Perkins IV: The Impact on Local Recipients

ACCOUNTABILITY

• Negotiations: Negotiations are required between local recipients (colleges and high schools) and the Office of the Chancellor (OCC) or Minnesota Department of Education (MDE) to set performance targets and measures. The state-to-local negotiations are based on the federal/state negotiated performance levels. (No state to local negotiations exist under Perkins III.)
• Compliance: A new set of indicators is required beyond those under Perkins III including retention, transfer and technical skill attainment, each of which must start at a baseline from which targets must be set for each subsequent year. We can use current system accountability for data for retention, graduation, and transfer; however, the addition of a separate measure for technical skill attainment presents some difficulties. At this time we do not have a system-level process for measuring technical skill attainment using third-party measures. (Perkins III included indicators for academic skill attainment [no longer measured at the postsecondary level], technical skill attainment, graduation, employment placement and retention, non-traditional career participation and completion.)
• Disaggregating the Data: Recipients must provide aggregate data, must be able to compare across different subsets of students, must provide explanations of the gaps among different subsets, and must address in the local Perkins plan strategies for closing the gaps. The Perkins categories that must be disaggregated are gender, ethnicity, special populations (individuals with disabilities, individuals from economically disadvantaged families, individuals preparing for non-traditional fields, single parents/pregnant teens, displaced homemakers, and individuals with limited English proficiency). (Under Perkins III we are required to report the data, however the data are not used in a programmatic way as will be required in Perkins IV.)
• Technical Assistance: States must develop a framework for engaging high schools and colleges in a continuous improvement process focused on Perkins objectives, which may include incentives for good performance and improvement plans where necessary. The Act expects provisions for sanctions when high schools and colleges do not meet negotiated targets. While there is an explicit provision in Perkin IV for state-imposed sanctions should recipients fail to meet their negotiated targets, sanctions are a last resort. Prior to the implementation of sanctions on a local recipient for not making continuous progress toward meeting performance targets, the OOC or MDE and the local recipient must jointly implement a technical assistance plan. Local funds should be directed toward areas needing improvement. (Under Perkins III, there are soft sanctions if recipients do not meet their targets but no hard sanctions which could ultimately result in reduced funding.)
• Tech Prep: Each state must decide how to handle Tech Prep at the state level – either roll the funds into the basic grant and disseminate accordingly or keep the funds separate. There are significant consequences to either option. (Currently Tech Prep funds are separate from the Perkins basic grant.)

PROGRAMMATIC

• State-level Secondary/Postsecondary Split: The split of funds between secondary and postsecondary education must be analyzed in light of Perkins IV and its new expectations. The anticipated analysis and discussion of the secondary/postsecondary split may results in a different configuration of how funds will be allocated and how much is directly available for individual local recipient programming. (The current Minnesota split is 65% postsecondary and 35% secondary. This allocation was specified in the Perkins III Minnesota State Plan based on a data-driven formula that was agreed to by the leadership of both the Minnesota Department of Education and the Minnesota State Colleges and Universities.)
• Local Use of Funds: Perkins IV makes assumptions that funds will be expended in ways different from the existing law in some respects. Local recipients must realize that fund expenditures are not an entitlement, but must be based on aligning student support services, academic programming, and assessment to improve technical and occupational programs and support student learning outcomes. In general, activities within Perkins IV must not be viewed separately from other activities that focus on under-represented students, high school to college transitions, and programs of study within any strategic planning and accountability endeavors. (The allowable uses of local funds under Perkins III and Perkins IV are similar; however Perkins IV establishes more stringent programmatic and accountability requirements.)
• Within Postsecondary and Secondary: Collaboration is an essential expectation for success under Perkins IV. While the amount of funding a local receives is still formula-driven, innovation may be rewarded through different Perkins funding mechanisms such as the use of incentive funding as well as pooling of local funds across different secondary and postsecondary consortia. Additionally, under Perkins IV it may be possible (we are awaiting clarification from the US Department of Education) to pool funds regionally at the secondary or postsecondary level to focus on improving career and technical education within the region. Local Perkins funds can also be leveraged with other initiatives to provide needed support services, particularly if the focus of the activity is on programs of study, technical skill attainment, under-represented students, or promoting non-traditional careers. (Under Perkins III, the Minnesota State Plan required local recipients to allocate 10 percent of their funds for collaborative activities involving secondary, postsecondary, and/or workforce agencies. The Minnesota practice of 10% collaboration is seen as a national model for other states to replicate. It is anticipated that this type of activity will continue under Perkins IV.)