January 2005
 
                                                                                                                                                                                                                      

 

 

THE STATE EDUCATION DEPARTMENT / THE UNIVERSITY OF THE STATE OF NEW YORK / ALBANY, NY 12234

 

James A. Kadamus Deputy Commissioner

Office for Elementary, Middle, Secondary and Continuing Education

Room 875 EBA                                                             518.474.5915

 

 

 

TO:

 

District Superintendents

Superintendents of Schools

New York City Department of Education

School Board Members

New York State Educational Associations

Nonpublic School Administrators

Administrators of Charter Schools

Other Interested Persons

 

FROM:

James A. Kadamus

SUBJECT:

Regents Proposal on State Aid to School Districts for 2005-06

 

The Regents State Aid proposal for 2005-06 builds upon a foundation formula proposal begun last year and responds to recommendations of a CFE Referee Panel.  Its goal is to provide a State funding system for education that provides adequate resources through a State and local partnerships so that all students have the opportunity to achieve the State’s learning standards, including resources for extra time and help for students.

 

The Regents propose to simplify school funding by consolidating 29 aids into a foundation formula.  The foundation formula is based on the cost of educating students in successful school districts, adjusted for regional cost differences and differences in each district’s concentration of needy pupils.  An expected local contribution is calculated based on each district’s actual value per pupil, adjusted by income per pupil.  State Aid is calculated as the foundation cost less the expected local contribution.  The proposal would hold school districts harmless against loss for the group of aids combined into Foundation Aid and would be phased in over five years.  Aids to be kept separate are:

 

·       Building Aid—enhancements are proposed to simplify and improve a cost allowance used in the calculation of Building Aid so that it is responsive to costs for site acquisition and multi-story buildings in dense urban areas.

·       Special education aid—recommendations include: continuing the additional weighting for students with disabilities receiving special education programs and services 60 percent or more of the school day in settings integrated with their non-disabled peers; current year aid for new high cost students with disabilities; and a per-pupil, rather than total dollar, save-harmless for Public Excess Cost Aid.

·       Universal Pre-K—increase this aid and base it on the per-pupil award used in the Foundation Formula, so that it can be incorporated in the future.

·       LEP Aid— Maintain a separate aid for the additional instruction of limited English proficient students.

In addition the proposal recommends enhancing school accountability by funding, through a separate budget proposal, technical assistance teams for high need school districts, a student information system, a financial condition indicator system and State Aid and grants management systems.   The State should require high need school districts to prepare an annual, comprehensive Sound Basic Education plan and report, for approval by the State Education Department.  The State should eliminate duplicative and redundant planning and reporting requirements, as provided for in a separate Regents legislative proposal.

 

The Regents recommend a $1.5 billion increase for school year 2005-06, with a total increase of $6.6 billion in the State's foundation formula over five years. Figure 1 shows the dollars requested for school year 2005-06.  Figure 2 shows the distribution of the share of the overall increase in computerized aids for 2005-06 to school districts grouped by need/resource capacity category.  Figure 3 shows the distribution of the increase in computerized aids for the fully implemented proposal, for school districts grouped by need/resource capacity category.  Figure 4 shows that 80 percent of the increase in computerized aids would go to high need school districts under the Regents proposal compared with 67 percent as enacted for school year 2004-05.  Figure 5 shows the distribution of computerized aid per pupil in 2004-05 and as proposed by the Regents for 2005-06 for school districts, grouped by need/resource capacity category.

 

 

 

Figure 1
 


Figure 4
 

 

 

 


Regents Proposal on State Aid

To School Districts for School Year 2005-06

 

CONTENTS

 

Deputy Commissioner’s Memo

 

Regents Conceptual Proposal

 

          The Regents Proposed Foundation Formula
          Effectively Drives Funding to Educational Need

 

          The Regents Proposed Foundation Formula
          Consolidates Many Aids, but Retains Several
          Separate Categorical Aids

         

          New York’s System of Accountability Should

          Be Enhanced to Ensure That Resources are

          Being Used to Provide a Sound Basic Education

 

          Regents Response to the Report of the CFE Referees

         

          Regents Continue to Advocate for Elements of

          The 2004-05 Proposal for a Foundation Formula

 

Technical Supplement

 

          Need/Resource Capacity Definitions

 

          High Need School Districts 2005-06 School Year

 

          Aids and Grants to be Consolidated and Other Aids
          Under the Regents Proposal

 

          Formula Components

 

          Regional Cost Adjustment Based on

          Professional Salaries

 

          Summary of Aids and Grants as Requested

          in the 2005-06 Regents State Aid Proposal

 

          Analysis of Aid Changes Under the 2005-06

          Regents State Aid Proposal

 

         


Figures

 

1.     Regents State Aid Proposal New York State

 

2.     Regents State Aid Proposal
Share of Overall Increase

 

3.     Fully Implemented Regents State Aid Proposal
Share of Overall Increase

 

4.     Computerized State Aid Increases
How They are Distributed

 

5.     Distribution of Computerized Aid per Enrolled Pupil

 

6.     Elementary –Level Mathematics

 

7.     Mean Free Lunch and Grade 4 ELA Mean Score
By Need/Resource Category 2002-03

 

8.     Professional Cost Index for New York State
By Labor Force Region (2003)

 

 

 

 

Regents 2005-06 Proposal On

State Aid To School Districts

 

REGENTS CONCEPTUAL PROPOSAL

 

Since 1999, New York State has steadily increased its standards and its student achievement.  Five new Regents examinations have been developed by committees of experts and phased in gradually.  Student results have been encouraging.  Figure 6 shows that students in every need/resource capacity category of school districts have improved consistently in elementary-level mathematics over this period.  Students meeting all the standards have increased in every category. Since 1999, New York City and the Big Four city school districts have achieved increases of almost 20 percentage points, mostly in the past two years.  Similar trends are found for other subjects and at other levels of instruction.

 

 

Figure 6

Elementary-Level  Mathematics
 

Percentage of Students

Scoring at Levels 3 and 4
 
 

 


 

 

 


Figure 6 also shows a troubling achievement gap.  Figure 7 further shows that, as the percent of students in poverty declines, as measured by students eligible for free lunch, achievement on the Grade 4 English language arts examination increases.  As poverty increases, results worsen.

 

The resource and achievement gap has been well documented in past Regents proposals.  The courts recognized the existence of this gap in the case of Campaign For Fiscal Equity, et al. v. State of New York, et al. by finding that large numbers of students in New York City were being denied the sound basic education the State Constitution
entitles them to.

 


This proposal expands upon last year’s Regents proposal on State Aid to school districts.  It provides a detailed description and rationale for a new funding system based on a Foundation Aid program.  The new system links education funding to the cost of successful education, targets State Aid to school districts with the greatest educational need, and recognizes variation in purchasing power around the State.  The proposal is also responsive to the court mandate of Campaign For Fiscal Equity, et al. v. State of New York, et al. in that it:

 

(1)        ascertains the cost of providing a sound basic education;

 

(2)        reforms the current system of school funding to ensure students have the opportunity for a sound basic education; and

 

(3)        proposes a system of accountability to measure whether proposed reforms actually provide an opportunity for a sound basic education.

 

This proposal is a simple and comprehensive solution to closing the student achievement gap and providing all students the education to which they are entitled.  It also makes explicit the ways in which the Regents proposal is responsive to the CFE court order noted above.

 

I.      The Regents Proposed Foundation Formula Effectively Drives Funding to Educational Need.

 

The Regents propose that the current State aid system be abandoned, and a new system adopted statewide that focuses on identifying student need and targeting funds to that need.

 

After careful consideration, the Regents decided on a Foundation Formula approach.  The Regents Foundation Formula replaces 25 existing formulae with one that has only four components.  By design, it is simple, predictable, and easily understood by the public.

 

The Foundation Formula first calculates the average cost of educating a general education student in New York State (i.e., the “Foundation Cost”).  The Foundation Cost is then adjusted by two indices, the “Pupil Need Index,” which accounts for the additional cost of educating disadvantaged students, and the “Regional Cost Index,” which accounts for cost disparities in different geographic areas. The State’s share of aid is then calculated by subtracting from the adjusted Foundation Cost an “Expected Local Contribution” from each district, and multiplying that result by a pupil count.  The Foundation Formula is represented as:

 

Foundation Formula Aid = [Foundation Cost x Pupil Need Index x

Regional Cost Index] - Expected Local Contribution

 

The Foundation Formula approach has several advantages.  It sets aid independent of any decisions by districts on how much to spend.  It also provides certainty to districts regarding how much funding they will receive.  And, most significantly, it explicitly links school funding to the cost of educating children and drives dollars where they are most needed.

 

The Regents Plan Accurately Measures The Cost Of Student Success.

 

The first element of the Foundation Formula, the “Foundation Cost,” is the starting point for determining cost.  The Regents Plan uses a “successful school districts” methodology to determine Foundation Cost.  This method identifies actual school districts that meet a defined standard and then estimates per pupil spending in those school districts.[1]  The “defined standard” set by the Regents as a proxy for sound basic education has three components.  The Regents standard selects school districts where students were achieving an average of 80 percent success on seven required examinations (English and Math at the elementary level and five Regents examinations — Math A, Global History, U.S. History, English and Earth Science) in 1999-00, 2000-01 and 2001-02.  This standard reflects student achievement at both the elementary and secondary school levels, avoids atypical results of any one year by averaging data from three years, and provides evidence that a large number of students are offered the opportunity to achieve Regents standards.  Applying this standard, the Regents will identify what successful school districts are spending per pupil for general education instruction.[2]

  

1.       The Regents Plan Adjusts Cost To Account for Pupil Need.

 

Because some students require additional time and help to achieve the State learning standards, the Regents Plan adjusts the Foundation Cost by a “Pupil Need Index.”  The Pupil Need Index recognizes the additional cost of providing extra time and help for high-risk students to succeed. Thirty years of research has proven that there are additional costs associated with educating students in poverty and in school districts that are small because of geographic isolation.  Applying the Index increases the Foundation Cost for districts with more needy pupils.

 

The Regents Pupil Need Index is based on the number of students eligible for free and reduced price lunch and students living in geographically sparse areas of the State. The Pupil Need Index employs a formula that increases the weighting for poverty as the concentration of poverty increases. This enhances the cost-effectiveness of the aid system by targeting dollars to educational need.

 

The specific index chosen by the Regents is based on SED research.  A September 2003 State Education Department study of educational need[3] examined how to establish an additional weight for educational need.  It found that states use additional weightings of from 0.25 to 1.0 based on the availability of funds. It also reported that additional weightings from 1.0 to 2.0 are recommended by experts to raise students from economically disadvantaged backgrounds to the achievement levels of their more advantaged peers.  The study concluded that New York should use an additional weighting of 1.0 for each needy pupil in districts with the highest concentrations of student need.  In this Regents proposal, the weighting for pupil need ranges from .5 to 1.0, gradually increasing as the concentration of poverty increases.

 

2.       The Regents Plan Properly Adjusts Cost To Account for Differences in Purchasing Power.

 

Because the purchasing power of a dollar varies in different parts of the State, the Regents Plan further adjusts the cost figure by a “Regional Cost Index.”   The Regional Cost Index operates to standardize costs across the geographic areas in which school districts operate.

 

The Regents Regional Cost Index is based on wages of non-school professionals in each of nine labor regions of the State, as defined by the New York State Department of Labor.  Labor regions are composed of groupings of contiguous counties.   The Regents Plan uses regions rather than school districts because job seekers tend to access an entire region when seeking employment and do not necessarily limit themselves to a single school district.

 

Teachers are purposefully excluded because school districts exercise unusual market influence over the price they pay for teaching services, which may distort the free market costs the index is intended to represent. The varying salaries paid teachers may reflect the preference of an individual district to pay more than an adjacent, competing one, rather than economic factors beyond the district’s control.

 

The Regents Regional Cost Index was developed after a review of national research on adjusting school aid for variation in costs.3   The index also reflects the recommendations of several New York State special legislative commissions charged with making recommendations to improve New York State’s school funding system: Fleischmann in 1972; Rubin in 1982; and Salerno in 1988.  SED used wage data from the 2001 Occupational Employment Statistics Survey collected by the Bureau of Labor Statistics for 63 non-education professional job titles that required at least a Bachelor’s degree for employment and thus could be expected to compete with the teaching profession.  Median hourly wage data were provided for each title statewide, as well as for each of nine labor regions.  SED then weighted these occupational wages in each region to mirror the workforce mix of the 63 titles statewide.  The index chosen ranges from 1.0 for the North Country labor force region to 1.496 for the combined New York City-Long Island labor force regions (see Table 1).

 

 

Figure 8

Professional Cost Index for New York State

by Labor Force Region (2003)

Labor Force Region

Index Value

Purchasing Power of $1,000 by Region

Capital Distict

1.168

$856

Southern Tier

1.061

$942

Western New York

1.080

$925

Hudson Valley

1.359

$735

Long Island/NYC

1.496

$668

Finger Lakes

1.181

$847

Central New York

1.132

$883

Mohawk Valley

1.016

$984

North Country

1.000

$1,000

 

B.      Regents Plan Derives State Aid By Subtracting From The Adjusted Foundation Cost An Expected Local Contribution.

 

School funding is a State and local partnership, and localities must contribute their fair share of education spending. Thus, once the Foundation Cost is determined, the Regents Plan subtracts an “Expected Local Contribution” to arrive at the level of aid the State will supply.  The Expected Local Contribution is an amount school districts are expected to spend as their share of the total cost of general education.  The Regents Plan measures it by multiplying the district property tax base by an expected tax rate, adjusted by district income per child.   The Regents Plan adjusts the tax rate by district income per child to assess the fiscal capacity of school districts by their income wealth as well as their property wealth. This method preserves both measures of district wealth (income and property) and the structure of the Foundation Formula.

 

Under the Regents Plan, the Expected Local Contribution is not a mandated tax rate, but a way of determining an equitable local share in order to calculate State Aid.  The plan avoids mandating a local contribution because it is difficult to enforce without penalizing students.  The plan holds  districts accountable through public reports of student performance and school district local effort.  If a district does not adequately fund its share, but student performance remains high, there need be no consequence.  If student performance suffers, however, State intervention will be triggered through the State Accountability System.

 

          C. The Regents Plan Properly Accounts For The Number of Students Aided.

 

Once the per-pupil State aid is determined for each district, that amount is multiplied by a count of pupils in the district to determine the total aid the State will pay to each district. The Regents proposal recommends counting students enrolled in school districts (i.e., average daily membership) rather than those actually attending (i.e., average daily attendance) as is done in current formulae.  By relying on average daily membership, the Regents proposal eliminates any disadvantage high-need school districts may suffer due to poor attendance.

 

 

       II.         The Regents Proposed Foundation Formula Consolidates Many Aids, But Retains Several Separate Categorical Aids.

 

The Regents Plan recommends some consolidation of aids for basic school operation.  Specifically, the Regents propose to consolidate a number of aids into the Foundation Formula.  Consolidation simplifies the formula, allows for increased equity, and gives districts greater flexibility in spending. The Regents Plan also retains certain aids separately.  The balance of this section describes aids that the Regents recommend be retained separately.

 

 

Special Education Aid

 

Whether to consolidate aid for special education into the Foundation Formula is a complex question.  As a beginning step, the Regents conducted a series of forums around the State to receive public comment.  Educators, advocates, parents and others expressed a variety of views.  For the most part, forum participants expressed a desire to retain special education funding as a separate aid.  They voiced concerns about the consistency of data from school district to school district and the need to adequately fund extra time and help needed by all students prior to referral.  They raised the issue of the ability of districts to cope with rising costs, including those associated with certain integrated program models and costs for high-cost students with disabilities, especially those who move into the district during the school year.

 

The Regents have asked staff to explore options for simplifying special education funding, while retaining it as a separate aid program.   Once recommendations are developed, staff will elicit public comment on identified approaches.  For this year, the Regents will retain special education funding as a separate aid and advance a proposal that provides current-year aid for new high-cost students with disabilities.

 

Universal Pre-K Funding

 

In the 2004-05 proposal, the Regents maintained separate categorical grants to support pre-K education.  Advocates for early childhood learning have argued that incorporating universal pre-K funding into the Foundation Formula will allow the State to continue to make progress toward offering the program universally.  Research has documented long-term achievement benefits for students.  While these may be arguments for folding funding for universal pre-K programs into the Foundation Aid program, there is not currently the capacity in all school districts to offer pre-K programs and K-12 programs.  When this capacity exists, the State should consider consolidating programs for pre-K into the Foundation Program.

 

Building Aid

 

Because capital costs for school districts can vary significantly around the State from year to year, this aid should be retained separately. For example, school construction costs may be high for a district for a number of years for a project and then small or nonexistent afterward.  Aid for school construction is provided based on approved expenses, a different basis than that used for Foundation Aid.

 

Regents recommendations concerning Building Aid and other State support for school construction will help overcome barriers to instructional improvement posed by inadequate school facilities. Early grade class size reduction, pre-K programs and science laboratories are examples of instructional programs that are dependent on the availability and quality of school space. These recommendations will simplify capital planning, reduce severe over-crowding in school districts, help fund extraordinary incidental costs beyond the control of the school district, reduce school construction costs, and improve the maintenance and repair of school facilities.

 

Recommendations to simplify planning and to ensure Building Aid is equitable:

 

·       Simplify the maximum cost allowance formula for State Building Aid. The State sets a reasonable cost ceiling for all capital projects. The current system is an overly complex and inefficient process that, in some cases, forces a district to compromise the desired educational goal in order to achieve maximum reimbursement. It is proposed that the State calculate a cost allowance based on a certain allotment of space and cost per enrolled pupil, according to the following formula:

 

Cost Allowance = Projected Pupil Enrollment x Allowed Square Feet

Per Pupil x Allowed Cost per Square Foot x Regional Cost Factor

 

Allowable costs would be updated monthly by the current New York State Labor Department Cost Index. Unlike the Regents Regional Cost Index proposed for Foundation Aid, which is fundamentally a professional wage index, the New York State Labor Department cost index is based solely on the wages of three major occupational titles critical to the building industry.   A simplified formula would offer greater educational flexibility, ease of understanding and transparency.

 

·       Building Aid review of preliminary and final plans and specifications for all new proposed school facilities in New York City prior to the awarding of construction contracts. Currently, all other school districts in the State benefit from an aidability review by the State Education Department that provides the information necessary for a district to maximize State Building Aid on school construction projects. Aidability reviews would reduce the more than 25 percent gap in aidable new building costs between New York City and the rest of the State.

 

Recommendations to relieve overcrowding:

 

·       Provide a supplemental cost allowance to recognize extraordinary site acquisition costs beyond the control of the school district, environmental remediation in dense urban areas, and building demolition necessary to build new school buildings to relieve severe overcrowding.

 

·       Provide a supplemental cost allowance for the increased costs associated with the construction of multi-story fire-resistive buildings in compliance with applicable building codes in dense urban areas where erecting one or two-story buildings is not practical.

 

Recommendations to improve the cost-effectiveness of school construction:

 

·       Eliminate the Wicks Law. A provision of State Law, known as the Wicks Law, requires municipalities, including school districts, to employ four separate prime contractors for school construction projects of $50,000 or more. A general contractor can effectively manage these separate functions. New York City already has this benefit. No other State mandates separate contracts for public works. Making the Wicks Law optional could reduce project costs by an average of 5 to 10 percent.

 

·       Allow school districts access to the Dormitory Authority of the State of New York for basic construction services to ensure they receive the quality construction they are paying for.

 

·       Eliminate State Building Aid for energy performance capital construction contracts without voter approval.  The Board of Regents believes that energy efficiency improvements in public schools are an important consideration in controlling school operating costs and demonstrate responsible environmental behavior.    Energy performance contracts or traditional capital improvement projects approved by voters are two methods available to districts to implement energy saving improvements. 

 

Recommendation to protect the investment in school facilities:

 

·       Provide resources for minor maintenance and repair of school facilities. Facilities maintenance and operating budgets are generally the first target for budget cuts during difficult fiscal times when districts are striving to maintain educational programs and offerings. Studies show that one dollar spent on maintenance can save six dollars in future capital construction costs. This program will pay for itself in reduced State Building Aid. School districts would be required to maintain their financial effort to maintain and repair their facilities.

 

         

Regional Services and the Big Five City School Districts

 

BOCES were established in 1948 to provide educational programs and services to school districts on a regional basis to reduce costs and promote excellence, especially in small rural school districts with declining enrollments.  BOCES have developed considerable expertise in offering programs of professional development, career and technical education, and information technology.  Demographic changes of increasing poverty and declining tax bases in large city districts have resulted in growing demand for such services in our large cities.  For reasons of efficiency and effectiveness, the Regents now find that it is in the public interest to share services for use in city school districts.  This proposal recommends that the existing practice of excluding large city school districts from accessing BOCES services be discontinued on a trial basis.  It recommends that the large four city school districts (Yonkers, Rochester, Syracuse and Buffalo) be given the authority to contract with neighboring BOCES for services in critical service areas that are strong in BOCES and weak in the city district.  It further recommends that:

 

For the New York City school district, the enriched Special Services Aid would be provided to support regional services in critical need areas within the city school district.

 

 

Aid For Limited English Proficient Students

 

The Regents Plan retains aid for the education of limited English proficient students and bilingual education grants as separate categorical programs. This proposal recognizes that services for limited English proficient pupils are different in nature from academic intervention services.  As school accountability systems improve, providing disaggregated achievement results for separate groups of students including limited English proficient students, consideration can be given to folding these aids into the Foundation Formula.

 

 

III.       New York’s System of Accountability Should Be Enhanced to Ensure That Resources Are Being Used to Provide A Sound Basic Education.

 

The courts have held that State defendants must institute a system of accountability that measures whether the reforms adopted actually provide students with the opportunity for a sound basic education.  In the Regents view, the State does not need a different accountability structure, a new accountability “office,” or a new independent oversight panel, to comply with the Court’s order.  The current system of accountability need only be enhanced and funded, as described below, to satisfy the Court mandate.

 

Funding these recommendations does not involve State Aid to school districts and therefore they are not included in the Regents school aid proposal.  They are described here because they complement the Regents aid recommendations and are important to realizing the goals of closing the student achievement gap.  The Regents and State Education Department will advance funding to support these recommendations as separate budget requests.

 

New York State’s current system of accountability establishes a framework that recognizes the dual responsibility of local districts and the State to ensure that public dollars are spent effectively to provide all students the opportunity for a sound basic education.  It is comprehensive, rigorous and it works.  The system has resulted, for example, in improvement overall in English language arts and mathematics achievement since 1999 and in a decline of the number of extremely low-performing schools in the State.  Approximately 70 percent of New York State schools now achieve Adequate Yearly Progress (“AYP”) under the NCLB.  The system responsible for this progress identifies low-performing schools and districts and imposes a series of graduated actions at the local level and interventions at the State level to improve student achievement.  Where results do not improve, consequences follow.

 

A.              School Accountability

 

Under the present system, the Commissioner of Education evaluates schools on a continuum of criteria to determine if they are in good standing or will be subject to intervention.  When a school performs below the State standard in English language arts or mathematics, the district is required to develop and implement a plan to improve student results.

 

In addition to assessing whether schools are achieving State learning standards, the Commissioner also determines annually whether every public school and district is making AYP in English language arts and mathematics at the elementary, middle, and high school levels.   When a school fails to make AYP for two consecutive years, the school is identified as either a School in Need of Improvement (“SINI”) if the school is subject to sanctions under Title I of the NCLB, or as a School Requiring Academic Progress (“SRAP”) if the school does not receive Title I, Part A funds and therefore is subject solely to the requirements of the Regulations of the Commissioner of Education.  Among other things, these schools must develop a two-year school improvement plan that is annually updated.  In addition, SINI schools are required to offer parents the option to transfer their children to other public schools within the district.

 

Once the Commissioner identifies schools as needing improvement or academic progress, a series of increasingly rigorous sanctions is triggered if failure continues.  Schools designated as SINI that fail to make AYP must offer eligible students supplemental educational services.  In addition, school districts are required to initiate one of several corrective actions for schools designated as needing improvement or academic progress that fail to make AYP for a second year.  When a school has failed to make AYP for four consecutive years after being identified as a school needing improvement or academic progress, the Commissioner requires the district to restructure or close the school.

         

The Commissioner also identifies for registration review schools that fail to make AYP and are farthest from State standards and most in need of improvement.  Once identified for registration review, the Regents assign the school performance targets that it is expected to achieve within a specified time or risk having its registration revoked.  After being placed under registration review, the school is visited by an external team that audits planning, resources and programs.  The school uses the report of the external team to develop a comprehensive education plan, and the district uses it to develop a corrective action plan.

 

School districts, Regional School Support Centers, distinguished educators, and SED staff provide schools that are identified for improvement with additional assistance and support.  In general, the State Education Department focuses its efforts on Schools Under Registration Review (“SURR schools”). Regional School Support Centers and distinguished educators provide critical support to schools designated as SURR and SINI.

 

B.              District Accountability

 

In addition to individual school accountability, the State Education Department is also responsible for determining whether each school district achieves AYP.  As in the case of schools, school districts that fail to make AYP for two consecutive years are designated as Districts In Need of Improvement (“DINI”) and must develop district-wide improvement plans. Pursuant to the No Child Left Behind (NCLB) Act,