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Comments and Letters to Federal Policymakers

NSBA regularly offers input to federal agencies, elected officials, and staff, on issues of importance to public schools. Through our member state school board associations, NSBA offers federal decision-makers practical implications of proposed or current policies on school district operations. Key NSBA comments and letters are posted below.

2022

October 27: NSBA Asks Congress for $1 Billion in Additional Emergency Connectivity Funds
NSBA joined 65 education and related national organizations in a letter to congressional leaders asking for $1 billion in additional funds for the Emergency Connectivity Fund (ECF), which is administered by the Federal Communications Commission (FCC).

The letter notes that the FCC received requests for $2.8 billion in ECF funds during its final application window, which was more than double the amount remaining in the program. “Without additional funding, many of these requests will not be met, leaving millions of students disconnected at a time when learning loss and teacher shortages are leading concerns,” the letter reads. The letter also includes examples of how the program is addressing the critical needs of schools and libraries across the country who are struggling to keep students, teachers, and library patrons connected in an increasingly digital world.

 

September 12: Comment on Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance (Title IX)
NSBA emphasized its dedication to assisting school districts as they develop and implement policies to address discrimination and to promote student rights and offered specific recommendations on the Department of Education’s new proposed rule addressing nondiscrimination on the basis of sex. NSBA noted that the Department’s new proposed rule is the second in two years, appearing as schools return to relatively normal operations in the wake of the pandemic. NSBA urged the Department consider the overarching realities school districts now face, such as unprecedented staff shortages and student mental health challenges, as it considers regulatory changes including the definition of sexual harassment and the “actual knowledge” standard.

July 12: NSBA Urges Congress to Keep STEM Provisions in Competitiveness Bill
NSBA sent a letter to congressional leaders urging they “preserve the Postsecondary STEM Pathways and the Improving Access to Elementary and Secondary Computer Science Education programs as the Senate and House work to resolve differences between the America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength Act of 2022 (H.R.4521) and the United States Innovation and Competition Act of 2021 (S.1260).” The letter notes that increasing funding for postsecondary STEM Pathways and Computer Science grants will "make a meaningful difference for students, schools, communities, and the nation’s economy" while ensuring that students have access to greater opportunities and advancement in science, technology, engineering, and mathematics.

May 23: NSBA Urges Congress to Oppose Vouchers

NSBA joined 40 other organizations in the National Coalition for Public Education in signing a letter to House and Senate appropriators urging them to oppose reauthorization or funding for the school voucher program for the District of Columbia. The letter also urged them to add language, as the House committee has done in previous years, to “require voucher schools to provide the same civil rights protections that public school students receive—including those under the Individuals with Disabilities Education Act (IDEA)—to students in the voucher program.” 

April 28: NSBA Advocates for Mental Health Funding
NSBA joined over 90 organizations in a letter led by the National Association of School Psychologists advocating for investments in mental health grants. The letter urges congressional appropriators to “...address the severe shortages of school-based mental health professionals by providing $1 billion to be divided between the School Based Mental Health Services Professional Demonstration Grant and the School-Based Mental Health Services Grant Program.”

April 21: NSBA Advocates for "Robust" Funding for Title II
NSBA joined a coalition of education organizations in asking congressional appropriators to provide robust funding for Title II. The letter encouraged appropriators to invest in retaining and recruiting teachers, principals, and other school leaders, as well as improving their practice by providing $3 billion for the Supporting Effective Instruction State Grants program, Title II, Part A of the Every Student Succeeds Act (ESSA).

February 8: NSBA Advocates for Increased IDEA Funding 
As Congress negotiates a spending bill for the remainder of Fiscal Year 22, NSBA and several education groups conveyed strong support for a significant increase in the federal investment in special education programs in a letter to House and Senate Appropriations Committee leaders. This action supports NSBA’s resolution to fully fund IDEA. 

February 4: NSBA Advocates for Continued Flexibility for Child Nutrition Programs 
NSBA joined the Food Research & Action Center (FRAC) and nearly 2,000 national, state, and local organizations from every state across the country, in a letter urging Congress to swiftly extend the U.S. Department of Agriculture’s (USDA) authority to issue nationwide waivers for the Child Nutrition Programs beyond the current waivers’ expiration date of June 30, 2022. 

Extensions will ensure schools, youth-serving and community-based organizations, and child care providers have the resources needed to effectively provide meals—no matter what the school day looks like—to close the childhood hunger gap; improve child nutrition and wellness; enhance child development and school readiness; and improve learning, attendance, and behavior. 

 

2021

July 28: Letter to Congressional Leaders Asking for At Least $130 Billion Dedicated to School Facilities in National Infrastructure Package

As congressional leaders engage in negotiations on a national infrastructure package, NSBA urged them to prioritize an investment of at least $130 billion in school facilities to accommodate new school construction, science and technology laboratories, career and technical education facilities, and further repairs and upgrades to building systems, such as HVAC and water systems. NSBA believes that a much-needed investment to help sustain and improve our schools and communities can be achieved by making our students and future generations the priority for the infrastructure package Congress is currently considering.

 
In response to a Request issued by Department of Education’s Office for Civil Rights, NSBA submitted comments discussing the administration of school discipline in schools serving K-12 students. NSBA offered insights on current and previous Department guidance on school safety and discipline, and urged the Department to consider how its guidance and resources could articulate specific best practices that could be adapted to meet the needs and resources of different school communities, rather than a “one-size-fits-all” approach. NSBA also provided views on specific disciplinary policies and practices and stressed the importance of having diverse teaching forces that reflect student populations and communities.

 

June 9: Letter to U.S. Department of Education Office for Civil Rights providing insight, input, and examples from school districts on a number of issues at the forefront of schools’ civil rights effort including the new Title IX regulations, the Civil Rights Data Collection, district-wide compliance reviews, and transgender student rights.

NSBA urged the Department to consider operational realities in K-12 school buildings as it weighs changes to the extensive procedural requirements provided in the new Title IX regulations. NSBA explained that schools are bound by existing sexual harassment procedures required by state and local law and policy, which they must apply in tandem with new federal requirements, that educators need flexibility to address student behavior, taking into account the age, maturity, and developmental stage of the students themselves, and that school officials are concerned about maintaining student confidentiality during investigations. NSBA also provided insights on the Civil Rights Data Collection and district-wide compliance reviews as an enforcement approach, and noted the need for clarity on school officials’ responsibilities to transgender students, especially in the contexts of bathroom/locker room use and athletics.

May 25: Letter to U.S. Department of Education Office of Special Education Programs Re: Pandemic-Related Recovery Services for Students with Disabilities.
NSBA urged the Department to inform states of their ability to use state ARP funds to innovate and create programs at the state level that fund prompt services to children while at the same time preventing prospective litigation.

May 20: Comment on U.S. Census Bureau’s proposed changes to how urban and rural areas are designated.
NSBA urged the Bureau to reconsider proposed changes to the thresholds for the number of housing units and the population count for a community as the changes could result in some communities receiving less resources and losing certain designations that are critical to local economies and services for children and other residents.

April 23: Comment on the Federal Communications Commission’s efforts to implement the Emergency Connectivity Fund provisions and funding included in the American Rescue Act.
NSBA urged the Commission to quickly distribute funds from the $7.17 billion Emergency Connectivity Fund to help close the digital divide in education and give school districts flexibility to distribute them based on local needs.