The regulations currently up for approval regarding gifted education in the state of Virginia should not be approved for the following reasons:

(1) Proposed changes negate the need for specialized training in gifted education in order to teach gifted children or to coordinate gifted programs. In order to effectively and appropriately serve gifted students, individuals need to have specialized training in the field.

(2) Proposed changes negate the need for 5-year plans to be approved by the State Board of Education,including the state level gifted coordinator. This leaves the plans potentially generated by individuals not familiar with gifted education (see comment above) and approved by boards that are not comprised of any individual(s) that have expertise in the area of gifted education which has direct implications for the types of services, if any, that gifted students will receive. Divisions with fewer resources would be additionally negatively affected.

(3) Proposed changes would include allowing funds that are currently earmarked for gifted programs to NO LONGER BE REQUIRED to be spent on gifted programming or services. This certainly will eliminate programs currently in rural or improverished areas where many under-represented populations currently exist.