By David Asato
November 2022
Of all the additional requirements tied to the ESSER III funding, arguably the most confusing, and therefore intimidating, requirement is the Maintenance of Equity (MOEquity).
On December 8, 2021, NDE provided an overview of MOEquity at our monthly TA session, but following this session, things were relatively quiet on the MOEquity end, until the final reporting requirements for the LEA-level Maintenance of Equity (MOEquity) were published in the Federal Register on June 8, 2022. The final reporting requirements provided us with key dates by which MOEquity information needed to be posted to our NDE website:
July 8, 2022 - LEA exceptions, the list of high-poverty schools for FY 2022, and a description of how NDE will ensure non-excepted LEAs meet MOEquity requirements, including information about when NDE will require noncompliant LEAs to describe the adjustments they will make to come into compliance. Nevada Department of Education SY 2021-2022 Maintenance of Equity Data (nv.gov)
November 1, 2022 - LEA exceptions, the list of high-poverty schools for FY 2023, and a description of how NDE will ensure non-excepted LEAs meet MOEquity requirements, including information about when NDE will require noncompliant LEAs to describe the adjustments they will make to come into compliance. Nevada Department of Education Maintenance of Equity Exceptions FY 2023_rev.11.8.2022 (nv.gov)
The good news is that, thanks to all of you, we were able to post the required information to the NDE website by the due dates. This now takes us on to the second set of key dates by which MOEquity information needs to be posted to our NDE website:
December 31, 2022 – MOEquity data for SY 2021-2022 for each non-excepted LEA listed in the July 8, 2022, posting.
December 31, 2023 - MOEquity data for SY 2022-2023 for each non-excepted LEA listed in the November 1, 2022, posting.
As we approach the December 31, 2022 deadline by which we need to post the MOEquity data for SY 2021-2022, as a reminder, the MOEquity provision states that LEAs receiving ARP ESSER funding may not, in FY 2022 (and FY 2023), reduce the combined State and local per-pupil funding for any high-poverty school by an amount that exceeds the total reduction, if any, of combined State and local per-pupil funding for all schools in the LEA. LEAs also cannot reduce the number of FTE staff per-pupil in any high-poverty school by an amount that exceeds the total reduction, if any, of the FTE staff per-pupil in all schools in the LEA. USED has also provided the process and formulas for reporting on pages 15-17, and pages 18-20 of their Maintenance of Equity FAQs - Maintenance-of-Equity-updated-FAQs_12.29.21_Final.pdf.
In order to simplify the process, and to avoid the need for our non-excepted LEAs to do all of the calculations, NDE is currently working on a tool that LEAs will be able to use to identify whether or not their high poverty schools met or did not meet the MOEquity requirements without the need to do all of the calculations. For those who are interested in learning how to use this tool, or learning more about the Maintenance of Equity requirements in general, NDE will be holding a TA session on Wednesday, December 7, from 11:00 am – 12:00 pm. Invites for this session have gone out to all non-excepted LEAs but for anyone else who may be interested in attending, please reach out to me at david.asato@doe.nv.gov. And whether or not you are a non-excepted LEA, or whether or not you are planning on attending the TA session, you are always welcome to e-mail any MOEquity related questions or comments to me. After all, it is arguably the most confusing, and therefore intimidating, requirement tied to the ESSER III funding.