As an educator of gifted students in Virginia Beach City Public Schools (VBCPS), I do not support the proposed Gifted Program Regulations.   I do not support the following items:

·        Assessment of each gifted student’s intellectual and academic growth

      Current VBCPS practices of embedding gifted education in the regular education for sustained and ongoing development of students’ gifts and talents is superior to an IEP-like approach. It is fiscally impossible to administer individualized intelligence tests to all gifted learners in a district the size of VBCPS in order to report to parents and legal guardians on the intellectual growth of their child.

·        The restricting time frame of 60 days for gifted referral, identification, and placement. This regulation suggests that a referral may be submitted at anytime and from the time it is submitted, the school division has 60 days to complete referral, identification, and eligibility processes. This is an unreasonable expectation for a large school division with a centralized gifted eligibility committee.

·        Annual review of achievement data on all children K-12

         maintaining a review of student achievement data at key points throughout the K-12 continuum us reasonable

·        Acceptance of referrals and formal gifted identification beginning at kindergarten.

      The proposed regulation fails to adequately ensure equity and excellence for all students with the potential for gifted identification. In VBCPS, all students are identified for gifted services through the talent pool model at kindergarten and first grade. This model ensures equity in access to all subgroups of the general population. 

·        Inclusion of a person on the eligibility committee who “knows the child”

     For large school divisions with centralized eligibility committees this is very costly. 

     As long as written teacher and parent input are provided for the committee, there should be no need for a person who "knows the child" to be physically present on the eligibility committee.

·        Reporting of monitored and assessed outcomes of gifted learners. This regulation suggests an IEP-like approach to gifted services which would be detrimental to the existing high quality curriculum, instruction, and assessment currently in place for gifted students in VBCPS; I previously taught in a system that mandated an IEP for all gifted students. Due to the large ratio of gifted students per teacher, it often became very difficult to make each student's plan "individualized" and each plan became very generic due to time constraints. This practice undermines current VBCPS practices of embedding differentiated gifted education in the regular education by taking away the GRT's time spent on integrating services for students-- requiring them to shift time and effort to an IEP-like module that is virtually impossible at the secondary level due to  the number of gifted students at each school.

·        A shift from development of a five year local plan to an annual plan. One year plans are not beneficial to the future growth and development of any gifted program.

•  Requiring school divisions to assure that testing and assessment materials selected and administered are free of cultural, racial, and linguistic biases is impossible because there are no assessment materials that have been proven to be free of cultural, racial, and linguistic biases. 

In conclusion, I recommend that state funds administered by the Department of Education for the education of gifted students be used only to support those activities identified in the school division’s Local Plan as approved by the Virginia Beach City Public Schools School Board and the Department of Education. Please consider reinstating: 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.

Thanks for your consideration of these comments and thank you for the opportunity to voice my concerns.