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BILL: SB 84 TITLE: Teacher Degree Apprenticeship DATE: March 27, 2024 POSITION: Favorable COMMITTEE: House Ways and Means Committee House Economic Matters Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four Maryland local school superintendents, supports Senate Bill 84. This bill establishes the Teacher Apprenticeship Startup Grant Program administered by the Maryland Department of Labor (MDL) to (1) provide opportunities to begin a career in education in the State to high school students, college students, and career changers; (2) develop a cohort of individuals qualified to work as paraeducators and teachers in the State; and (3) encourage local boards of education to hire apprentices. MDL may award up to $225,000 to a sponsor for development and launch of a teacher apprenticeship program from State or federal funds. A program sponsor must establish a multi-year registered apprenticeship program that develops a career path, such that level one is a tutor, level two is a paraeducator, and level three is a teacher. Local superintendents support the General Assembly's assistance and efforts to address the critical shortages of qualified teachers and school personnel. The teacher shortage in Maryland is well-documented and dire. According to the MSDE 2022-2023 First Day of School Vacancy Data Collection, there were 2,572 total vacancies, with the highest number in special education (581); these vacancies vary significantly across LEAs due to local recruitment and retention efforts. Additionally, enrollment in teacher preparation programs has increased since 2017 but is still 2,300 enrollees short of the 2012 levels (Source: Title II Annual Teacher Preparation State Report).  More alarmingly, teacher attrition has increased from 9.1% in 2014 to 11.2% in 2023, representing over 7,000 educators who did not return to teaching in the 22/23 school year. Lastly, the issuance of conditionally certificated teachers has increased by 136% over the last five years (MSDE - Updates on the Maryland Educator Workforce; 9-12-23 before the House Ways and Means Committee). PSSAM supports a strong apprentice model that will give students a head start on the teacher profession in a supportive academic environment for learning and hands-on teaching. When developed appropriately, apprenticeships offer a sequence of academic and occupational courses, career development, and work experience to prepare students to begin careers and to pursue lifelong learning. “In the classroom” teaching and support helps students integrate academic knowledge and occupational competence to enable students to develop the critical thinking, problem solving, employability, and technical skills required to meet the needs of a teacher in the modern classroom. Currently, twenty-three local school systems are administering very successful Grow Your Own programs with the potential to yield more than 300 teachers, 100 new paraprofessionals, and support more than 400 conditionally certificate teachers to pass license exams. PSSAM believes SB 84 will aid these existing efforts to strengthen the teacher pipeline and serve as a key resource for recruiting and supporting a more diverse workforce. The Teacher Apprenticeship Program will also help to support and highlight the benefits of teaching in the context of the Blueprint for Maryland’s Future that promises increased starting salaries, clear pathways for upward mobility, and leadership growth. For these reasons, PSSAM supports Senate Bill 84 and requests a favorable report.

BILL: HB 1237 TITLE: Early Childhood Education - Publicly Funded Prekindergarten Programs - Alterations DATE: March 27, 2024 POSITION: Favorable with Amendments COMMITTEE: Senate Education, Energy and the Environment Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four Maryland local school superintendents, supports House Bill 1441 with amendments. This bill proposes numerous changes related to publicly funded prekindergarten programs, but most importantly, it would extend funding for the very successful Prekindergarten Expansion Grant Program through FY 2029. One of the bedrocks of The Blueprint for Maryland’s Future is the expansion of public and private prekindergarten programs. In fact, the expansion of seats, and improvements in Kindergarten Readiness Assessment (KRA) scores have been one of the most celebrated early victories in many school systems. PSSAM deeply appreciates the sponsor’s comprehensive efforts to address many of the implementation challenges in Pillar I - Early Childhood. We believe this legislation is greatly improved but we hope the committee will consider the following suggested amendments. In order to accomplish ambitious prekindergarten goals, the Blueprint established a complex, yet innovative mixed delivery model employing both public and private prekindergarten providers. The goal is a 50/50 system, with the local school systems responsible for recruiting private providers. To date, the participation of private providers has been slow to materialize, with many of the barriers to participation beyond the control of LEAs. It is important to note that LEAs are not the credentialing authority for private providers, and have very little, to no control over the financial viability or operations of these private businesses. In an effort to address this slow rate of participation, HB 1441 establishes mandated rates of 10% per year in the growth of private PreK seats. We strongly request an amendment to reasonably reflect the essential partnership between the State, private providers, and local school systems in meeting this goal. Therefore, we ask the committee to consider the following language: on page 6, in line 25, after “shall,” insert “MAKE REASONABLE EFFORTS TO”. In keeping with this sentiment of partnership, we ask that the following language be struck: lines 19-22 of page 7, which would indicate to the casual, or even educated observer, that the inability to attract private providers to this model is the result of local school systems “not fully embracing the mixed delivery system.” We also request that the committee strongly consider removing the proposal for MSDE to develop a career ladder for private PreK providers and their employees. LEAs have been struggling with the development and negotiations of the career ladder mandated in the Blueprint for the last two and a half years. While this has been an extensive and complicated implementation effort, we are well situated to work with our union partners. There is no such infrastructure for the development of a career ladder system for the private sector, and we are deeply concerned about the diversion of limited staffing and financial resources from MSDE to assist the private sector in such a significant undertaking. We appreciate the Committee’s consideration of our recommendations and suggestions, and request a favorable with amendments report.

BILL: HB 1386 TITLE: Education - School Employee Anti Bias Training - Requirements DATE: March 27, 2024 POSITION: Oppose COMMITTEE: Senate Education, Energy and the Environment Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four Maryland local school superintendents, opposes House Bill 1386. This legislation requires the State Department of Education, in consultation with the Professional Standards and Teacher Education Board, to develop guidelines for an anti-bias training program for school employees. Further, it requires local school systems to provide training that is job-embedded, paid professional development provided during non teaching time; to the extent practical, be offered in a peer-to-peer setting, take half a day or less and incorporate lessons from local incidents. PSSAM strongly supports the sentiment behind this legislation but opposes the overly prescriptive requirements in the bill. All school systems have some professional development that include elements and topics described in this bill. In fact, many systems have a staff position whose sole responsibility is to incorporate concepts of diversity and equity in student and professional development curriculum. This bill’s omnibus, one-size-fits-all approach does not recognize the extraordinary efforts currently underway in the LEAs, and instead layers on a tremendous amount of new training that will be incredibly expensive to implement. In addition, the legislation requires that training is created and developed in conjunction with staff and teachers. This is not a bad practice per se, but completely disregards our local flexibility to negotiate these types of activities with our bargaining units, along with any other number of locally identified priorities. This legislation also does not recognize the existing, competing professional development requirements with which we must comply. Nor does it contemplate or acknowledge that some of these existing programs would be edged out or diminished to allow for this extensive new training. One of our largest school systems estimates that this legislation could easily cost over $600,000 and would require a minimum of 5 additional specialists . This is in addition to their existing office of equity that already does much of this work, but not in the very prescriptive manner required in the bill. In addition, this estimate does not account for costs that might be needed to engage consultants, as necessary, to reconfigure their internal team responsible for implementation. In fact, this system has only been able to sustain their current high level of equity programming due to the generous support of philanthropic funders. They, along with every other LEA, does not have the infrastructure or fiscal resources to sustain the new requirements every two years for the vast number of employees who would be impacted by this legislation. Again, PSSAM supports the goals of this legislation and is happy to work with the sponsor in the interim to provide an inventory of existing training on these topics to more holistically identify gaps in local professional development. For these reasons, we oppose HB 1386 and request an unfavorable report.

BILL: HB 1237 TITLE: State Department of Education - Task Force to Study the Maryland Online Special Education System DATE: March 27, 2024 POSITION: Favorable with Amendments COMMITTEE: Senate Education, Energy and the Environment Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, supports HB 1237 with amendments. This bill establishes the Task Force to Study the Maryland Online Special Education System and provides for membership of the task force. The Maryland State Department of Education (MSDE) must staff the task force, which must study the system that includes both the Maryland Online Individualized Education Program (MOIEP; IEP) and the Maryland Online Individualized Family Service Plan (MOIFSP; IFSP). The task force must (1) study the effectiveness, functionality, and usability of the Maryland Online Special Education System; (2) determine the availability of other platforms and how other platforms compare to the current system in terms of effectiveness, functionality, usability, and cost; (3) evaluate the costs of maintaining or upgrading the current system or purchasing or leasing another platform; and (4) make recommendations to maintain and upgrade the system or replace the system with another platform as determined by the task force. PSSAM supports any initiatives to alleviate the paperwork for special educators. The increasing burdens of this administrative work is one of the top reasons cited by special teachers for moving to general education classrooms or leaving the profession altogether. According to MSDE, the State Superintendent is committed to addressing the concerns in this bill via an existing IEP User/Workgroup that meets quarterly to obtain stakeholder feedback on the Maryland Online IEP System and the IEP document form and format. Many of the current participants are the same stakeholders that are identified in this bill, and more. PSSAM is aware of this group and this Superintendent's commitment to moving the work forward. Therefore, we ask that the Committee amend the bill to remove the creation of a new Task Force but retain the report required by the Department. For these reasons, PSSAM requests a favorable with amendments report for HB 1237.

BILL: HB 558 TITLE: Primary and Secondary Education - Comprehensive Health Education Framework - Established DATE: March 27, 2024 POSITION: Oppose COMMITTEE: Senate Education, Energy and the Environment Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four Maryland local school superintendents, opposes House Bill 558. This bill requires the Maryland State Department of Education (MSDE), in consultation with the Maryland Department of Health (MDH), to develop a comprehensive health education framework that includes, at a minimum, specified topics. Each local board of education must create an age-appropriate curriculum that is consistent with the comprehensive health education framework as specified. PSSAM strongly supports the current local approach to implementation of health curriculum consistent with State guidelines. PSSAM also shares concerns raised by local school boards and other advocacy organizations regarding legislative efforts to codify standardized curriculum, assessments, or standards. PSSAM maintains our longstanding position regarding curricular mandates, which highlights the critical nature of preserving local authority and oversight. Each Maryland local school systems must be afforded flexibility in developing curriculum that best reflects the specific, and diverse needs of their student population and local community. Again, local superintendents support robust and comprehensive instruction in health education, and believe that this objective is best accomplished by preserving local flexibility in implementing health curriculum. For these reasons, PSSAM opposes House Bill 558 and kindly requests an unfavorable committee report.

BILL: SB 579 TITLE: Primary and Secondary Education – Breakfast and Lunch Programs – Universal Expansion DATE: March 27, 2024 POSITION: Favorable COMMITTEE: House Ways and Means Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, supports Senate Bill 579. This bill requires the Maryland State Department of Education (MSDE) to report to the General Assembly on the cost to provide free breakfast and lunch to all students in public schools in the State by December 1, 2024. MSDE must consider the following for each county in determining the cost, including the current rate of providing free breakfast and lunch through (1) Maryland Meals for Achievement; and (2) participation in the U.S. Department of Agriculture (USDA) Community Eligibility Program (CEP). Also, in determining the cost, specified data by county must be considered and must be disaggregated by (1) elementary, middle, and high school; and (2) breakfast and lunch. PSSAM supports this legislation as a hopeful precursor to a future universal State-funded breakfast and lunch program. Based on our experiences during Covid in feeding students and families, we are extremely confident that all twenty-four local school systems will be able to implement such an ambitious program effectively and efficiently; however, local funding would not be able to support such an expansion. Hopefully, this report will help create a roadmap for funding and implementing such a program in the future. For these reasons, PSSAM supports Senate Bill 579 and urges a favorable report.

BILL: SB 797 TITLE: Education - Access to Attorneys, Advocates, and Consultants for Special Education Program and Fund - Established DATE: March 27, 2024 POSITION: Favorable COMMITTEE: House Ways and Means Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, supports Senate Bill 797. This bill establishes the Access to Attorneys, Advocates, and Consultants for Special Education (AAACSE) Program administered by the Maryland Volunteer Lawyers Service (MVLS) and the AAACSE Fund, administered by the Maryland State Department of Education (MSDE). The AAACSE Program directs resources and services to eligible students to provide access to legal, advocacy, and consultant services. Eligible students are those with a disability whose parent (1) meets household income guidelines established by MVLS and (2) made at least one attempt to resolve a disagreement with a public agency regarding the child’s special education services or program. Beginning in fiscal 2026, the Governor must include $1.0 million to the AAACSE Fund in the annual budget bill. Local superintendents consistently place top priority on providing special education services to our students.  We strive to ensure that our students receive high quality special education programs and instruction that will meet their individual needs. We work diligently to adhere to comprehensive federal and state requirements to serve our special education students. PSSAM supports the innovative nature of this legislation and is very pleased with the changes made to the bill including the definition of “advocate” to provide quality control on who is being paid to speak for, or represent, some of our most vulnerable students. Similarly, we are pleased to see the inclusion of more specific requirements and criteria regarding training for attorneys, advocates and consultants to ensure that they are knowledgeable on all aspects of state and federal special education regulations and statutes. According to our special education directors, a misinformed advocate or representative can do serious damage to the delicate and deliberative process of ensuring the most appropriate special education services. Lastly, we are strongly supportive of the bill’s removal of the initially proposed reporting requirements by LEAs. We appreciate the committee’s recognition that those proposed requirements are not related to the work of the new Program or Fund. In addition, they are largely duplicative of other special education reporting, and do not have a clear purpose or rationale for inclusion in this bill. Special educators are responsible for important medical billing and related administrative functions that require accurate data recordation and meaningful reports that are shared with families on a formal basis each quarter and on an informal basis throughout the student's tenure with the school system. These existing reports allow the school team and parents to effectively understand student needs, track progress, and pivot practices and strategies for success. The bill’s initially proposed reporting requirements did not enhance this process and are appropriately amended out of this bill. PSSAM supports a special education system that respects the dedication and professional expertise of special educators and school administrators to develop, in collaboration with parents, individual education programs (IEPs) to identify and determine the most appropriate services for students. PSSAM welcomes the additional services Senate Bill 797 will provide to our special education students and families. For these reasons, PSSAM requests a favorable report on Senate Bill 797.

BILL: SB 1077 TITLE: Public Schools - Appropriations for School Safety Expenditures - School Security Employees DATE: March 27, 2024 POSITION: Favorable COMMITTEE: House Appropriations Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, supports Senate Bill 1077. This bill authorizes the annual appropriation to the Safe Schools Fund to provide grants to local school systems or law enforcement agencies to assist in providing adequate law enforcement coverage for public schools, from $10.0 million to $15.0 million in fiscal 2026, and to $20.0 million in fiscal 2027 and each year thereafter. The bill also (1) expands the authorized uses of the grant funds to include school security employees and (2) requires the Maryland Center for School Safety, the State Department of Education, the Maryland Coordination and Analysis Center, and the Interagency Commission on School Construction jointly to review and provide guidance on the state of physical security in schools. PSSAM appreciates the bill as amended to revert to the current model using the number of schools, rather than the initial proposal based on enrollment. The current model recognizes that school safety requires a campus deployment strategy and is a more equitable funding formula. Also, we support new bill provisions that require a joint review and subsequent recommendations on the improvement of physical security in schools by key State entities. In 2018, the General Assembly passed the Safe to Learn Act and created a comprehensive initiative for the improvement of school safety, including the creation of the Safe Schools Fund to be administered by the Maryland Center for School Safety (MCSS). While local districts are in need of additional funding for school safety, the existing prohibition on using the funds for school security employees has resulted in lower usage of the Fund; this is reported in the fiscal note as expenditures of $6.2 million of the $10.0 million mandated appropriation in FY ‘23. The authorization under this legislation will greatly enhance the demand and usage of the entire Fund. For these reasons, PSSAM supports Senate Bill 1077 and requests a favorable report.

BILL: SB 1091 TITLE: Education - Blind and Visually Impaired Students - Textbook Equity DATE: March 27, 2024 POSITION: Favorable COMMITTEE: House Ways and Means Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, supports Senate Bill 1091. This bill requires, by January 1, 2025, publishers that sell pupil edition textbooks in the State to provide an electronic file of the textbook in a specified standard to the National Instructional Materials Access Center. It further requires local boards of education to, by March 15 of each year, determine the instructional materials that will be used in the upcoming school year by students with individualized education programs (IEPs) and 504 plans under the federal Rehabilitation Act of 1973. A local board must coordinate with the Instructional Resources Center (IRC) to provide the instructional materials in a specialized format to students who are blind or visually impaired, no later than the first day of classes of the upcoming school year. If a local board is unable to fulfill these requirements, the local board and the family of the student must develop and agree on a plan to remedy the delivery of the instructional materials no later than 45 days before the first day of classes of the upcoming school year. The Maryland State Department of Education (MSDE) must provide specified support to the IRC and cover the cost to produce certain instructional materials under certain circumstances. PSSAM supports the purpose and intent of Senate Bill 1091 to ensure accessibility for vision-impaired students to textbooks and other instructional materials. PSSAM believes that each student should have high quality and accessible instructional materials, and all Individualized Education Plans (IEP) and 504 plans that account for specialized materials should be met with expediency and accuracy. PSSAM thanks the sponsor, advocates, and committee for working together on the house version of this legislation and amending the bill in its current form. PSSAM supports a special education system that respects the dedication and professional expertise of special educators and school administrators to develop, in collaboration with parents, individual education programs (IEPs) to identify and determine the most appropriate services and learning materials for students.  With the bill in its current form, PSSAM welcomes the additional services Senate Bill 1091 would provide to our special education students and families. For these reasons, PSSAM supports Senate Bill 1091 and requests a favorable report.

BILL: HB 1082 TITLE: Blueprint for Maryland’s Future Implementation – Funding and Independent Evaluation – Alterations DATE: March 26, 2024 POSITION: Support COMMITTEE: Senate Budget and Taxation Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, supports House Bill 1082. This bill would provide a $150,000 State grant to each Local Education Agency for each fiscal year for the salary and benefits for Blueprint Implementation Coordinators (IC) in each Local Education Agency (LEA). The bill also extends the date for an independent evaluation of the implementation of the Blueprint. In the final version of the Blueprint legislation (HB 1300/2020), the Legislature required each local governing body and the LEA to jointly designate a Blueprint Implementation Coordinator for each district. This position was required through fiscal 2025, which was subsequently changed to fiscal 2026 during the 2021 session (HB 1372). The IC position was also mandated without an identified funding source. Lastly, the position was to be created by July 1, 2021 and all LEA were in compliance within one or two months of that deadline. In July of 2021, the role of the coordinators was unclear, and many districts assigned this responsibility to existing staff. Now, two and a half years later, many of the coordinators are still wearing multiple hats in their districts, and have significant responsibilities in addition to the Blueprint work. This is especially challenging in smaller districts with fewer staff and resources. For example, among the ICs there are Chief Financial Officers, Chiefs of Staff, Chief Academic Officers, Directors of Assessment and Reporting, and Chief Innovation Officers. PSSAM started convening the ICs in 2021 with monthly implementation and planning meetings. As the AIB was named, and the new State Superintendent was settling in, implementation began in earnest. Last year at this time, we calculated ICs required attendance at roughly 71 meetings; since last year, we have easily doubled that amount and are only calculating obligations at the state level; local outreach and implementation efforts likely rival those figures. Implementation Coordinators have been responsible for dozens of mandated reports to the State, as well as presentations and training sessions within their districts and to the public. The commitment to the Blueprint work has been immense and led by the ICs and their superintendents. The designation of ICs has created an equity issue between small and large systems. Even after adjusting for the enrollment of the districts -- the planning and implementation requirements are the same – whether you are a district with 200,000 or 2,000 students. As we have moved through the initial two years of the Blueprint, it is exceptionally clear that these ICs are integral for implementation with fidelity. We recognize that many staff in our districts are overworked and overburdened, but we feel it is appropriate to request a carve-out for the salaries of the ICs, especially since the General Assembly mandated the position. We believe a line item in the budget would provide an equitable funding opportunity for all districts to hire and employ a full-time IC for successful implementation of the Blueprint for Maryland’s Future. For these reasons, PSSAM supports House Bill 1082 and requests a favorable committee report.

BILL: HB 428 TITLE: Community Schools - Rental Assistance for Community School Families Program and Fund - Establishment DATE: March 26, 2024 POSITION: Support with Amendments COMMITTEE: Senate Budget and Taxation Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, supports House Bill 428 with amendments. This bill creates the Rental Assistance for Community School Families Program to provide rental assistance to eligible student households; it requires the Department of Housing and Community Development, in consultation with the State Department of Education, to administer the Program and establish the Rental Assistance for Community School Families Fund. PSSAM strongly supports the creation of this Fund and the recognition of community schools as important conduits to serve our neediest families; however, as currently drafted the bill requires community schools coordinators identify eligible students and facilitate direct payments for rent and utilities to families. This is way outside of the scope of work for community-based practitioners who are in schools to provide wraparound supports and establish trusting environments for families. Any housing assistance is most appropriately administered by county and state housing departments who regularly assist families with these intimate financial details and should be handled outside of any relationships with school personnel. We strongly advocate for the removal of local school personnel, namely the community schools coordinators, from playing any implementation role in this new program except for providing information and referrals as appropriate. We request the bill be amended as follows: Page 3, new line 30-31: (IV) Providing information about the availability of the rental assistance program to families, including eligibility requirements, and how to apply. Page 7, strike lines 12-15 and replace with: (F) Upon request, a local school system shall provide verification of student enrollment, and inclusion in the compensatory education enrollment, or eligibility for McKinney Vento Assistance. The first amendment ensures that the dissemination of information regarding this program reaches community school families. The second amendment ensures best practices regarding financial privacy for families by verifying eligibility through established procedures regarding income verification at the district level, keeping it as far away from the relationship between families and their school communities and school personnel. For these reasons, PSSAM requests a favorable with amendments committee report for House Bill 428.

BILL: HB 200 TITLE: Community Schools - Alterations DATE: March 26, 2024 POSITION: Support with Amendments COMMITTEE: Senate Budget and Taxation Committee CONTACT: Mary Pat Fannon, Executive Director, PSSAM The Public School Superintendents’ Association of Maryland (PSSAM), on behalf of all twenty-four public school superintendents, supports House Bill 200 with amendments. The establishment and expansion of community schools has been one of the most impactful and successful initiatives in the implementation of Blueprint for Maryland’s Future. PSSAM is pleased to see the exponential growth in community schools and the corresponding academic improvements, and positive community impact. While we appreciate the hard work put into both versions of this legislation, we do not support the House bill’s provisions that strike allowing districts with less than 40 schools to use some of their Concentration of Poverty Grant (CPG) to manage district wide community schools initiatives. We strongly support the Senate bill’s (SB 161) authorization for use of the Concentration of Poverty Grant (CPG) to expend up to 15% of personnel grant and per pupil grant funds on behalf of eligible schools, provided that a plan to meet specified current law requirements is submitted to the Accountability and Implementation Board (AIB). This set aside will ensure the totality of the CPG funds are used with fidelity, and that the appropriate staff are managing this essential funding and procurement functions, not putting management and fiscal burdens on the local community schools coordinators. We request that the development of spending plans for the 15% funding and the evaluation criteria be developed in consultation with the LEAs, AIB and the MSDE, and not prescribed in the bill and statute. The development of metrics and objectives should be created through regulations in collaboration with practitioners to most accurately reflect the goals and objectives of the community schools’ pedagogy. Lastly, since these plans and evaluations will ultimately be public documents, they need to be carefully crafted to remove student and family identifiers and should be vetted and established in regulations, not statute. Allowing districts with less than 40 schools to use some of their grant funding to manage the program will yield tremendous economies of scale and enhance best practices and cooperation among these smaller cohorts. Federal Title programs have long acknowledged the need to set aside funding for administrative tasks, such as budgeting, contracts and grant writing, to support the hands-on work. Centralizing and supporting these tasks at the district office will allow school coordinators to concentrate on engaging families, supporting students, and collaborating with community partners. The following example from Harford County Public Schools illustrates the importance of allowing funding to be used for centralized support. Currently, their ten community schools have a combined budget of $3,957,841 with no dedicated coordination or support. In the near future, their community schools budget is expected to exceed their Title 1 budget, which currently has 6 district-support professionals. Making this much needed adjustment is extremely important to ensure funding is used efficiently and effectively. We also support appropriate oversight and evaluation of the community schools with a standard needs assessment developed by the State Director of Community Schools, in consultation with local school systems and members of the community schools’ leadership team. However, we do not support expanding any authority given to the Maryland State Department of Education (MSDE) to modify or approve the needs assessment. We support the current law’s requirement of the creation and approval of an implementation plan for a community school, but believe the expanded annual evaluation is overly onerous. If the committee feels an evaluation is needed, we request and support a triennial evaluation instead.  However, it is important to note that these schools also undergo periodic audits to ensure that funds are being spent appropriately and in accordance with their implementation plans. Further, community schools participate in the annual local budget processes so there is continual oversight from the districts as well. For these reasons, PSSAM requests a favorable with amendments committee report for House Bill 200.