The Joint Legislative Audit and Review Committee (JLARC) has found that the Office of Superintendent of Public Instruction (OSPI) has “not yet established processes to monitor districts’ efforts to address the academic effects of restricted in-person instruction or outcomes of emergency spending”—despite federal and state requirements to that effect.

School districts in Washington received three rounds of federal Elementary and Secondary School Emergency Relief (ESSER) funds. As of the end of Dec. 2022, school districts in Washington have $1.075 billion left to spend. The funds can be used for almost anything, but the federal government specified that $333.9 million must be spent to address learning loss (there is $167.3 million remaining of this amount). There is considerable interest in how these funds are being used and how well they are working—which could help determine the best uses of the remaining funds.

To that end, the federal government required state education agencies to submit plans for their use of ESSER funds. As part of the ESSER award, state education agencies and local school districts are required to comply with any reporting requirements from the federal government, including on “Impacts and outcomes (disaggregated by student subgroup) through use of ARP [American Rescue Plan] ESSER funding (e.g., quantitative and qualitative results of ARP ESSER funding, including on personnel, student learning, and budgeting at the school and district level).” (See appendix B of Washington’s plan.)

Further, by signing the Washington plan, the state superintendent assured that OSPI “will implement evidence-based interventions as required under section 2001(f) of the ARP Act and ensure its LEAs [school districts] implement evidence-based interventions, as required by section 2001(e)(1) of the ARP Act.” (Emphasis added. See appendix C of Washington’s plan.) Both of those sections of the American Rescue Plan Act state that the state education agency and local school districts must use a portion of the third round of ESSER funding “to address learning loss through the implementation of evidence-based interventions, such as summer learning or summer enrichment, extended day, comprehensive afterschool programs, or extended school year programs, and ensure that such interventions respond to students’ academic, social, and emotional needs and address the disproportionate impact of the coronavirus” on certain student groups. (Emphasis added.)

Meanwhile, the state Legislature enacted ESHB 1368 in 2021. The bill, in Sec. 12(3), required school districts to submit “academic and student well-being recovery plans” to OSPI, “to address student needs that are anticipated due to school closures and extended time in remote learning mode due to the COVID-19 pandemic.” Further, the bill requires schools to “report progress on implementing the plan in a manner identified by the office of the superintendent of public instruction. The plan must, at a minimum, address learning loss among students.”

Nevertheless, JLARC’s preliminary report, released this month, found that OSPI has not met the monitoring requirements. After reviewing the school district recovery plans, JLARC found that 94% of districts planned to use funds for social-emotional learning and mental health supports, 72% planned to use funds for summer school, 62% planned to use funds for additional instructional time before or after school, and 42% planned to use funds for tutoring. However, JLARC found that OSPI has not created a way for schools to report their progress on implementing these plans or to measure spending outcomes. As JLARC notes, this means that “there is limited information available about whether districts are achieving their goals or if they are addressing racial disparities in education.”

Additionally, JLARC writes that there is no way to tell how much is being spent on specific items, as the accounting categories used by OSPI are very broad. To be clear, the state is reporting how it is spending the federal dollars, but the established accounting categories that the state traditionally uses (e.g., amounts spent on salaries or instruction) and the categories established under federal ESSER rules (e.g., education technology or sanitization) do not allow for the state and public to monitor how much districts are spending on specific interventions (e.g., tutoring). (Further, as I wrote in November, a very large portion of relief spending to that point was categorized as “indirect” or “other.” That post shows what the various categories of spending are.)

Ultimately, JLARC recommends that OSPI “establish a process to monitor school districts’ implementation of their Academic and Student Well-being Recovery Plans, in accordance with 2021 state legislation.”

No agency response is included in this preliminary report (the final report will be out in May), but representatives from OSPI discussed it at a Jan. 4 JLARC meeting. They said, “We do have substantial monitoring of all the funding and we have monitoring in place . . . of both the plan and some of the initial implementation.” They said they have provided this information to JLARC and have not heard back.

If OSPI has—contra JLARC’s finding—established a way for districts to report their progress and measure outcomes, I can’t find any such data available publicly. The OSPI representatives at the JLARC meeting said they have publicly-available dashboards. OSPI does have useful dashboards showing ESSER spending (using the regular, broad accounting codes) and a dashboard showing the academic and student well-being plans. Importantly, though, the dashboard with the plans was last updated June 22, 2021 (when they were initially due from districts). It includes nothing about how much has been spent on each intervention or how the interventions have worked so far.

On Jan. 9, Superintendent Reykdal held a press conference on his priorities for the session. He talked about the federal ESSER funds and seemed to refer to the JLARC findings. He said,

I want to be abundantly clear that every single dollar of federal funds is accounted for in exactly the manner we use in the state of Washington—our accounting codes—and we’re going to continue to report on it and continue to report on that. There are folks who now, after the fact, would like us to report on activity level. How do we know where the tutoring was? How do we know exactly who did the after school supports? How do we know exactly the interventions that were made for students? The state has never accounted in that way, though we are pushing through to try to understand that better. That was not the expectation when these dollars rolled out, and we will support our legislators or anyone else who wants to go further if the investment in that infrastructure is there. We cannot recreate codes, we cannot ask districts to spend tens of thousands of hours imagining and reimagining what they did two years ago with dollars that they spent at the time. We will be very accountable by program and by object and we will do everything we can to give you more detail on the specific activities, but that is a massive transformation in state government and in public education.

(Emphasis added.)

School finance is very complicated in general. Going back and changing accounting codes now would indeed be a huge endeavor. However, saying that calls for more specific categorization are coming “after the fact” is surprising, given that ESHB 1368—which required OSPI to set up a way for school districts to report on their progress on their plans—was signed by the governor Feb. 19, 2021. The third round of ESSER funding wasn’t passed by Congress until March 10, 2021.