently address the needs of Virginia’s gifted students. 

The state funding for gifted needs should be used to support only those activities identified in the school division's gifted plan (as approved by the Board of Education).  The repeal of this will allow these funds to be used for any other purpose.  Gifted Education is already under funded as evidenced by the lack of gifted resource instructors in our county.  Please do not allow the underlined wording above to be repealed.  This will set back the quality of our Gifted Education program just as we are starting to see small improvements (new advanced class offerings at the Middle and High School levels).

Please vote NO to these proposed revisions! 

Adopting these regulations would have a negative effect on our gifted students.

As an educator and parent of children who have participated in gifted education, I oppose the changes being considered to Gifted Education.  I have three primary concerns:

1.  Requiring an annual report will not benefit schools, parents, or students.  There should be a 5-year planning process to allow schools to develop and refine their educational programs for gifted children.  This would promote excellence and consistency within districts and the state.

2.  Reports should be submitted to the VA DOE for review.  This will help insure that ALL gifted programs meet certain standards and are held accountable for improvements.

3.  Funding needs to be reinstated for gifted programs and used ONLY for gifted education. 

Thank you.

I am in agreement with many over having a 5 year plan, along with reinstating the DOE's funding for the local gifted programs.  Our county has already lost money from the state because of our Composite Index. We have about 70% of our student body on free and reduced lunches.  I know what will happen to our gifted program if money is not specifically allocated towards those children. Our gifted children are deserving of a challenging education that will continue to help prepare them to be our leaders tomorrow. They will not have problems passing SOL standards, but they need to have opportunities to "think outside the box", to rise to challenges above and beyond SOLs, to extend and explore content and areas that enhance their leadership abilities, and to receive a public education that suits their needs like we do for the rest of our student population.

T

As the mother of two gifted students and a teacher,  I do not want to see the proposals enacted.  Both proposals have the potential to significantly weaken the education of the gifted.  Giving local school boards sole jurisdiction over the Local Plan is not the best course of action because most members of most school boards have no training in educating gifted students therefore they will not have the experience nor the expertise to adequately critique the plan and offer constructive suggestions.  In addition to these concerns, enacting the second proposal which will take away the language that funds gifted education will enable local school boards to shift funds from gifted students to any other group that they feel needs the money.  Already No Child Left Behind and making AYP, dictate too much of how funds are allocated and what curriculum is taught.  In our efforts to meet the dictates of the government, we are leaving behind another group of students.  Without funding, programs for the gifted could be eradicated and we are already not doing enough for these students.  We must oppose these proposals.

Please do not adopt the new regulations on gifted education! We need to move forward and not backward. The school board should not be allowed to approve the gifted education plans because they are not experts in the gifted field and, therefore, do not know what the program needs in order to provide for the children.  The DOE needs to regulate the gifted program to make sure that they are receiving appropriate and equal education throughout the commonwealth. Teachers and others who are experts in education should be the only ones allowed to change the gifted education plan. Annual approval will not allow for time to know and understand the program before changes are made. It also provides for inconsistent services. A 5-year plan allows for consistency and time to contemplate necessary changes. Also, funds should be provided for the gifted education program, not to be used any other way. We need to provide quality services for children in the gifted education program, not make it harder for them by allowing their funds to be used elsewhere and have people on the school board who know nothing about education make the decisions. 

8VAC20-40-10. Applicability

Paragraph 1
•    Change  …services for students from kindergarten through high school graduation to: …services for students from kindergarten through twelfth grade

 8VAC20-40-20. Definitions

Paragraph 2
•    Change  …accelerated learning aptitudes of eligible or identified students to: …accelerated learning aptitudes of identified students

Paragraph 4
•    Change  …beginning with kindergarten through graduation to: …beginning with kindergarten through twelfth grade

Paragraph 4, Number 2: Specific Academic Aptitudes
•    Change  …selected academic areas that include English, history and social science, mathematics, and science: to  …selected academic areas as defined by one or more of the following: English/ language arts, mathematics, history/social science, or science.

Paragraph 4, Number 3: Career and Technical Aptitude
•    Change  …advanced use of language to: …advanced use of technical language

“Identification” Paragraph
•    Change  …finding students who are eligible for the division’s gifted education program: to  …finding students who are eligible for service options offered through the division’s gifted education program.

•    Change  …identification and placement committee to: …identification and placement committee(s)

“Referral” Paragraph
•     Change  …parents, teachers, professionals, or students to: …parents/guardians, teachers, professionals, students, peers, self, or others

 “Screening” Paragraph
•     Change to: Screening is the annual process of creating a pool for potential candidates K-12 using multiple criteria through the referral process, review of current assessment data, or information from other sources. Screening is the active search for students who are then referred for the formal identification process.

“Service options” Paragraph
•     Change …the delivery of appropriate programs provided to eligible students to: …the delivery of appropriate service or services provided to eligible students

8VAC20-40-40. Screening, referral, identification, and placement.

Paragraph A
•    Change …procedures for identification and service in, at a minimum, English, history and social science, mathematics, and science to: …procedures for identification and service in one or more of the following: English/ language arts, mathematics, history/social science, or science.

•     Change …visual and performing arts aptitude to: …visual or performing arts aptitude

Paragraph C
•     Change …referrals from school personnel, parents or legal guardians, or other persons of related expertise, as well as peer or self referral to: …referrals from parents/guardians, teachers, professionals, students, peers, self, or others

Paragraph D, Number 2
•    Change …the school division’s gifted education program to: …the school division’s gifted education services

•     Change …shall be offered programs or courses to: …shall be offered service options

Paragraph D, Number 3, Item e
•    Change … norm-referenced aptitude tests to: …nationally norm-referenced aptitude and/or achievement tests

Paragraph D, Number 4
•    Change …designed to address general intellectual aptitude or specific academic aptitude to: … designed to address general intellectual aptitude
•    Change …norm-referenced aptitude test to: …nationally norm-referenced aptitude test

Paragraph D, Number 5
Change wording to say: If a program is designed to address specific academic aptitude, an individually administered or group?administered, nationally norm?referenced aptitude or achievement test shall be included as one of the three measures used in the school division*s identification procedure.

Paragraph D, Add a new Number 6 (from the old paragraph 5):
If a program is designed to address either the visual or performing arts or career and technical aptitude, a portfolio or other performance assessment measure in the specific aptitude area shall be included as part of the data reviewed by the identification and placement committee.

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

•    Change …offered placement in a classroom or program setting to: … offered placement in an instructional setting

8VAC20-40-55. Parental rights for notification, consent, and appeal.

Paragraph B
•    Change …within ten business days to: …within ten instructional days

Paragraph B, Number 1
•    Change …in writing within ten business days to: …in writing within ten instructional days

8VAC20-40-60. Local plan, local advisory committee, and annual report.

Paragraph A
•    Remove: …review and approve annually a comprehensive plan…
•     Reinstate: Each school division shall submit to the Department of Education for approval a plan for the education of gifted students…

•    Make it a five-year local plan as is currently required.

Paragraph A, Number 2
•     Change …personnel preparation to: … professional development

Paragraph A, Number 3
•    Change …visual and performing arts aptitude to: …visual or performing arts aptitude

Paragraph A, Number 10
•    Change … student’s intellectual and academic growth to: … student’s academic growth

Paragraph A, Number 11
•    Change … school division’s program of differentiated curriculum and instruction demonstrating accelerated and advanced content within programs or courses to: …school division’s differentiated curriculum and instruction demonstrating accelerated and advanced content

Paragraph A, Number 14
•    Change…annual evaluation to: annual review

•    Remove/delete: …including review of student outcomes and the intellectual and academic growth of gifted students.

•    Change…Such evaluation shall be based on multiple criteria and shall include multiple sources of information for gifted students to: …Such review shall be based on multiple criteria and shall include multiple sources of information.

8VAC20-40-70. Funding.

Paragraph 1
•    Reinstate the following statement:  “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.”

While creating 5-year gifted plans can sometimes feel cumbersome, submitting plans on a yearly basis would be an unnecessary bureaucratic workload.  Local gifted plans should be developed on more than a yearly basis (every 5 years or no less than every 3 years) in order to set long-term goals, to evaluate and implement changes, and for general evaluation of gifted programming.

Gifted plans should be submitted to the VA Dept.of Ed. for approval to be sure that schools comply with the minimum identification and programming requirements. Peer review is a necessary accountability measure – leaving the local school boards to review the plans takes away a professional level of evaluation since many (if not most) school board members don’t have professional experience with gifted programming.  While many accountability measures (SOL testing) frustrate teachers, state oversight of gifted plans is a protection for programming at the local level.

The Quest Advisory Committee for the Charlottesville City Schools recommends the following changes to the proposed revisions.

8VAC20-40-20. Definitions

Paragraph 4, Number 2: Specific Academic Aptitudes

•    Change  …selected academic areas that include English, history and social science, mathematics, and science: to  …selected academic areas as defined by one or more of the following: English/ language arts, mathematics, history/social science, or science.

Paragraph 4, Number 3: Career and Technical Aptitude

•    Change  …advanced use of language to: …advanced use of technical language

Identification” Paragraph

•    Change  …finding students who are eligible for the division’s gifted education program: to  …finding students who are eligible for service options offered through the division’s gifted education program.

•    Change  …identification and placement committee to: …identification and placement committee(s)

“Referral” Paragraph

•     Change  …parents, teachers, professionals, or students to: …parents/guardians, teachers, professionals, students, peers, self, or others

“Screening” Paragraph

•     Change to: Screening is the annual process of creating a pool for potential candidates K-12 using multiple criteria through the referral process, review of current assessment data, and information from other sources. Screening is the active search for students who are then referred for the formal identification process.

“Service options” Paragraph

•     Change …the delivery of appropriate programs provided to eligible students to: …the delivery of appropriate service or services provided to eligible students

8VAC20-40-40. Screening, referral, identification, and placement.

Paragraph A

•    Change …procedures for identification and service in, at a minimum, English, history and social science, mathematics, and science to: …procedures for identification and service in one or more of the following: English/ language arts, mathematics, history/social science, or science.

•     Change …visual and performing arts aptitude to: …visual or performing arts aptitude

Paragraph C

•     Change …referrals from school personnel, parents or legal guardians, or other persons of related expertise, as well as peer or self referral to: …referrals from parents/guardians, teachers, professionals, students, peers, self, or others

Paragraph D, Number 2

•    Change …the school division’s gifted education program to: …the school division’s gifted education services

•     Change …shall be offered programs or courses to: …shall be offered service options

Paragraph 4

•    Change …designed to address general intellectual aptitude or specific academic aptitude to: … designed to address general intellectual aptitude

•    Change …norm-referenced aptitude test to: …nationally norm-referenced aptitude test

Paragraph D, Number 5

Change to: If a program is designed to address specific academic aptitude, an individually administered or group?administered, nationally norm?referenced aptitude or achievement test shall be included as one of the three measures used in the school division’s identification procedure.

Paragraph D, Add a new Number 6 (from the old paragraph 5):

If a program is designed to address either the visual or performing arts or career and technical aptitude, a portfolio or other performance assessment measure in the specific aptitude area shall be included as part of the data reviewed by the identification and placement committee. (From the old paragraph 5)

Paragraph E

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

•    Change …offered placement in a classroom or program setting to: … offered placement in an instructional setting

8VAC20-40-55. Parental rights for notification, consent, and appeal.

Paragraph B

•    Change …within 10 business days to: …within 10 instructional days

Paragraph B, Number 1

•    Change …in writing within 10 business days to: …in writing within 10 instructional days

8VAC20-40-60. Local plan, local advisory committee, and annual report.

Paragraph A

•    Remove: …review and approve annually a comprehensive plan…

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

•    Make it a five-year local plan as is currently required.

Paragraph A, Number 3

•    Change …visual and performing arts aptitude to: …visual or performing arts aptitude

Paragraph A, Number 10

•    Change …gifted student’s intellectual and academic growth to: …gifted student’s academic growth

Paragraph A, Number 11

•    Change … school division’s program of differentiated curriculum and instruction demonstrating accelerated and advanced content within programs or courses to: …school division’s differentiated curriculum and instruction demonstrating accelerated and advanced content

Paragraph A, Number 14

•    Change…annual evaluation to: annual review

•    Remove/delete: …including review of student outcomes and the intellectual and academic growth of gifted students.

•    Change…Such evaluation shall be based on multiple criteria and shall include multiple sources of information for gifted students to: …Such review shall be based on multiple criteria and shall include multiple sources of information,

8VAC20-40-70. Funding.

Paragraph 1

•    Reinstate the following statement:  “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.”

I am concerned about the changes you are considering regarding gifted education in Virginia. As a parent of a gifted child I would ask that you:

1) Require local school division to develop 5 year gifted plans that require peer review. This enables school divisions to have the opportunity to develop long-term goals, implement changes, and evalust before updating the plan the following year. Without peer review, there is no way for gifted educators to know how they "stack up" against other localities and it doesn't provide the opportunity for constructive criticism and feedback. Requiring localities to submit plans on an annual basis to their local school board is unwise because school board members may not fully understand the educational and socio-emotional needs of gifted students. This would allow the school board which relies on the vote of consituents to make decisions that may require funding for a select few instead of all students. Submitted to the DOE for approval creaes an accountability system for school divisions and give parents and educators the opportunity to guarantee that localities are meeting the standards determined by the DOE. 

2) Reinstate the gifted funding section which states that funding administered by the DOE for the education of gifted students be used only to support those activites identified in the school division's plan for gifted students as approved by the Board of Education.  

Countless studies have shown that the performance of American students compared to the accomplishments of students in other countries, continues to decline. Our students cannot compete with those of other nations, especially in math and science.  We are wasting a national resource and even endangering the survival of our country by failing to nourish the education of our brightest students. 

Gifted students are in every sense of the word, special needs students.  Failing to motivate and teach them at their level often results in students who are "turned off" by schools and who often drop out of school and society.  Using them as mentors, as if often done in classrooms, is unfair to them and our country.

We should be increasing funding for gifted education and making it mandatory for all school districts.

The only quality control and outside review of a division plan is through the approval process by the DOE. Without DOE approval, no central authority will be responsible to confirm that the plan is in compliance with regulations.

 Educators and community stakeholders invest significant time and effort to  create a 5-year plan for gifted education and in the process seek peer review from other gifted education colleagues. To shift this process to the local level will eliminate the productive insights that emerge from this peer review. 

Please do not adopt these regulations.  As a parent of a gifted child, I personally feel that adopting these regulations will offer more harm than good.  PLEASE consider the voices of everyone that has posted a comment.