by James C. Sherlock
The massive flows of federal and state funding to local school districts are based largely on data reported by the schools to their districts, the districts to the Virginia Department of Education (VDOE), and VDOE to the U.S. Department of Education.
In Fiscal Year 2018, the U.S. Department of Education sent more than $820 million to Virginia in support of K-12 education. Every dollar was allocated based on data collected and quality assured at the local, state and federal levels.
The City of Richmond Public Schools (RPS) has massive problems that result in outsized contributions by the federal government. One of those problems — a serious and potentially consequential one — could imperil federal funding.
We will explore a recent event that illustrates that issue.
The federal money. In 2018-19, VDOE reported RPS received $2,273 in federal aid for each pupil in its system on a reported average daily membership of 24,708 students. The total was 0ver $56 million.
The average school district in Virginia received $901 per pupil.
The federal requirements. The federal government, as you would expect, has strict requirements for data quality.
The accountability provisions included in the No Child Left Behind Act of 2001 (NCLB) significantly increased the urgency for States, local educational agencies (LEAs), and local schools to produce accurate, reliable, high-quality educational data. With determinations of whether or not schools and LEAs make “adequate yearly progress” (AYP) dependent upon their student achievement data, it has never been more important for State and local data systems and reporting processes to produce accurate, reliable information.
“It is vitally important for States and localities to implement the best enhanced management controls possible over the data that are being used to make key judgments about AYP, funding, NCLB accountability, and other State and local education policies.”
Federal guidelines are very clear. Section 5E of those guidelines defines roles and responsibilities for data quality at the individual school, district (LEA), state and federal levels. They have been in effect since 2006.
RPS is the local educational agency (LEA) for the City of Richmond. RPS is required by the federal government, inter alia, to:
- Establish a data quality team, including the (RPS) chief information officer.
- Establish an (RPS) schedule for data collection and reporting, based on State-level deadlines.
- Coordinate staff training on data quality across all schools.
- Establish a process for error remediation between individual (Richmond) schools and the (RPS).
- Validate and certify the accuracy of all (RPS)-level data before transmittal to the State.
So what happened? I reported the other day from an RPS Reopening Dashboard file on the RPS website that only 21% of 3008 RPS staff had been fully vaccinated as of June 7 (open the “source data – June 7” sheet).
RPS has been collecting and reporting data on school staff vaccinations to VDOE as well. I followed up with VDOE to see how other school divisions were doing.
I received from the VDOE press officer VDOE’s Vaccine Report as of April 26 2021 by LEA. As you will note in that spreadsheet, RPS reported to VDOE in April that 68% of 3901 RPS staff were fully vaccinated.
So, is it 21% of 3008 school staff, 68% of 3901 staffers, or something else? We simply don’t know. But it matters.
VDOE is awaiting federal guidance before putting out its own guidelines on vaccination requirements for school staff this fall. If asked for the current vaccination status by the feds, VDOE will get the data from the school districts.
The level of granularity down to the individual school level of the data posted on the RPS website suggests those data are far more likely to approach reality — assuming, and it is a big assumption, that individual schools reported accurately — than what it reported to VDOE in April.
What is absolutely clear is that there is no effective quality assurance of data in RPS.
Consequences. The U.S. Department of Education will not be amused.
Consider, if you will, just two of the federal and state data points — Average Daily Membership and Average Daily Attendance.
Average daily membership (ADM) is determined by dividing the total aggregate daily membership by the number of days school was in session from the first day of the current school year through the last school day in March of the current school year.
Average daily attendance (ADA) is determined by dividing the aggregate number of days of attendance of all students by the number of days school was in session from the first day of the current school year through the last day in March of the current school year.
Anyone want to guess at the accuracy of the RPS data on just these two figures of significant importance in funding? A system that doesn’t have any idea how many of its teachers have been vaccinated?
This incident raises fundamental questions of quality and accountability for the data from which the U.S. DOE sends $56 million and more a year in federal education funds to RPS.
The kids in Richmond desperately need to be taught well in environments conducive to learning. It is clear that the federal money has not helped RPS achieve that outcome. But ignore that for now. Assume better leadership could deploy that money effectively.
Compounding its other failures, RPS puts all of that federal money at risk by not maintaining any semblance of data quality.
What to do? It is the dual responsibility of the Inspectors General of the U.S. Department of Education and of Virginia to investigate VDOE’s performance of its data quality oversight, training, collection and reporting responsibilities.
It is VDOE’s responsibility to investigate RPS in this matter.
I can give the investigators a head start. The federal guidelines require the RPS data quality team to be led by the RPS Chief Information Officer. RPS has no CIO position and none that reasonably replicates the usual qualifications, position in the management hierarchy or responsibilities of Chief Information Officers.
We look forward to their reports.