SNS: Ready for Prime Time

March 25, 2011 | By Thompson Education | Post a Comment

(This post was written by Andrew Brownstein, one of Thompson’s federal education policy editors, and originally appeared on Title I-Derland, Thompson’s blog on federal K-12 policy.) When it comes to “supplanting,” the problem is that states and districts are required to apply a test akin to U.S. Supreme Court Justice Potter Stewart’s famous comment about pornography: “I know it when I see it.”

So says attorney Melissa Junge, co-founder of the Federal Education Law Group. “People are scared, so they wind up making easy administrative decisions that might not be good educational decisions,” she said. “There’s this lockdown compliance mentality that has evolved…because it’s a ‘you know it when you see it’ kind of test.”

Still with us? The somewhat snoozeworthy topic of supplement not supplant (SNS) is getting a fresh appraisal thanks to an eye-opening paper written by Junge and law partner Sheara Krvaric, and presented recently for the Center for American Progress (CAP) and the American Enterprise Institute. It has already generated loud buzz at the U.S. Department of Education and on Capitol Hill. Cynthia Brown, CAP’s vice president for education policy, called the paper “historic” and said it “really breaks new ground.” Title I-Derland will be exploring its themes in several posts, with a detailed analysis to come in the May issue of the Title I Monitor. I predict its publication will later be seen as a “shot across the bow” similar to the 2004 paper Marguerite Roza and Paul Hill penned on the deficiencies of comparability, which sparked major momentum to change that provision.

SNS had good intentions. It was added years after the Elementary and Secondary Education Act was passed in 1965. Districts were using Title I money to simply subsidize their general operating budgets, leading to a variety of scandals. In adding the SNS requirement to the statute, Congress made clear that Title I funds are meant to be extra: They provide an additional layer of support for the neediest students and are not meant to substitute for state and local funds.

However, unlike other Title I fiscal requirements, such as comparability or maintenance of effort, SNS focuses on individual goods and services. Are you providing reading coaches in non-Title I schools with state and local funds while funding the same positions  in Title I schools with Title I funds? Bingo! That’s supplanting.

That’s a fairly clear case. But many supplanting scenarios are anything but clear. And that’s when the head-scratching begins. “Instead of being a real fiscal rule, dealing with numbers — and numbers are transparent — it’s a discretionary, psychological, theoretical test: ‘What would you have done in the absence of federal funds?’” Junge said. “Who knows what you would have done? That’s a really hard thing for schools to deal with.”

We’re interested in your thoughts. How much time do you spend on supplanting issues? Is it worth it? Does SNS primarily help to ensure the integrity of Title I funds or does it stifle much-needed innovation? Check this site for upcoming follow-up posts on how SNS works in practice and ways the provision could be improved.


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