UPDATED

The Council of Chief State School Officers has proposed its own plan for ensuring that federal funds supplement and do not supplant state and local education spending, a plan that differs in a few key respects from the U.S. Department of Education’s own proposed rules.

Under the proposal that CCSSO is submitting as a formal public comment to the Education Department, districts would not have to pick between four options for distributing state and local school aid, as the department’s proposed regulations would require. In fact, there’s no menu of possible methodologies in the state chiefs’ proposal. And CCSSO also says that state and local money should be distributed to schools without taking their Title I status into account—that refers to schools with large shares of low-income students.

The CCSSO plan would also require districts to publish how they distributed state and local money, show they’re actually distributing it that way, and consider their funding method’s impact on schools undergoing comprehensive turnarounds.

The supplemental-money rule has become one of the most controversial elements of the Every Student Succeeds Act, which passed late last year. During initial negotiations over how to regulate this last spring, the department proposed that spending between Title I and non-Title I schools would have to be nearly equalized. But that idea provoked a lot of criticism from various quarters.

In the formalized proposal it released in August, the department decided to make the near-equalization of spending between schools one of four options for districts to show they are meeting supplement-not-supplant requirement. The other three are: a weighted per-student formula; a method that considers personnel and non-personnel spending; and a state-developed method that’s approved by the department.

The state chiefs’ group says it is committed to “equitable education opportunities for every child, no matter their race, ethnicity, income level or where they attend school.” But the CCSSO also says of the Education Department’s proposal: “Setting up a compliance system where every educational decision that touches spending must be vetted through a central district office is more than just a paperwork burden; it takes decision-making away from the people closest to students.”

In remarks accompanying its formal comment to the department, the CCSSO picks apart the four options the department has proposed:

• The weighted per-student formula, the group says, is too narrow and could render many existing such formulas out of compliance;
• The combined personnel and nonpersonnel spending method is overly vague and leaves several unanswered questions about spending practices in schools;
• The state-developed option could be too much of a load for state education departments to carry, according to the state chiefs;
• The Education Department’s proposed option to roughly equalize spending between Title I and non-Title I schools leaves terms like a “high proportion” of disadvantaged students undefined, and leaves out some classes of disadvantaged students, the CCCSO says.

UPDATE: On a conference call with reporters Tuesday, Wisconsin Superintendent of Public Instruction Tony Evers highlighted how the CCSSO’s proposal would put a spotlight on resource inequities at low-performing schools in particular. And he stressed that states understand the importance of equity.

“Equity is enhanced by transparency,” Evers said, adding that there’s been clear progress made on the issue since contentious negotiations over the supplemental-money rule in the spring.

By contrast, the proposed department rules could upend certain changes to district operations like those made in Clark County schools in Nevada, said Steve Canavero, that state’s superintendent.

Asked about whether the group’s plan shares much in common with the department’s proposed rules, CCSSO Executive Director Chris Minnich responded that the requirement for a district to publish its methodology was inspired by the department. And Minnich, said with respect to federal aid supplementing state and local dollars, there should be more of a focus on the quality of services being provided, not just on total dollars spent.

Department officials have maintained that some districts are improperly and unfairly shortchanging Title I schools, and that its supplemental-money proposal would result in up to $2 billion in additional state and local aid for those students. Civil rights groups have hailed the department’s push on this issue, but district administrators and Republicans in Congress say the department’s plan is overly prescriptive and potentially damaging to students and districts.

UPDATE: Sen. Lamar Alexander, R-Tenn. and the chairman of the Senate education committee, has been a big critic of the department’s approach. But he’s a fan of what CCSSO is proposing.

“The Chief State School Officers’ proposal is practical and is in keeping with what Congress wrote and intended in the new education law. The department should listen to this idea rather than moving forward on its proposed rule, which violates the law and congressional intent by effectively having the federal government decide how to distribute state and local education dollars,” Alexander said in a statement.

Approximately 600 comments have been submitted to the department regarding its August ESSA spending proposal. The comment period closes Nov. 7.