To The Virginia State Board of Education:

Greetings:

I write to express my concern about some of the revisions proposed to the regulations governing education of gifted and talented (GT) students in Virginia.  I limit myself only to a few points, as others have ably expressed concern about line by line edits that should be made.

First, I am concerned that the deletion of the section that specifies funds will be used for gifted education may allow districts to apply those funds to other aspects of their budgets.  This is the appearance of the deletion, if not the intent.  8 VAC 20-40-70.

Second, education of gifted students is a specialty, requiring additional teaching certifications and knowledge not available to the general public.  Moving approval of a local district's plan for gifted education away from the specialists in Richmond and into the hands of the local school board fails to recognize the lack of knowledge that may exist at the local level.  8 VAC 20-40-60.  Even though the revised regulations provide that the Gifted and Talented Advisory Boards are to certify compliance, these are volunteer boards composed, by regulation, of teachers, parents and other community members.  I have been a member of the Fairfax County Public School's Advisory Commitee for three years.  We have reviewed the plans every year to verify that the schools are working towards their stated goals.  However, I do not feel that I, a parent with no training in education, am qualified to review the plan to certify that it complies with all state regulations and is the best way to provide for the education of our gifted students.   Without oversight by the specialists at the Department of Education, there is a real risk that the local GT Plan will be watered down. 

Further, switching from a five-year plan with annual performance reports to an annual plan seems to increase the administrative burden on the local school districts while at the same time decreasing their accountability.  By the time the plan expires, they won't yet have the information to determine if the goals were met, especially when switching to new teaching methods.  Please continue with 5 year plans. 

Third, the proposed regulations provide that the local school district must evaluate a student within 60 days of receipt of a referral.  In practical terms, this means that the school district will be constantly evaluating students during the entire year, as referrals may be made at any time by parents or teachers.  8 VAC 20-40-40E.  To ease the administrative burden, and reduce the likelihood of rushed decisions made on incomplete information, I suggest that each school district be allowed to assess students on a fixed timetable, so that referrals that are not received by a certain date are required to wait until the next assessment period.  Fairfax County administers norm-referenced aptitude tests three times a year on a fixed timetable and this seems to adequately balance the need to identify GT students with the administrative burden testing entails.

Fourth, the proposed regulations give parents only ten business days from receipt of the GT Committee's decision regarding acceptance for GT services to file an appeal. 8 VAC 20-40-55. This seems rather short, especially for parents who have not previously had experience with the selection process.  I suggest that 21 days would be a reasonable amount of time and would not unduly lengthen the appeals process.

Fifth, the requirement that all students from kindergarten through high school graduation be screened annually for inclusion in gifted services is excessive and creates an undue administrative burden.  The percentage of truly gifted students is small and they frequently stand out in a class full of general education students, and will generate a referral from teachers or parents if they are "late bloomers."  A one-time screening of all students, followed by an option for future screening based on referrals of specific students seems adequate.  My concern is that an annual screening requirement will become an exercise in administrative compliance (open file, look for 2 seconds and check off a box) and not a true search for the gifted students.  Wouldn't the time be better spent teaching general education teachers how to recognize the signs of giftedness that sometimes stay under their radar so they are better prepared to make a referral when appropriate? 

Thank you for considering my opinion on these issues.

Sincerely,

Sarah Thomas Mayhew

Fairfax, VA