Mary Levy Testimony – Roundtable on At-Risk Funding – February 1, 2019

At-Risk Funding Transparency

Mary Levy   –   February 1, 2019

Thank you for holding this hearing, and thanks to the Council members who introduced and who supported this legislation.  Since 1980, I have analyzed public school budgets, expenditures, and staffing to determine where the money goes.  For each of the past five years I have worked with the Coalition for DC Public Schools and the DC Fiscal Policy Institute to analyze local school budgets, especially the use of at-risk funding.

Clearly, each year DCPS has used at-risk funding to supplant funds for other programs, in contravention of the DC Code.  My colleagues and I have documented this practice; the Committee on Education itself has consistently made the same finding in annual Committee reports; and DCPS officials have admitted it in testimony to this Council.  Yet it has continued.

This practice cheats at-risk students by using funds designated to services to support them to instead fund services for which all qualifying students are entitled, regardless of at-risk status.  These services include legally required special education and ELL student services as well as general education services provided to all students in each grade level.  Schools with few at-risk students and little money to take have virtually all of their core program funded with regular funds, while schools with large at-risk enrollments have less per pupil in regular funding.  This is classic supplant rather than supplement.[1]

In addition, our analyses show that this practice is inequitable among schools with similar populations.  The siphoning off of at-risk funds varies greatly among individual schools in any given year; some schools lose most of their at-risk funds to supplanting and others very little.

There already being a law against using at-risk funds this way, the proposed legislation is an important further step in securing more effective services for at-risk students.  I see two main strands:  transparency and an increased role for local schools in determining the best use of the funds.   Transparency in the form of full information both in budget formulation and in reporting on actual use of funds is important and necessary.  Sunshine makes a difference, and the specific provisions here will help prevent the budget fait accomplis that we have experienced, where mis-allocation becomes visible only when it is too late to correct.

Having the plans for use of at-risk funds formulated by principals and Local School Advisory Teams brings in the expertise of those closest to individual students and their needs.  This was part of the original enactment providing at-risk funding, and the Council was right the first time.  The Chancellor will retain the ability to amend inappropriate plans, and the incidence of siphoning at-risk funds off for core program use will probably be eliminated.

Please enact this legislation.



DCPS officials have argued that they cannot afford to fully fund the core program services provided to all students regardless of at-risk status.  More money from the Council would be helpful, but even without it, there are at least three alternatives available:

(a) Rethink general education entitlements: do all students, even the most advantaged, need every single staff/NPS level entitlement?

(b) Reduce funding for programs not based on student need that are available to only a select few schools chosen by criteria unknown. I have a list.

(c) Cut down on central office staff, who are much more numerous and much more highly paid than was the case 12 years ago

As to alternative (c), according to the most recent statistics from Census Bureau fiscal reports, DCPS central office spending in FY 2016 was 10.8% of total current expenditures, compared to the U.S. average of 1.9% percent.  DCPS is spending $2,260 per pupil, which is ten times the US average of $226.[2]  For many years I have categorized DCPS employees by whether or not they serve students directly, which is what most members of the public want to know when they ask about central office or “administration.”[3]   The number of central office full-time equivalent staff performing the same functions that DCPS now performs has risen from 516 in 1981, when we had 95,000 students to 626 in 2007, when we had 52,000, to 797 this year for about 49,000.

Below are November 2019 counts of central office staff with common titles.  Certainly the system needs some number of these people.  Those who are really good are worth a great deal.  But do we really need 45 Chiefs and Deputy Chiefs?  86 Directors?  180 Program Specialists?

Title # of FTEs Title # of FTEs
Chief 14 Program Specialist 180
Deputy Chief 31 Project Manager 73
Director 86 Coordinator 144
Manager 79 Analyst 55
Specialist 84 Program Coordinator 9

If central office were reduced to a more reasonable level, DCPS would not have to appropriate at-risk funds for core program services that are funded with regular funds at schools in well-to-do neighborhoods.

[1] Some alternatives are listed on the reverse of this testimony.

[2] Derived from U.S. Census Bureau, Public Education Finances:  2016, May, 2018 Tables 6, 7 and 19.  These figures are self-reported by DCPS.

[3] The source is lists of DCPS employees, obtained by FOIA or from submissions to the D.C. Board of Education (before FY 2008) or to the DC Council (since FY 2008), based on office of employment, program, job title, purpose of applicable grant funding, and DCPS website descriptions.  Employees performing functions subsequently transferred or contracted out are excluded in the earlier year calculations.


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