The Virginia State Board of Education states in the “Annual Report on the Condition and Needs of Public Schools in Virginia,” its second objective is to eliminate the achievement gap.  The failure to prioritize the underrepresentation of low-income and minority students in gifted programs will undermine efforts to reduce the achievement gap between both low-income and minority “high-achieving” students and their more affluent and majority “high-achieving” peers.  Policymakers must utilize gifted programs to provide a pool of low-income and minority students who are both qualified and prepared to matriculate to Virginia’s elite and selective institutions of higher learning.  Diversity at Virginia’s elite and select universities is best achieved by educating and preparing low-income and minority students equitably in Virginia’s public schools so that their SAT scores, grade point averages, and rigor of coursework on evaluation are as meritorious as more wealthy and majority applicants.  It is in the state and national interest to prepare low-income and minority students to meet the business community’s demand for high skilled workers and lessen the need to recruit high skilled workers from abroad through the H2 visa program.  Virginia’s problem is not that there are too many students in its gifted education programs but that there are too few low-income and minority students.

This is the first governmental blog I've ever come across that actually ask you to leave a comment. I think this is unique and a great thing. I live in Texas and I wish we had a state blog resource on DUI Laws and DUI Penalties to help get the word out about how bad of a problem it is in our state.

Lecturing on her work, The History of Whiteness, Nell Painter states that “the black poor remain outside the concept of ‘the American’”.  Professor Painter would likely agree that the black poor remain outside the concept of ‘the gifted’.  She lectures further that, “poverty and a dark skin endure as the opposite of whiteness driven by an age old social yearning to characterize the poor as permanently other and inherently inferior”.  The Henrico NAACP says not anymore.  Minority is not alien and poor is not degenerate.  The black, brown, and poor are Us, American, and inherently gifted.  If Virginia’s public schools are to have places for the gifted affluent, there will be places for the gifted minority and the gifted poor, right now and this today.  The mistake of “with all deliberate speed” will not be repeated in providing necessary educational services to gifted minority and low-income students.
In Henrico Public Schools, black students are 36% of the total student enrollment but only 7% of the students identified as gifted.  White students are 48% of the total student enrollment and 80% of the students identified as gifted. 
 
To deconstruct this conception of giftedness which under identifies minority and low-income students in need of gifted education services, the Henrico NAACP advocates that the gifted education regulations be further revised to include: 
 
The Virginia Department of Education (VADOE) and local school divisions must have policies and procedures designed to prevent inappropriate under identification and disproportionate representation by race, ethnicity, and poverty status of children in gifted education and governor’s school programs.
 
Disproportionate representation.
 
-The VADOE must monitor school divisions in the priority areas:  disproportionate representation of racial, ethnic, and low-income students in gifted education, and governor’s school programs to the extent the representation is the result of inappropriate identification.
 
-The VADOE must identify school divisions with disproportionate representation, and of those, the number where the disproportionate representation is the result of inappropriate identification of children by race, ethnicity, and poverty status. 
 
-Identifying inappropriate identification could include a review of policies, procedures, and practices related to identification of gifted minority and low-income children.
 
-If disproportionality is due to inappropriate identification, require the school division to correct the noncompliance, including revising deficient policies, procedures, and practices.
 
-The VADOE must report annually to the Governor and Legislature as follows:  (#due to inappropriate identification)/(all school divisions) and in the following annual report on correction.
 
Significant disproportionality.
 
-The VADOE and school divisions must collect and examine data to determine if significant disproportionality based on race, ethnicity, and poverty status is occurring in the State and school divisions with respect to identification of children for gifted education and governor’s school programs.
 
-In school divisions where significant disproportionality exists, school divisions are required to reserve 15% of gifted funds to address the disparity.
 
-In school divisions where significant disproportionality exists, school divisions will review policies, procedures, and practices related to identification of minority and low-income gifted students.
 
-If policies, procedures, or practices are deficient in school divisions where significant disproportionality exists, the VADOE will require the school division to revise to comply with the requirements.
 
-In school divisions where significant disproportionality exists, the VADOE will require the school division to publicly report on the revisions of policies, procedures, and practices.

To deconstruct this conception of giftedness which under identifies minority and low-income students in need of gifted education services, the Henrico NAACP advocates that the gifted education regulations be further revised to include: 
 
The Virginia Department of Education (VADOE) and local school divisions must have policies and procedures designed to prevent inappropriate under identification and disproportionate representation by race, ethnicity, and poverty status of children in gifted education and governor’s school programs.
 
Disproportionate representation.
 
-The VADOE must monitor school divisions in the priority areas:  disproportionate representation of racial, ethnic, and low-income students in gifted education, and governor’s school programs to the extent the representation is the result of inappropriate identification.
 
-The VADOE must identify school divisions with disproportionate representation, and of those, the number where the disproportionate representation is the result of inappropriate identification of children by race, ethnicity, and poverty status. 
 
-Identifying inappropriate identification could include a review of policies, procedures, and practices related to identification of gifted minority and low-income children.
 
-If disproportionality is due to inappropriate identification, require the school division to correct the noncompliance, including revising deficient policies, procedures, and practices.
 
-The VADOE must report annually to the Governor and Legislature as follows:  (#due to inappropriate identification)/(all school divisions) and in the following annual report on correction.
 
Significant disproportionality.
 
-The VADOE and school divisions must collect and examine data to determine if significant disproportionality based on race, ethnicity, and poverty status is occurring in the State and school divisions with respect to identification of children for gifted education and governor’s school programs.
 
-In school divisions where significant disproportionality exists, school divisions are required to reserve 15% of gifted funds to address the disparity.
 
-In school divisions where significant disproportionality exists, school divisions will review policies, procedures, and practices related to identification of minority and low-income gifted students.
 
-If policies, procedures, or practices are deficient in school divisions where significant disproportionality exists, the VADOE will require the school division to revise to comply with the requirements.
 
-In school divisions where significant disproportionality exists, the VADOE will require the school division to publicly report on the revisions of policies, procedures, and practices.

The regulations as proposed fail to address the disproportionate representation of Culturally & Linguistically Diverse gifted students in Virginia's gifted programs. in the past, many Virginia localities have worked  to better serve all of its population including gifted learners who may come from low socio-economic backgrounds and those who originate from culturally and linguistically diverse ethnic groups. However, numerous disproportionalities continue to exist...many African American and Hispanic Students who have high potential are not being served by gifted programs across the state. To revise these regulations without attention to the needs of all students is inappropriate. The new regulations will not encourage the use of multiple criteria which is a notable  'best practice' , they may well discourage divisions from using this research-based practice which allows multiple identification tools to be used to assess  students' gifted potential. All students in Virginia deserve fair and equitable access to state & locally funded gifted services. We appeal to you to review and revise the regulations to ensure that a minimum of 4 identification criteria are used (one of which should be a nontraditional, non-biased assessment tool) and that all districts will be required to serve culturally and linguistically gifted students that are represented among their general population. Further, we recommend that reporting procedures be implemented to ensure that all divisions continue to annually report demographic data and specify procedures utilized to ensure equitable access to local, regional & state gifted services.

Like many others I ask that the Regulations Governing Educational Services for Gifted Students in Virginia be reviewed/revised to address the disproportionate representation of low income and minority students. The demographic  composition of children in the gifted  programs in school divisions across the state should reflect that of the population. We must close achievement gaps among ethnic/racial groups. Revisions to the Regulations must have as a goal the opportunity to address and close those acheivement gaps. I support the movement to revise the Virginia Reguations Governing Educational Services for Gifted Students.  Marcus Martin MD 

In Richmond City Schools:  African American students are 88% of the student enrollment but only 60% of students receiving gifted education services.  Caucasian students are 7% of the student enrollment, yet 36% of students receiving gifted education services.

We echo the words of Thomas Jefferson: "By …[selecting] the youths of genius from among the classes of the poor, we hope to avail the State of those talents which nature has sown as liberally among the poor as the rich, but which perish without use if not sought for and cultivated. "

-Recommend:  Change 8 VAC 20-40-40 Screening, referral, identification, and service.  School divisions should not be required to establish uniform procedures for screening, referring, identifying, and serving students.

-Recommend:  In school districts where the student population is very homogeneous, districts may find that criteria used for identifying gifted/talented students on one campus works for all campuses in the district.

-For example, if each campus in the district has similar socioeconomic and racial/ethnic demographics, the same criteria may be used throughout the district.

-Recommend:  However, in districts in which the demographics are more diverse, a single set of criteria used on all campuses will tend to identify gifted/talented students on one campus to the exclusion of potentially eligible students on another campus.

I am greatly concerned about  the underrepresentation of minority students in gifted education.  I am a black student who attended Virginia public schools most of my life.   Although I excelled in school I was never recommended for the gifted and talented program, nor were my black friends.  

I graduated from Brooke Point High School in Stafford, Virginia. In Stafford Public Schools:  African American students are 21% of the student enrollment but only 7% of students receiving gifted education services.  Caucasian students are 64% of the student enrollment, yet 83% of students receiving gifted education services.

I believe the regulations governing gifted and talented education should provide better guidance to school divisions on the criteria, standards, or requirements for the administration and regulation of gifted programs in school divisions which have established different levels of gifted services.  I also believe the Board of Education should address the underrepresentation of minority students in gifted and talented programs.  

Proper education is paralleled with prosperity. Black students are under represented in gifted and talented programs and deserve equal opportunity. I am a proud member of the Howard University community and many of my peers are products of gifted and talented programs in their primary and or secondary education. I appose lowering the standard for these programs but I strongly suggest the consideration of more minorities in these programs. These students are no way less adequate then the rest of their peers and deserve an equal opportunity. The program should reflect the demographics of the school district, e.g. if 25% of the school population is African America, the gifted and talented programs should theoretically be 25% African American. 

As a student who benefited from the gifted programs in the Henrico County School System, I strongly urge  our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations. In Henrico Public Schools:  African American students are 36% of the student enrollment but only 7% of students receiving gifted education services.  Caucasian students are 48% of the student enrollment, yet 80% of students receiving gifted education services.  This is simply unacceptable.  I do not believe that race lowers a child's ability or right to benefit from an accelerated curriculum.  What I do believe is that the opportunities available to students vary, and that all students may not receive the proper support in purusing opportunities such as governor's school.  Consequently, I recommend the gifted education regulations be amended to provide the rules governing the administration of governor’s school programs which are a component of gifted education programs in Virginia.

I strongly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia.  Minority and low-income gifted students will receive needed services so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community.

In Henrico Public Schools:  African American students are 36% of the student enrollment but only 7% of students receiving gifted education services.  Caucasian students are 48% of the student enrollment, yet 80% of students receiving gifted education services.

-Recommend the gifted education regulations be amended to provide the rules governing the administration of governor’s school programs which are a component of gifted education programs in Virginia.

-Recommend the regulations provide that school divisions may include as part of their gifted plan, permitting geographic representation as part of providing gifted services to prevent the exclusion and penalization of gifted students from under-performing and economically disadvantaged schools from being excluded from gifted programs, pull-out or center-based gifted programs, and governor’s schools.

-Inter-district geographic representation is used presently to provide for the equitable distribution of governor’s school seats among school divisions in the various governor school jurisdictions.  Each locality receives a quota or specified number of seats in the governor’s school programs.

-Recommend intra-district geographic representation be required as a component of an equitable gifted and governor’s school program.

I support amending gifted education program regulations in order to effectively address underrepresentation of minority and low income students in Virginia schools.

As a college advisor, I recognize both the immense talents and weaknesses in my students. Many of them were not fortunate enough to be able to enter in or become knowledgeable about specialty academic programs that would enable them to be on par with their more affluent peers. 

Underrepresentation of minorities and low income students in gifted education contributes to the already dire achievement gap between high and low resource communities. Every child who has talent, interest, and a will to advance him or herself academically should at least have access to opportunities that would aid in such an endeavor. 

Within low income communities, access to specialty educational programs can literally mean the difference between life and death.

I strongly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia.  Minority and low-income gifted students will receive needed services so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community.

In Chesterfield Public Schools:  African American students are 27% of the student enrollment but only 10% of students receiving gifted education services.  Caucasian students are 61% of the student enrollment, yet 82% of students receiving gifted education services.

To the member of this committee I beleve the following :

• School divisions in Virginia  population  for the gifted program should refect that community .
• That data should also show the representation of low -income and minority students in the gifted education  programs .
• Resolve resource inequities  and make sure there are quality teachers along with instructional  support.

 Do not approve of this regulation in its current form .

Type oI belever this text and enter your comments here. You are limited to approximately 3000 words.

I strongly urge our elected officials to implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia. Student of color and low-income students who are gifted will receive needed services so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community.

I strongly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia.  Minority and low-income gifted students will receive needed services so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community.

I strongly urge state officials to accept and implement the NAACP recommended amendments to the gifted education regulations, which will result in equitable and truly representative gifted programs throughout Virginia. Ethnic minority and low-income gifted students will receive the services they need AND have a right to access.

In Chesterfield public schools: African American students are 27% of the student enrollment, but are only 10% of the students receiving gifted education services. European American (Caucasian)students are 61% of the student enrollment, but are 82% of students receiving gifted education services.

Students eligible for free or reduced-price lunch are 25% of the student enrollment, but are less than 3% of the students placed in the center-based gifted education program.

I urge state officials to: 1) reject 8 VAC 20-40-40 subparagraph D3 and replace it with specific language that establishes how to weight the criteria  used to identify students to be placed in gifted programs; 2) require school divisions to use criteria and a process that is evidence-based and has been validated through rigorous scientific methods to identify students who need and are placed in gifted education services.

The changes in the regulations cited above are needed to address and correct the lack of access to gifted education by low-income and ethnic minority students. The changes will allow these students to reach their full potential and become productive, contributing citizens of Virginia.

I strongly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.

In Chesterfield Public Schools, African American students are 27% of the student enrollment but only 10% of students receiving gifted education services.  Caucasian students are 61% of the student enrollment, yet 82% of students receiving gifted education services.

Of the 57 Chesterfield County students selected for admission to Maggie Walker Governor’s School for the 2009-10 school year, 1 student was African American and 1 student was Hispanic.

Chesterfield County Public Schools uses a single criterion – 97^th percentile or higher on the CoGAT – for a student to be considered for center-based gifted education programs.  Students scoring in the 96^th  percentile or below are considered for home school gifted services which consists of differentiated instruction in the classroom (at best). 

Recommend subparagraph D3 be rejected and replaced with specific language that establishes how to weight the criteria relied upon for gifted identification.  The weight given any criteria should be research-based and validated.

Recommend subparagraph D3 be rejected and replaced with specific language requiring school divisions which rely upon a cut off score, in this case 97^th percentile, and used to determine the level of gifted services, to establish the validity of using that criteria as a determinant in providing the level of gifted services.

REJECTING repealing 8 VAC 20-40-50Criteria for screening and

identification. Reducing the requirement of FOUR or more criteria is not research-based and

conflicts with the recommendation of African American gifted expert Dr. Joy Davis. Dr. Davis

recommends against reducing the number of criteria to three. Reducing the criteria to three will

result in greater emphasis placed on standardized ability and achievement tests which historically

disadvantage low-income gifted students and gifted students educated in low-performing

schools.

Educationally yours,

Gifted minority students in Prince William Schools

In Prince William Public Schools: African American students are 22% of the student enrollment

but only 12% of students receiving gifted education services. Caucasian students are 41% of the

student enrollment, yet 64% of students receiving gifted education services.

-Recommend

REJECTING repealing 8 VAC 20-40-50Criteria for screening and

identification. Reducing the requirement of FOUR or more criteria is not research-based and

conflicts with the recommendation of African American gifted expert Dr. Joy Davis. Dr. Davis

recommends against reducing the number of criteria to three. Reducing the criteria to three will

result in greater emphasis placed on standardized ability and achievement tests which historically

disadvantage low-income gifted students and gifted students educated in low-performing

schools.

Educationally yours,

Gifted minority students in Prince William Schools

In Prince William Public Schools: African American students are 22% of the student enrollment

but only 12% of students receiving gifted education services. Caucasian students are 41% of the

student enrollment, yet 64% of students receiving gifted education services.

-Recommend

In Henrico Public Schools:  African American students are 36% of the student enrollment but only 7% of students receiving gifted education services.  Caucasian students are 48% of the student enrollment, yet 80% of students receiving gifted education services.

.

As a product of the Fairfax, Virginia public school system, and a participant in the Gifted and Talented program at my school, I know the value of that education, and of having the additional academic support to ensure that I continued to strive toward my greatest potential. My personal experience was of being the only black child in my GT section while knowing that I was not the only black child capable of doing the work and thriving. 

The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia.  Minority and low-income gifted students will receive needed services so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community.

As a product of Fairfax County Public Schools and as an African American, this issue has been a source of frustration for me.  It became apparent to me at an early age that there was a huge racial and socioeconomic discrepancy in the gifted program and the regular program at my elementary school.  I believed that there were many other students who were very capable but were not given the chance to exceed early on in their education, including me. 

The gifted program at the elementary level fed into the honors classes in middle school, where it was clear that kids in the honors program had more resources (i.e. SAT vocabulary books) in addition to a more rigorous curriculum. Regular classes were hardly challenging and the environment in regular classes made it is extremely difficult to grow academically as a result of not being challenged enough.  By high school, students were allowed to choose their own classes (regular, honors, AP), but after being stuck on a certain track for so long and not encouraged to challenge themselves, the majority of students in the regular program chose to stick with the regular courses.

I believe that this system reinforces the achievement gap between both low-income and minority “high-achieving” students and their more affluent and majority “high-achieving” peers.  The failure to prioritize the underrepresentation of low-income/minority students in gifted programs will certainly undermine efforts to reduce the achievement gap.  All students in Virginia deserve fair and equitable access to state and locally funded gifted services.  Without a strong foundation, these students will not reach their full potential which is totally unacceptable.

I strongly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia.  Minority and low-income gifted students will receive needed services so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community.

In Fairfax Public Schools:  African American students are 11% of the student enrollment but only 7% of students receiving gifted education services.  Caucasian students are 48% of the student enrollment, yet 57% of students receiving gifted education services.

 Fairfax reports erroneous data to the VADOE on its gifted student enrollment.  Fairfax reports its Caucasian student enrollment is 79,427.  Fairfax reports 34,132 Caucasian students as gifted; therefore 57% of Caucasian students in Fairfax are gifted.  This data is false and inaccurate.

 The Regional Education Laboratory Appalachia used its own definition of “students identified as gifted”, relying on the “Student Record Collection”, to generate its report because of the unreliable data collected by VADOE and absence of uniformity in gifted data reporting procedures across school divisions.

 Recommend:  Change 8 VAC 20-40-20 Definitions.  Operationalize the definition of a gifted student to facilitate accurate and uniform demographic data collection of gifted programs between school divisions and the VADOE as required by the Code of Virginia Section 22.1-18.

Recommend:  A provision in the regulation requiring VADOE to implement data collection as required in the Code of Virginia 22.1-1-18, on school division gifted programs, level of gifted services, governor’s school programs, summer regional governor’s school programs, and Math & Science Innovation Center gifted programs.

Require school divisions to report annually in school division gifted plans demographic data on the criteria relied upon for the identification of gifted students for school division gifted programs and governor’s school (for example:  referrals and source, ability test scores, achievement test scores, teacher ratings of gifted students, index scores, cut scores, and grade point averages) (including prerequisite courses for governor’s school). 

The NAACP Legal Defense and Educational Fund, Inc. (LDF) has long been committed to ensuring equal access to a high-quality education for students of all races.  Experience and common sense indicate that outstanding talents are present in children from every racial and ethnic group.  Unfortunately, however, talented African-American and Latino students are disproportionately under-represented and under-served in gifted education throughout Virginia.  In the 2008-09 school year, for instance, the statewide public school enrollment was 26% African-American and 9% Latino whereas the gifted student population was only 12% African-American and 5% Latino.  In virtually every school division, disparities are also pronounced.  For instance, in Chesterfield County during the 2008-09 school year the rates were below even the troubling statewide average: African Americans made up 28% of the student body but less than 10% of the gifted students; Latinos were 7% of the student population, but less than 2% were included in gifted education.

This disproportionality is a major roadblock to ensuring educational excellence and equity and to narrowing well-documented achievement gaps based on race.  Inclusive gifted education programs in grades K-12 are essential to create a pool of students equipped for success at Virginia’s elite colleges and universities, which are pipelines to leadership at the local and national levels. 

We support those amendments proposed by the Virginia Department of Education (VDOE) to the Regulations Governing Educational Services for Gifted Students that may help mitigate the unjustifiably disproportionate under-representation of African-American and Latino students in gifted education programs, including mandating that the screening process occur at least annually, and requiring that assessment materials be evaluated for racial or cultural biases.  But in order to achieve measureable and significant gains, VDOE must adopt more stringent requirements that are directly calculated to correct the existing racial disparities.  We therefore support the campaign spearheaded by the Chesterfield County, Virginia NAACP Branch and other NAACP branches throughout Virginia to address racial disproportionality in access to and participation in gifted programs.  In particular, we offer four specific policy recommendations, each supported by scholarly literature and informed by comparative analysis of gifted education requirements in other states.  Although these steps alone may not solve the problem of disproportionate access entirely, without them Virginia cannot begin to make progress toward a complete solution.

Recommendation 1:   Require school divisions to conduct a holistic review to identify gifted students, using at least four assessment measures, two of which must be qualitative.

Both the current regulations and VDOE’s proposed revisions define giftedness expansively, consistent with recent scholarship that has recognized intelligence as a broad concept that extends beyond language and logic to include a wide range of human abilities.  VDOE’s proposed revisions, however, unjustifiably take a significant step backward from the existing regulations in defining the process that school divisions must use to ensure identification of students who demonstrate diverse gifted attributes. 

The overwhelming consensus among experts in gifted education is that any process for identifying gifted students should include multiple criteria—both quantitative and qualitative—in order to ensure that talented students of all backgrounds benefit from these programs.  But, whereas the current regulations require school divisions to consider at least four measures in their gifted identification processes, the proposed revisions would permit consideration of only three. 

This change is not research-based and conflicts with current best practices.  If VDOE’s proposed revisions were to go into effect, a school division could fully comply by considering only an aptitude test, a student’s GPA, and any “additional valid and reliable measure,” which could also be a quantitative measure.  Moreover, although the regulations prohibit use of any single criterion to deny admission to a gifted program, they do not mandate how much weight should be placed on each criterion.  As a result, school divisions may lawfully rely primarily on standardized tests.  In this way, the proposed revisions undermine the important goals contemplated by VDOE’s gifted education policies.

It bears emphasis that LDF does not contend that VDOE should prohibit any use of properly validated tests in the gifted education identification process.  But scholarly research establishes that standardized tests and other quantitative measures do not fully capture the wide range of intellectual capacities and abilities that are indicators of giftedness, especially among students of color and those from low-income backgrounds. 

Thus, in addition to retaining the existing requirement that school divisions use at least four measures in their gifted identification processes, VDOE should expressly require that at least two of the four criteria be qualitative measures, such as interviews with students, evaluation of a student’s portfolio or previous work, and classroom observation.  Qualitative measures are particularly useful in identifying factors such as motivation, personality, persistence, and concentration that impact greatly on success in gifted education programs as well as creative productivity throughout life. 

Finally, LDF urges VDOE to revise the gifted identification process to encourage school divisions to conduct a holistic, individualized review to determine whether a student is eligible for gifted education.  Research shows that gifted identification processes select students with more diverse forms of talent if conducted according to an individualized method that relies on human judgment rather than a mechanical approach, such as a predetermined matrix, checklist, or rigid point system.  Moreover, individualized review allows for consideration of students’ previous opportunities to learn.  Schools will overlook many gifted students of color if they fail to recognize that many such students have had inadequate opportunities to develop and perform at high academic levels, though they have the capability to do so.

Although no state has a comprehensive approach to addressing disparities in gifted education, certain innovative aspects of other states’ regulations inform our recommendation for a more comprehensive approach in Virginia.  For instance, other states, such as Texas and Maryland, explicitly require that identification be based on both quantitative and qualitative criteria.  And California mandates consideration of two factors that provide a more individualized perspective on students’ gifted potential: (1) “studies of the factors contributing to a pupil’s underachievement and studies of a pupil’s underachievement resulting from handicapping or disadvantaged conditions” and (2) “the economic, linguistic, and cultural characteristics of the pupil’s background.”

Recommendation 2:  Require school divisions to train teachers to identify gifted students from all backgrounds and to promote parent and student engagement in the identification process.

Neither the current regulations nor the proposed revisions mandate any training for regular classroom teachers on identifying giftedness.  This is a significant oversight. Teachers are key gatekeepers in the gifted identification process.  Their referrals of potentially gifted students are an important resource, and teachers provide input to and serve on the identification and placement committees that make eligibility determinations.  Thus, teachers have the potential to be advocates for children from under-represented populations in the nomination, screening, and identification of gifted students.

            Yet it is well-documented that teachers across the country fail to refer African-American and Latino students, even those with high scores on standardized tests, at rates proportionate to their referral of white students.  Too often, teachers retain stereotypes and misperceptions that lower their expectations for African-American and Latino students; as a result, teachers tend to focus on these students’ shortcomings instead of recognizing their diverse talents.  To overcome this referral bias, teachers of all races need training to better recognize the different learning styles and behavior that gifted students may display.  Appropriate training increases the likelihood that teachers will make more reliable, more informed, and therefore more equitable referrals of students from all backgrounds. 

In addition to more rigorous and evidence-based teacher training, LDF urges VDOE to require school divisions to promote early, active, and ongoing parent and student engagement in the gifted identification process.  While both the current regulations and the proposed revisions permit parent, peer, and self referrals, many parents and students, especially in communities of color, have limited information about gifted programs.  Moreover, referral forms can be confusing and cumbersome.  VDOE should require school divisions to conduct outreach, hold workshops, and disseminate information to ensure that families are aware of the diverse characteristics of gifted students, the nature of the division’s gifted educational offerings and their benefits, the stages of the gifted identification process, and how placement decisions are made.   

Recommendation 3:  Require school divisions to collect, disaggregate, and publish detailed school- and division-wide data on gifted programs. 

It is essential for Virginia to adopt uniform and robust data collection and reporting requirements for all school divisions’ gifted programs.  Currently, the VDOE publishes only statewide data on the students referred to, identified for, and participating in gifted education, disaggregated by race and grade-level.  This is entirely inadequate.

More specific data collection at the school- and division-levels is essential to hold school divisions accountable for fair access to gifted programming.  LDF urges that the gifted regulations be further amended to require school divisions to annually collect and report to VDOE demographic data on student referral to, screening and identification for, and participation and retention in gifted education programs.  Data should be disaggregated by race, ethnicity, gender, and socio-economic status, for each school, grade level, and type of service (e.g., school-based gifted services, center-based gifted services, pull-out programs, etc.).  Data collection requirements should provide uniform definitions of service type to facilitate comparison across divisions.  VDOE should be required to make such data publicly accessible through publication on its website, and ensure it is regularly updated and presented in a format that is easy to understand.

Recommendation 4:  In any school division where there is significant disproportionality based on race and ethnicity in the identification or participation of students in gifted programs, the division must adopt an effective strategy for, and dedicate resources to, reducing the disproportionality. 

Neither the current regulations nor the proposed revisions require school divisions to develop strategies to address severe and long-standing disproportionality based on race and ethnicity in the identification and participation of students in gifted programs.  LDF therefore proposes that Virginia’s gifted regulations be further amended to require school divisions to take certain actions if there is a significant under-representation of students of a particular race or ethnicity in gifted programs in the division overall or in a particular school, grade level, or type of service.  First, the division should be required to develop a comprehensive, coordinated, and evidence-based strategy for a substantial reduction in the level of disproportionality.  Second, the division should be required to target an appropriate portion of its gifted education budget to implement this strategy.  Third, the school division should be required to publicly report on its progress in reducing the disproportionality. 

If the disproportionality persists, VDOE should review and require revisions, as appropriate, to the division’s gifted education policies and procedures.  For instance, if African-American and Latino students consistently and disproportionately perform poorly on a selected assessment instrument, VDOE should require rigorous scrutiny of the school division’s rationale for continued use of that instrument.  VDOE should also be required to report annually to the governor on its own efforts and those of school divisions to mitigate any identified disproportionality. 

This approach should not be difficult for either school divisions or VDOE to implement because it draws heavily upon existing federal requirements under the Individuals with Disabilities Education Act (IDEA).  By statute, IDEA mandates that local educational agencies develop similar strategies, and reserve funding, to reduce the over-identification or disproportionate representation by race or ethnicity among students with disabilities.  VDOE could adapt its regulations implementing these IDEA disproportionality requirements as a model for revisions to its gifted regulations. 

Adopting comparable regulatory frameworks for reviewing and redressing disproportionality in both the gifted and special education contexts makes good sense.  Throughout the nation, the same school districts that disproportionately exclude African-American and Latino students from gifted programs for high achievers also typically inappropriately channel these students into special education. 

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We strongly urge VDOE to adopt these further revisions to its regulations in order to address long-standing disparities in access to and participation in gifted education throughout the Commonwealth.  By taking these important steps, Virginia can begin to ensure that each of its classrooms reflects the diversity of its residents and help close the race-based achievement gaps that continue to plague our nation’s schools.

[A full copy of our letter to the Superintendent of Public Instruction, Dr. Patricia I. Wright, including citations to the relevant research is available on our website, at http://www.naacpldf.org/content.aspx?article=1549]

I strongly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia.  Minority and low-income gifted students will receive needed services, so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community.

In Chesterfield Public Schools:  African American students are 27% of the student enrollment but only 10% of students receiving gifted education services.  Caucasian students are 61% of the student enrollment, yet 82% of students receiving gifted education services.

Of the fifty-seven Chesterfield County students selected for admission to Maggie Walker Governor’s School for the 2009-2010 school year, one student was African American and one student was Hispanic.  This is impossible to justify.

Students eligible for free or reduced-price lunch are 25% of the school district enrollment but less than 3% of students placed in the center-based gifted education program.

I recommend rejecting 8 VAC 20-40-40 subparagraph D3, screening, referral, identification, and service.  Subparagraph D.3 provides that the identification process used by each school division must ensure that no single criterion is used to determine a student’s eligibility [for gifted services]. 

Chesterfield County Public Schools uses a single criterion – 97^th percentile or higher on the CoGAT – for a student to be considered for center-based gifted education programs.  Students scoring in the 96^th percentile or below are considered for home school gifted services which consists of differentiated instruction in the classroom (at best). 

I recommend subparagraph D3 be rejected and replaced with specific language that establishes how to weight the criteria relied upon for gifted identification.  The weight given any criteria should be research-based and validated.

I recommend subparagraph D3 be rejected and replaced with specific language requiring school divisions which rely upon a cut off score, in this case 97^th percentile, and used to determine the level of gifted services, to establish the validity of using that criteria as a determinant in providing the level of gifted services.

In school divisions where significant disproportionality exists, school divisions will review policies, procedures, and practices related to identification of minority and low-income gifted students.

I have had the distinct privilege to work in my community as podiatric physician with special interest in geriatric populations as well as serve as an administrator (assistant principal) in the New York City public school system. Regarding the school system, I have had the opportunity to observe with great consistency the disparity in spending and resources when it comes to children of color. Often deprived and stereotyped, our children are seeemingly left to rummage through the dregs of academia; be it access to materials, reasonable class size, or adequate staffing. Our children's needs always seem no more than an after thought, an inconvenience that must be - at best- modestly met. A great number of my children have extraordinary skills and perception. Access to programs that would allow these talents to blossom has never been afforded these scholars. They are instead sheperded into "honors programs" that are neither funded nor honorable.  They hear about their non-minority cohorts receiving all that the promise of a good education (gifted programs) has to offer. They become dispondent and, despite best efforts, often settle for third tier colleges (if college happens at all). I am a proud graduate of Hampton Institute, Class of 1982. Through the grace of my lord and savior Jesus Christ, I have accomplished much in my life. Our young men and women deserve better; they are entitled to better. I would be honored to have my voice added to the many that see the need to make the availability of gifted programs to all students - equally - a non-negotiable. 

I echo Dr. Joy Davis's comments concerning this most important issue. It is significant to note that the proposed new regulations will not solve our crucial problem of the underrepresentation of culturally and linguistically diverse learners in special education. In fact, the proposed regulations in every way run counter to solving this challenge. The proposed regulations fail to include multiple criteria in the screening, assessment, evaluation and determination stages. This absence runs counter to all contemporary research and best practices in the field of gifted and talent development. If we wish to continue the status quo and support the continuation of this underrepresentation then the regulations accomplish that objective very well. If we wish to move towards equity and fairness, I urge you to use multiple criteria in all aspects of screening, assessment, evaluation and giftedness determination.

I strongly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia.  Minority and low-income gifted students will receive needed services so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community. I see this as an essential step to helping eliminate achievement gaps for black, Hispanic, and ESL students.

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As the product of gifted education programs, I, as a black male, am keenly aware of the benefits both immediate and long-term of such programs. Therefore, I strongly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia.  Minority and low-income gifted students will receive needed services so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community.

In Hanover Public Schools:  African American students make up 10% of the student enrollment but only 3% of students receiving gifted education services.  Caucasian students are 85% of the student enrollment, yet 91% of students receiving gifted education services.

Recommendation: Gifted regulations include a provision requiring all governor school budgetary information be reported on the VADOE database in a manner similar to that of all school division budget information

The Commonwealth of Virginia, under aegis of the department of education, has an opportunity to systemically ameliorate the racial and income disparity in gifted education.  This issue has been thoroughly researched by a bevy of scholars and non-scholars.  Therefore, current policymakers need not waste time with convening another group to study this matter.  The progressive position would be to implement, with all deliberate speed, the plan devised by the NAACP.

In Chesterfield Public Schools:  African American students are 27% of the student enrollment but only 10% of students receiving gifted education services.  Caucasian students are 61% of the student enrollment, yet 82% of students receiving gifted education services.

-Of the 57 Chesterfield County students selected for admission to Maggie Walker Governor’s School for the 2009-10 school year, 1 student was African American and 1 student was Hispanic; and

-Students eligible for free or reduced-price lunch are 25% of the school district enrollment but less than 3% of students placed in the center-based gifted education program.

-Recommend rejecting 8 VAC 20-40-40 subparagraph D3, Screening, referral, identification, and service.  Subparagraph D.3 provides that the identification process used by each school division must ensure that no single criterion is used to determine a student’s eligibility [for gifted services]. 

-Chesterfield County Public Schools uses a single criterion – 97^th percentile or higher on the CoGAT – for a student to be considered for center-based gifted education programs.  Students scoring in the 96^th  percentile or below are considered for home school gifted services which consists of differentiated instruction in the classroom (at best). 

-Recommend subparagraph D3 be rejected and replaced with specific language that establishes how to weight the criteria relied upon for gifted identification.  The weight given any criteria should be research-based and validated.

-Recommend subparagraph D3 be rejected and replaced with specific language requiring school divisions which rely upon a cut off score, in this case 97^th percentile, and used to determine the level of gifted services, to establish the validity of using that criteria as a determinant in providing the level of gifted services.

Comment Title:  Implement the NAACP gifted education recommendations

I strongly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia.  Minority and low-income gifted students will receive needed services so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community

In Petersburg City Public Schools:  African American students are 94% of the student enrollment but only 87% of students receiving gifted education services.  Caucasian students are 2% of the student enrollment, yet 10% of students receiving gifted education services.

-Recommend the regulations include this language: 

Significant disproportionality.
 
-The VADOE and school divisions must collect and examine data to determine if significant disproportionality based on race, ethnicity, and poverty status is occurring in the State and school divisions with respect to identification of children for gifted education and governor’s school programs.
 
-In school divisions where significant disproportionality exists, school divisions are required to reserve 15% of gifted funds to address the disparity.
 
-In school divisions where significant disproportionality exists, school divisions will review policies, procedures, and practices related to identification of minority and low-income gifted students.
 
-If policies, procedures, or practices are deficient in school divisions where significant disproportionality exists, the VADOE will require the school division to revise to comply with the requirements.
 
-In school divisions where significant disproportionality exists, the VADOE will require the school division to publicly report on the revisions of policies, procedures, and practices.

I stronly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor's school program throughout Virginia. Minority and low-income gifted students will receive needed services so they can reach their fullest potential and make their necessary contributions to Virginia, the United States, and our global community. 

I strongly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia.  Minority and low-income gifted students will receive needed services so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community.

I urge you to study and accept the recommendations given by the NAACP to amend the gifted education regulations. Please give all students in the State of Virginia with potential genius the opportunity to reach the highest heights of where there gifts can take them. Allow them all to contribute to being the pride of Virginia, these United States and the World.

I support the NAACP's request to consider a revision of the Virginia Regulations Governing Educational Services for Gifted Students to include provisions to help eliminate achievement gaps between students from different socio-economic groups. It is essential that minorities and less forunate studetns become a key percentage of the gifted and talented students that lead the the elementary and middle schools in the state of Virginia. The standrads and requirements need to be as un-bias as possible and if that means regulations being changed then that is a change I supoort.

I strongly agree and urge our elected & appointed officials to accept and implement the NAACP recommendation for changes and amendments to the gifted education regulations.  The recommendation of The NAACP will have more equitable gifted & governor's schools program throughout Virginia and America.  It will be beneficial to minorities and low-income gifted students, they'll receive needed services so they can reach not only their full potential but make necessary contribution to Virginia, USA and possibly our global community.  Why should the rich be the only ones with provides services and access?

My children attended the Virigina Public School System.  Because we were a military family who has just arrived in the area from South Carolina where we were expose to the Gifted Education Program is the only reason we knew what to seek.  If we had relied on the Virginia Public School System to label our children as gifted, our family would have lost out on those years of advance opportunities.  We went with our children on the first day of school and reviewed their school records with the Viriginia school officials and requested that our children be place in the gifted program.  Eight years later when our son entered elementary school, we had to do the same.  The Virginia school officials does not take the time to even view our minority children's school records to see if they would benefit from the gifted program.  Our children arrived with all A's and documentation that they were previously in the gifted program in another state.  If we were not vocal our minority children would have been purposely left out of this program.  Just imagine what happens to the minority students who parents are not aware that they can have their children tested, records reviewed, etc.  This should not be the case.  It should be the responsibility of the school officials to review records of outstanding performing students for enrollment into the Gifted Education Program.  However, when our children entered in the classroom they were one or one of two students in the Gifted Education classroom.  I wandered how ALL of those majority students knew about the program since they were so highly represented in population in that classroom that day.  Eight years later when my son entered the Gifted Program, once again he was the only minority student in the class.  The Virigina Public School System should be ashamed and held accountable for their actions.  Our minority students are under represented in the VIrginia GIfted Education Program.  Let us as get it rectified!

I strongly urge our elected and appointed officials to accept and implement the NAACP recommended changes and amendments to the gifted education regulations.  The NAACP recommendations will result in a more equitable gifted and governor’s school program throughout Virginia.  Minority and low-income gifted students will receive needed services so they can reach their fullest potential and make their necessary contribution to Virginia, the United States, and our global community.

In Loudon Public Schools:  African American students are 8% of the student enrollment but only 3% of students receiving gifted education services.  Caucasian students are 64% of the student enrollment, yet 81% of students receiving gifted education services.

 When identifying gifted/talented students from poverty and/or identifying students who are twice exceptional, one of the first obstacles to overcome is the perception of giftedness.

 If a school district has a twenty-year history of primarily identifying gifted/talented students from middle and upper middle-class households, school boards and administrators may not understand how someone can be gifted/talented and not score high on a traditional, standardized test or also be receiving special services from special education.

 Magnet schools and gifted programs were intended to achieve voluntary desegregation in the public schools and mitigate “white flight” from the public schools.  Now these programs serve to perpetuate class and racial advantage.

 -Recommend 8 VAC 20-40-60 local plan, be amended to require local plans address:

 Disproportionate representation.
 
-The VADOE must monitor school divisions in the priority areas:  disproportionate representation of racial, ethnic, and low-income students in gifted education, and governor’s school programs to the extent the representation is the result of inappropriate identification.
 
-The VADOE must identify school divisions with disproportionate representation, and of those, the number where the disproportionate representation is the result of inappropriate identification of children by race, ethnicity, and poverty status. 
 
-Identifying inappropriate identification could include a review of policies, procedures, and practices related to identification of gifted minority and low-income children.
 
-If disproportionality is due to inappropriate identification, require the school division to correct the noncompliance, including revising deficient policies, procedures, and practices.

 -Recommend that annual plans address disproportionality and corrective action plans if warranted.

 - Recommend the State Board of Education report with specificity in its’ Annual Report on the Conditions and Needs of Public Schools in Virginia to the Governor and General Assembly on the disproportionate representation of low-income and minority students in gifted education and Governor’s School programs.

As the Brown vs. Board of Education Supreme Court Case ruled a equal education for all. This ruleing needs to be strickly inforced within this state in the all the schools. Any school with very gifted and educated students reguardless of their race needs equal financial support so that they can continue to learn and strive for the best. Even if they are from a low-income family and go to a low- income inner city school, they still deserve the same equal education as anyone else.