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Comments on the Department of Education’s Proposal for Monitoring Maintenance of Equity

All4Ed submitted joint comments to the U.S. Department of Education regarding its proposed data collection to monitor state and district compliance with the Maintenance of Equity (MoEquity) provision of the American Rescue Plan Act.

We, and our partners at the Center for American Progress, National Center for Learning Disabilities, National Urban League, SchoolHouse Connection, Teach Plus, The Education Trust, and UnidosUS, believe that it is important to collect the necessary fiscal and staffing data to help implement MOEquity in a way that minimizes the burden on states and districts while meeting the goals of the provisions in the American Rescue Plan Act. To that end, we recommend that the Department continue to exempt districts that are not cutting funding in any of the covered fiscal years, rather than applying a broad enforcement and data collection effort. We also recommend that the Department consider a longer timeline that would allow for more accurate reporting and require reporting of only the data necessary to understand whether the requirements have been met. Finally, we hope that as the Department implements MOEquity, it continues to effectively monitor and enforce other key provisions in the Every Student Succeeds Act that can also improve resource equity, including ensuring that states are publishing complete and timely school-level spending data on report cards and conducting resource allocation reviews.