Defining supplement not supplant

Franklin’s proposed policy on donations of non-budgeted funds (policy KCD) is the subject of two prior posts (#1 and #2).  In this post, we address the supplement not supplant langauage.

The proposed policy would encourage and welcome future giving, but only to the extent that the donations supplement rather than supplant – take the place of — the operational budget. The “supplement not supplant” language mirrors federal education laws which dictate that school districts may use federal funds only to supplement and, to the extent practical, increase the level of funds that would, in the absence of the federal funds, be made available from non-Federal sources for the education of participating students.

On the local level, under the proposed policy, once the School Committee has set its budget for operations based on available public funding sources, it would not accept donations targeted to preserve particular academic programs or operations. For instance, if the budget allocations provided by the town, state, and federal governments forced the School Committee to eliminate a foreign language offering at any level, among other programmatic cuts, donations from private sources to reinstate that program would not be accepted. That is, the School Committee would not permit a practice where advocates for particular disciplines can go out and raise money, while other disciplines which are no less worthy don’t get supported because they don’t have wealthy benefactors.

The School Committee has, and will continue to, accept donations for supplemental services such as field trips, cameras, Smart Boards, and other services, items or supplies that are not tied to the core academic responsibilities of the district. These are things that supplement, rather than supplant, the budget.

For further reading on this topic, I urge you to consider the following:

The National Association for the Education of Young Children defines the phrase “supplement not supplant” as follows:

A requirement in law that a grant recipient may not use those grant funds to replace other sources of funding. For example, the statute may state that federal funds may not supplant any local, state or private education funding sources. The NAEYC glossary of financial terms can be viewed by clicking here.

Tennessee published a “supplement/supplant” definition which can be viewed by clicking here. The definition from that document states:

Under the Federal “supplement not supplant” requirement, the Tennessee Department of Education and Tennessee LEAs may use Federal funds only to supplement and, to the extent practical, increase the level of funds that would, in the absence of the Federal funds, be made available from non-Federal sources for the education of participating students. In no case may a school district use Federal program funds to supplant—take the place of—funds from non-Federal sources.

Supplement not supplant provisions generally operate the same way for all programs. Supplanting is presumed to occur in the following instances:

• The local educational agency or school district uses Federal funds to provide services that it is required to make available under other Federal, State or local law.
• The agency or school district uses Federal funds to provide services that it provided with non-Federal funds in the immediate prior years.
• The agency or school district uses Title I funds to provide services for eligible childrenthat it provides with non-Federal funds for other children. The law does permit agencies or districts to exclude State and local funds expended for any school that operates as a schoolwide program school under section 1114, and for any school or school attendance area as part of a State or local program that is very similar to Title I (comparable program provision).

The Federal government requirements for “supplement not supplant” are set out here.

Continuing the dialog on policy KCD

In the continuing debate over the proposed policy on the donation of non-budgeted funds, I thought it would be helpful to provide you with additional resources on the topic. We have assembled a list of articles which discuss the topic, which, at best, can be described as a delicate balancing act. You can get an index of these articles and other documents of interest by clicking here. This is a continuing discussion from the original blog post on the proposed policy which can be viewed by clicking here.

In the article entitled The New Fundraising from the American School Board Journal, the author discusses school foundations, private fundraising, and whether they are compromising equity or saving public schools.

In the article entitled Gathering Storm from the American School Board Journal, the author highlights the soaring costs in school budgets nationwide, driven by increases in fixed costs such as health insurance, pensions, and new regulations. Not to be missed in this discussion is the Massachusetts Department of Education’s (DOE) recent report on fiscal conditions for schools which can be viewed by clicking here. In that report, the DOE noted that:

Over the past decade and a half, the Commonwealth has moved steadily to increase expectations on school districts, schools, teachers, and students to meet the demands of a global economy. It has also added fiscal resources to support reaching these expectations, increasing state aid for education by almost 11 percent per year throughout the 1990s. Recent fiscal challenges at the state level, however, coupled by rising fixed costs and shifting enrollment patterns for districts, have combined to create substantial challenges for districts in sustaining the momentum of education reform.

In the article entitled A Balancing Act from the American School Board Journal, the author discusses how school districts can find the right balance between corporate support and commercial infringement when dealing with the issue of advertising in schools.

Finally, we have included some articles from the Lakeshore Weekly News and Boston Globe which address the issues at stake. In the article entitled Public Schools, Private Donations, the author warns that:

The success of public schools should not rely on private donations. Class divisions already exist in public schools. Communities that cannot rely on parents’ personal income to subsidize their students should not be punished for it. To further stratify success is to go down a road that will rot the public school system.

In an article entitled What Taxes Don’t Cover, the author discusses private fundraising in Massachusetts’ schools, and offers the following:

But some education specialists say public schools’ increasing reliance on private donations dilutes efforts to increase school funding and widens the gap between schools in wealthy and poor communities. Arnold Fege , director of public engagement and advocacy for the Washington, D.C.-based Public Education Network, which tracks private fund-raising efforts for public schools, said budget pressures brought on by the advent of high-stakes testing under the federal No Child Left Behind law has pushed parent groups and education foundations to intensify their fund-raising.

“It’s a surrogate form of tax revenue that creates huge equity problems,” he said. “Schools become a charity rather than a public service,” he said.

You can read another Boston Globe report by clicking here. Also, the New York Times did a report on deep pocketed partners for public schools which can be viewed by clicking here. PTO Today magazine published an article on the topic, raising questions about the equity of private donations. It can be viewed by clicking here.

All of this brings me back to the bottom line purpose of the proposed policy, which is to encourage supplementation of school budgets, but discourage funds to supplant the operations decisions. This type of policy is particularly important in tough fiscal times. In cash-strapped school systems around the state, it is common for parents to raise money for extracurricular activities, equipment, and extra supplies. But when the fundraising turns to an academic, rather than extracurricular, program, many public school educators feel the line has been crossed as to what is acceptable. Without a policy such as this, advocates for particular disciplines can go out and raise money, while other disciplines which are no less worthy don’t get supported because they don’t have wealthy benefactors.