Ellen Desmond

While the intent of this bill, further fiscal transparency, is admirable, the language of the bill further confuses the role that federal funding plays in NH school districts. As the Grants Manager for the Concord School District, I oppose this bill as written and offer what I believe is missing context as a means to clarify the opportunities already afforded to the public to weigh in on the implementation of federal funding in our school districts. Formula funding, passed through the NH Department of Education from a federal governmental unit (USED), is not, in fact, unanticipated. Despite a misalignment between the federal fiscal year and our state/local fiscal year, districts include anticipated federal revenue in their local budgets based on prior year allocations and other factors that contribute to the funding formula. Notably, when these federal funds have been allocated by NHED for local education agencies and preliminary awards have been issued (also publicly posted on NHED's website), the Superintendent and School Board Chair are required to certify that General Assurances, which outline obligations of federal funds, have been reviewed by the local board of education. Program Assurances that specify grant-specific requirements are often brought to school boards at this time as well. Each LEA is required to submit to the NHED an application that details use of funds--this plan is developed with stakeholder input, as were the ESSER Use of Funds Plans. For those interested, opportunities to sit on committees or stakeholder teams that analyze data, ascertain need, and support the implementation of best practices already exist. Competitive funding, via NHED or direct from a federal agency, is not well-categorized as "unanticipated" either. Discretionary federal grant applications are extensive; district administrators already must prioritize competitions that align with the school board's strategic goals. Further, these applications--and certainly the awards, if granted--often require letters of support, stakeholder input, advisory boards, or community data; they are not written or carried out in a vacuum. In Concord, we make every effort to unpack the often-complicated required activities language for stakeholders so grant goals and expectations are clear. We update the board, its committees, school staff, and community members on grant progress formally and informally. While I cannot speak for other districts, I know my colleagues act similarly, with fiscal stewardship and long-term sustainability in mind. This bill only adds another layer of administrative "red tape" that will deter districts from applying for federal funds needed to supplement limited state education dollars. Policies and procedures regarding acceptance, implementation, and expenditure of federal funding are best overseen at a local level. If stakeholders do not feel that the RSA as written is being upheld in their communities as transparently as they would like, it would be prudent for them to get acquainted with the mechanisms already in place for their involvement in the receipt and implementation of federal grants. I invite you to contact me to further clarify or with any follow-up questions.