As President-elect Biden and Vice President-elect Harris prepare to take office in January 2021, their transition teams are working with advocacy organizations and communities across the country to identify critical policy needs. IDRA sent the letter and recommendations below to the Biden-Harris education transition team, urging the new administration to focus on much-needed COVID-19 relief and policies that promote systemic educational equity. For more information, please contact Morgan Craven, J.D., IDRA’s National Director of Policy, Advocacy, and Community Engagement at firstname.lastname@example.org.
December 4, 2020
Dear Members of President-elect Biden’s Education Transition Team:
The recommendations in this letter are submitted on behalf of the Intercultural Development Research Association (IDRA), a national non-profit organization with the mission of achieving equal educational opportunity through strong public schools that prepare all students to access and succeed in college.
Since 1973, IDRA has advocated equitable and excellent schools for all young people, particularly those from historically-marginalized communities, including students of color, those from families with limited incomes, emergent bilingual students, those who face gender-based discrimination, and immigrant students. These students are disproportionately impacted by harmful systemic inequities within our education and other related systems. IDRA’s guiding principles emphasize excellence, equity and accountability. Equity without excellence is unacceptable, and excellence without equity is impossible.
IDRA’s approach combines research and data analyses; effective educational practices; and community-driven policy recommendations and advocacy campaigns. Additionally, we operate the IDRA EAC-South, one of four federally-funded equity assistance centers. We provide technical assistance, training, equity audits, and coaching to schools, education agencies, and related entities in 11 southern states and Washington, D.C.
IDRA urges President-elect Biden’s administration to immediately prioritize the recommendations below, which focus on several key areas:
- An equitable response to COVID-19 that addresses systemic inequities;
- Research-based funding policies for public schools that emphasize resource equity and opportunities, coupled with excellent outcomes;
- School climate policies that end harmful discipline and policing practices, address systemic racism, protect the civil rights of all students, and support safe and culturally-sustaining schools;
- Funding, programmatic changes, explicit agency guidance, and a national school-based network that ensure excellent educational opportunities for emergent bilingual students; and
- Community engagement strategies that center students and families in proven educational leadership practices.
IDRA looks forward to serving as a resource to the Biden-Harris transition team and administration. Should you have any questions or wish to discuss these recommendations, please contact Morgan Craven, J.D., IDRA National Director of Policy, Advocacy, and Community Engagement at email@example.com.
IDRA Recommendations to Ensure Excellent and Equitable Public Schooling for All Students
Ensure an Equitable Educational Response to COVID-19 in the First 100 Days
COVID-19 has disrupted educational access for millions of students, schools, and families across the country. This disruption has exacerbated existing inequities for historically-marginalized students as it created new teaching and learning challenges. IDRA recommends that Congress and the Biden-Harris administration do the following.
• Immediately allocate emergency relief funds to address projected revenue shortfalls that will impact public schools and institutions of higher education. Federal relief funds can help states minimize or avoid cuts to education budgets. The impacts of these cuts can be long-lasting, particularly in the many states that already underfund their public education systems and for property-poor school districts that rely heavily on state funding to supplement limited local tax revenue sources to meet the basic needs of their students. As states receive additional federal funds, they must be incentivized by the U.S. Department of Education to also use their own emergency (“rainy day”) funds, identify new and stable revenue sources for public education, and prioritize serving historically-marginalized students in their spending.
• Immediately allocate emergency relief funds specifically to address new COVID-19 costs, including those related to learning loss, the digital divide (connectivity, devices, and digital literacy training), and the physical safety of students and teachers. Without a specific allocation for these programs and materials, some school districts may not see the funds they need for reimbursements and upcoming COVID-19 costs. In Texas, for example, CARES Act resources were distributed in place of the state funds already allocated to schools for the remainder of the school year. While this was considered a permissible expense under the CARES Act, it left many school districts struggling to cover new COVID-19 costs, with few other funding sources for reimbursement for those new costs.
• Require and enforce supplement, not supplant; maintenance-of-effort; and maintenance-of-equity provisions for all federal relief funds. These requirements ensure state and local fund recipients do not shirk their responsibility to invest in public education. They also protect funding for students from families with limited incomes, emergent bilingual students, students with disabilities, students experiencing homelessness, and others who most need resources in their schools, especially if states cut their education budgets.
• Give states flexibility and guidance to report assessment data based on formative assessment systems and other measures that do not penalize students and schools. Following school closures in 2019-20, the U.S. Department of Education waived federal testing and reporting requirements for states given the sheer difficulty of assessing students, many of whom had no had meaningful access to their schools since the pandemic began. Those teaching and learning challenges persist, particularly in schools serving historically-marginalized students. We need information about how students are faring during COVID-19 to effectively address learning loss and allocate sufficient resources. However, summative assessments that are difficult to administer virtually, do not accurately measure teaching and learning, and unfairly penalize students can be counterproductive. The U.S. Department of Education should allow states some flexibility to measure and report teaching and learning in different ways for the 2020-21 school year and should encourage them to develop statewide formative assessment systems to use beyond the pandemic.
Additionally, increasing funding for the National Assessment of Educational Progress (NAEP) will help to assure that states are held accountable for school outcomes even if their education agencies experience widespread testing challenges.
In addition to the recommendations above, IDRA urges the administration to immediately and publicly reverse U.S. Department of Education policies that funnel emergency funds away from public schools through vouchers and voucher-like “microgrant” programs. Future COVID-19 relief funds should be explicitly open to all students, including college students, regardless of citizenship status. For more information about these and other recommendations, please review IDRA’s letter to congressional leaders related to a COVID-19 emergency relief package.
Provide Federal Resources Equitably and Incentivize Fair School Funding
Many schools across the country do not receive the funding they need to provide an equitable and excellent education to all students. Often, school funding formulae reinforce the inequitable distribution of resources to schools and rely on local property values and unstable state revenue sources to fund schools. These factors exacerbate racial and socioeconomic segregation and perpetuate a long history of inequitable access to resources for students of color, students living in poverty, and their families. IDRA urges President-elect Biden’s administration to:
• Push Congress to increase funding for Title I of the Every Student Succeeds Act so that schools have access to the materials, training, and other resources to ensure excellent educational opportunities for all students. An increase in Title I funding should be coupled with an equity-focused review of current distribution formulae and robust, up-to-date guidance from the U.S. Department of Education. This guidance should provide recommendations for how states can best target new funds and adopt funding formulae and programs to:
- Reduce racial and socioeconomic segregation across and within school districts. This should be done in addition to supporting important pieces of legislation like the Strength in Diversity Act, which would provide grants and supports to school districts to plan and implement strategies to increase racial and socioeconomic diversity in schools.
- Use research- and evidence-based approaches to calculate the accurate costs of educating students and base resource distributions on those cost studies. These calculations should include base-level student funding costs, and additional costs for providing high-quality instruction to “special student populations,” including emergent bilingual students, students from families with limited incomes, students who receive special education services, those experiencing homelessness, and those with an incarcerated parent, among others.
- Provide financial supports in their formulae to school districts to plan and implement programs that support community-centered and college-going cultures in schools. This includes increasing access to advanced coursework and well-trained teachers, counselors, and other personnel who can support college preparation and success.
Foster Safe and Culturally-Sustaining Schools that Do Not Rely on Harmful Discipline and Policing
The federal government can play an important role in dismantling the school-to-prison pipeline, and the new administration should actively pursue changes to federal guidance, funding, data collection, and civil rights investigations and enforcement to protect students and foster safe and culturally-sustaining school climates. Discipline reform and school climate work are closely related. Efforts to end harmful practices will be most effective if schools have tools and strategies to support all students and adults in their campus communities.
President-elect Biden through executive order, Congress, the U.S. Department of Education, and other federal entities should do the following to end harmful discipline and school policing practices, which disproportionately impact Black students, Latino/a students, students with disabilities, LGBTQ students, and the many students at the intersections of multiple identities.
• Issue a revised version of the 2014 school discipline guidance issued by President Obama’s administration. There are a number of important revisions to consider, many of which focus on school policing. Federal guidance should omit recommendations that school police be part of any school safety or discipline plan.
• Reject the findings of the Trump administration’s school safety commission that inappropriately linked efforts to reduce the use of exclusionary school discipline and policing to incidents of targeted school violence. The administration used this false link to justify its rescission of the 2014 school discipline guidance. Others also use it to defend many of the practices and policies in schools that prioritize harmful and ineffective security measures over proven strategies that center relationship building, community connections, and restorative practices as the true measures of school safety.
• Push for the following legislation that protects students and prohibits the use of federal funds for practices that harm students, including:
- The Counseling not Criminalization in Schools Act, which prohibits the use of federal funds for school police and provides grant funding for counselors and other critical school personnel;
- The Ending PUSHOUT Act, which provides grant funding for states that ban harmful discipline practices and expands enforcement capacity at the Office for Civil Rights; and
- The Protecting Our Students in Schools Act, which bans the use of corporal punishment in schools.
• Direct federal departments charged with addressing violations of students’ civil rights to adopt robust complaint investigation procedures. These departments must pursue investigations thoroughly, including in cases in which a school or education agency’s policies and practices have had a disparate impact on students of color or other historically-marginalized groups. All agency guidance documents and internal procedures and rules should prioritize the robust enforcement of civil rights protections for all students.
The Biden administration should urge Congress to increase funding for the people, personnel, and programs and practices that create safe and culturally-sustaining schools for all students. Specifically, funding should be allocated and incentives put in place for states to target the following.
- People: Invest in supports for students, families, and educators in school communities, including through robust family and student engagement programs and bilingual parent support specialists through increased Title I, Title III, emergency relief, and other funding programs. COVID-19 has revealed the critical need to expand these programs as school districts across the country continue to report “missing” students and families, rampant academic failure, and decreased enrollment.
- Personnel: Increase funding for counselors, social workers, nurses, school psychologists and other mental and behavioral health professionals trained to support student and adult needs in school communities. This is particularly important as many students are experiencing challenging life circumstances and trauma associated with COVID-19. Student-led research supported by IDRA found that 75% of young people surveyed experienced mental health challenges since schools closed in March. Additional competitive grant funding should be available for school districts that create plans to limit exclusionary discipline and end the presence of police in schools so they can hire personnel to meet recommended student-to-professional ratios.
- Programs and Practices: Expand the use of research- and evidence-based programs and practices that create stronger, culturally-sustaining schools and increase student academic success, attendance, and self-concept through increased Title I and other program and competitive grant funding. Specifically, these programs and practices should include:
- ethnic studies courses and culturally-sustaining pedagogy and educational practices;
- the community schools model;
- district-wide training on trauma-informed teaching, systemic racism, restorative practices, and implicit bias;
- teacher recruitment and retention plans that focus on increasing teacher racial, ethnic, and gender diversity and addressing teacher shortages in bilingual education teachers, STEM, and special education; and
- district-wide training on the importance of recognizing and centering student civil rights in educational practices, discipline systems, and access to coursework that prepares all students for college.
Congress should increase funding for equity assistance centers, which are the only federally-funded training and technical assistance centers focused specifically on civil rights. These centers, funded and monitored through the U.S. Department of Education, provide critical supports to education agencies, schools, and related groups like parent and student organizations to address discrimination based on race, religion, national origin, and gender. The centers have been critical in the expansion of culturally-sustaining educational practices and research-based teacher and administrator training. Additionally, equity assistance centers can help to support schools and education agencies as they overcome the harms of current executive orders and commissions that prohibit and vilify discussing and teaching about racial justice, discrimination, and systemic inequities. Such orders and commissions should immediately be rescinded and disbanded.
The U.S. Department of Education should be required to collect and publish data annually through the Civil Rights Data Collection (CRDC). The annual publication of these data is critical to ensure school districts educate all students equitably and, if not, are held accountable by communities and federal agencies. In addition to other key datapoints, discipline and school climate data are published through the CRDC. The data required to be reported in these areas should be expanded to include intersectional data about students and additional information about policing in schools, access to ethnic studies courses, and other indicators of safe and culturally-sustaining schools.
Ensure Excellent Educational Opportunities for Emergent Bilingual Students
Emergent bilingual students (often referred to as English learners) represent about 10% of all students in the country, and a far greater percentage in some states. But too often they are missing from conversations about educational equity and federal funding, monitoring, and civil rights protections. We urge President-elect Biden’s administration to be proactive in its protection of the rights of emergent bilingual students, recognizing the importance of these students not only as assets and contributors to our collective success, but as young people whose basic rights to an excellent education warrant protection. We urge the new administration to:
• Continue to meet with civil rights and educational equity organizations that focus on emergent bilingual students to develop a comprehensive platform of federal policies and a national network of federally-funded centers to improve educational opportunities for emergent bilingual students. These policies must address the specific needs of these students in early childhood education spaces; ensure consistent and effective data collection, assessment, and accountability practices; and address the needs of students and families during and after distance learning due to COVID-19. IDRA would be pleased to join and help to convene such a group.
• Push Congress to increase formula grant funding in Title III of ESSA, which provides federal funds to states to serve emergent bilingual students, offer teacher training, and foster family and community engagement programs. While the U.S. population of emergent bilingual students increased dramatically over the past 20 years, federal funding for their educational programs did not. We urge President-elect Biden’s administration to increase Title III allocations, based on reliable cost studies, inflation, and long-term teaching and learning needs exacerbated by COVID-19.
• Urge Congress to increase funding for the National Professional Development Program (a Title III program), which provides discretionary grant funding and other resources to institutions of higher education to support teachers and other professionals who work with emergent bilingual students. These resources are critical to increase the number of well-prepared and certified teachers and professionals and address the pervasive shortage of qualified bilingual educators.
• Strengthen the Office of English Language Acquisition (OELA) and the National Clearinghouse for English Language Acquisition through increased funding and personnel. Title III grants should be administered through OELA, rather than the Office of Elementary and Secondary Education. Consolidating grant distribution, oversight, guidance, and training under one department (OELA) would allow for a more seamless and effective management of these functions by department personnel with specific expertise in educational programs for emergent bilingual students.
Center Students and Families in Educational Leadership
Schools belong to their communities. Effective schools are co-created by stakeholders, including students, families, community leaders and educators. IDRA recommends that President-elect Biden’s administration invest in proven strategies that expand student and family leadership in education policy and practice, particularly during this time of widespread isolation between many schools and families. Specifically, IDRA recommends that the new administration:
• Urge Congress to immediately increase funding for Title I, Title III, and other programs that support students and family engagement programs. Additional grant funding will help school districts plan and implement local strategies for ensuring student and family engagement. This engagement should not be superficial but should involve meaningful relationship-building strategies that encourage student and family leadership in schools’ educational policies and practices. IDRA has developed a framework for family leadership in education that has proven effective for decades. This and other strategies are now more critical than ever. Many school districts have reported “lost students” due to COVID-19 and less communication with families, particularly families of color, even controlling for the digital divide.
• Use grant funding to incentivize community-based school district governance and accountability strategies. These funds can be distributed through the U.S. Department of Education to support local accountability teams – made up of parents, students, educators, and other community stakeholders – that are charged with developing plans to improve educational quality and access, collect data, and review and enforce implementation of strategies. Additionally, some federal funds should be withheld from states that enact punitive accountability systems that punish school districts without offering supports and resources for improvement.
Thank you for your work for students and the urgency with which you do it. Once again, should you have any questions about the recommendations above, please contact IDRA’s National Director of Policy, Advocacy, and Community Engagement, Morgan Craven, J.D., at firstname.lastname@example.org. IDRA is happy to serve as a resource to you during this important transition.
 U.S. Department of Education. (2018). Our Nation’s English Learners – What are their characteristics?, data website. https://www2.ed.gov/datastory/el-characteristics/index.html
 See Joint Letter from Advocacy Organizations Seeking Additional Emergency COVID-19 Funding for English Learners. (April 17, 2020). Supplemental Funding for English Learners/Title III in COVID Relief, https://www.idra.org/wp-content/uploads/2020/05/unidosus_titleIIIcovidsignonletter_41720.pdf
 Rafa, A., Erwin, B., Brixey, E., McCann, M., & Perez Jr., Z. (May 27, 2020) Fifty State Comparison: English Learner Policies, Education Commission of the States, https://www.ecs.org/50-state-comparison-english-learner-policies/. Evans, A., Erwin, B., MacDonald, H., Pompelia, S., Aragon, S., & Perez Jr., Z. (October 23, 2019). Fifty State Comparison: Teacher Recruitment and Retention, Education Commission of the States, https://www.ecs.org/50-state-comparison-teacher-recruitment-and-retention/
 A data analysis by IDRA found that even controlling for access to connectivity and devices, Black and Latinx families were less likely to have contact with their schools during COVID-19 school closures, indicating a more systemic community engagement problem on the part of schools.