As a former gifted program coordinator, Associate Director of Gifted Programs for the DOE, visiting professor of gifted education for the College of William and Mary, and advocate of gifted children, I am concerned about the proposed regulations governing gifted programs.  Specifically, I am concerned that local districts are not held accountable for submitting their gifted program plan for review by the DOE. I believe that such accountability is in the best interests of gifted students as plans should be reviewed by individuals knowledgable about characteristics of gifted learners and effective gifted programs. 

I recommend that the proposed regulation NOT be adopted as they are written.  Instead, I propose adopting the revisions as proposed by the Virginia Association for the Education of the Gifted and the Gifted Program Coordinators.