CCSD Reorg. Proposal Fails to Address Needs of ELLs

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In approximately 406 days, on August 1, 2017, the Clark County School District is expected to look dramatically different than it does today. At that time, the recommendations of longtime educator and consultant Michael Strembitsky, could go into effect, creating “a radically different management structure and culture for the Clark County School District (CCSD) than what exists today.” This is if CCSD were to follow Strembitsky’s preliminary plan, which he presented to the Advisory Committee to Develop a Plan to Reorganize the Clark County School District on Thursday, June 16, 2016.


In 2015, the Nevada Legislature passed Assembly Bill 394, which breaks up the Clark County School District into local precincts. The reorganization emphasizes local control as a means of responding to the diversity of the school district, the fifth largest in the nation with more than 320,000 students, and each school’s unique needs. The bill has three important goals:

  1. Improving responsiveness: The legislation reads, “Reconfiguring the structure of the Clark County School District into local school precincts will offer an educational system that is responsive to the needs and concerns of the residents of that school district.” The sponsor of AB 394, Assemblyman David Gardner (R-Las Vegas), underscored this goal during the first hearing on the bill, when he stated, “This bill is an attempt to make our school districts more accountable and closer to parents.”
  2. Increasing student achievement: Another key goal of the legislation is to improve educational outcomes in Clark County. During the first legislative hearing, the bill sponsor presented research indicating that smaller school districts have higher levels of student achievement.
  3. Increasing efficiency: Proponents of the bill also argued that smaller entities can be more efficient than large school districts.

AB394 created the Advisory Committee comprised of Nevada Legislators and the Technical Advisory Committee (TAC), a group of Clark County community and business leaders and lawmakers that makes recommendations on the reorganization to the Advisory Committee. Both committees have met numerous times since Governor Sandoval signed the bill in April 2015. They have each heard presentations providing recommendations and information on best practices from various organizations, including Nevada Succeeds, the Nevada Department of Education, the Clark County Education Association, various financial and capital projects advisors from CCSD, and parent and community groups, including Break Free CCSD and HOPE (Honoring our Public Education).

Per the provisions of the bill, the Advisory Committee is expected to submit its final recommendations by January 1, 2017, in time for Nevada’s next biennial legislative session.

Strembitsky’s plan expedites the final objective, moving it up one year to the 2017-2018 school year. His proposal states that this recommendation was made “after consideration of the factors that would most likely result in a successful district-wide implementation.” Last Thursday, he told the committee, “You do it in one fell swoop or you don’t do it.”

Failure to Address Needs of English Language Learners

During public comment at both Thursday’s Advisory Committee and Friday’s TAC meetings, speakers expressed concerns about the lack of provisions specifically addressing the district’s English Language Learners (ELLs).

Around 60,000 pupils, nearly 20 percent of the 320,000-plus students in CCSD, are identified as ELLs. Yet, the graduation rate for these students remains roughly 28 percent, the second-lowest graduation rate for ELLs by state in the U.S.

Nowhere in Strembitsky’s plan are English Language Learners mentioned. His plan simply states, “Each school is placed in a unique position to respond to local circumstances, provide an arena for the creative and innovative talent of staff and ownership for the education of the children in their community. Operating in this manner makes it easier to identify problems and provide direct solutions. The current structure instead often requires schools to go through various district offices before problems can be resolved.”

The TAC also does little to address this high-needs population. ELL students are only specifically named in the committee’s final recommendations. On the issue of per pupil funding, Las Vegas Mayor Carolyn Goodman wrote, “[The reorganization plan should] establish an increased per pupil allocation, including a base figure plus access to additional fund allocations not limited to special needs, gift, ELL, Title I and other circumstances as designated by earmarked funding sources.”

Under Strembitsky’s plan, each school would be responsible for 85 percent of its total operating budget. What those figures will look like and whether additional funding will be allocated to schools with high populations of ELLs has yet to be determined. Strembitsky said his plan does not address the adequacy of resources, but rather the best way to use existing resources. In fact, he also said he’s never seen the district’s budget breakdown and that it was not a factor in drafting his recommendations.

State Senator Michael Roberson, chair of the Advisory Committee, reminded the audience, “This process does not end when we approve the plan.” The Advisory Committee will be responsible for ensuring the state provides the school district with sufficient resources to implement the plan. No minimum spending or resource allocation requirements have been set forth by either committee on any one budgetary item, including English Language Learner programs.

Federal law is also vague on the minimum requirements school districts must meet for their ELL populations. Title IV of the Civil Rights Act prohibits discrimination based on race, color or national origin. It also says that children with limited English proficiency need to be taught based on sound educational theory and programs need to be given adequate resources so as to ensure “a realistic chance of success.”

Strembitsky’s plan also fails to outline the role of the Central Office of CCSD in working with ELLs and other at-risk populations. A memo from the U.S. Department of Justice and the U.S. Department of Education says that school districts are responsible for monitoring the effectiveness of ELL programs and the academic performance of ELLs and those who have exited the program. What this will looks like under the reorganization remains unclear.

Other Equity Concerns

Critics of the proposed CCSD reorganization plan have expressed concern that the reorganization will “may deepen the achievement gaps and lack of resources that already exist for schools in poor and minority neighborhoods.” These neighborhoods have often borne the brunt of two of the district’s biggest problems: massive teacher vacancies and aging school facilities, as articles The Las Vegas Sun and the Las Vegas-Review Journal have reported.

In October 2015, the Guinn Center published its report, “Breaking Up Is Hard to Do: Issues in the Reorganization of the Clark County School District,” which found the following equity issues in CCSD:

  • CCSD students currently face significant levels of segregation. This isolation exists by race/ethnicity, socioeconomic status, and language.
  • Low levels of student achievement are highly correlated to large concentrations of minority, low-income, and English Language Learner students.
  • High performing schools are concentrated in suburban areas while low performing schools are concentrated in central Clark County.
  • Schools for special populations such as alternative education and special education students are not evenly distributed throughout CCSD.
  • There are high numbers of novice teachers and teacher vacancies in schools with high concentrations of low-income students.

The Guinn Center also published an accompanying infographic that illustrates the equity implications of AB394.

In a report for the Nevada Spending and Government Efficiency (SAGE) Commission, the Guinn Center also reported that the oldest school buildings in CCSD are concentrated in the city’s urban core, and they would not likely be helped by impact fees, which are paid in some states to help the construction of new schools.

Principal Training

Another concern brought up during last week’s Advisory and Technical Advisory Committee meetings was the principal training. Following Strembitsky’s accelerated timeline for the reorganization, all 350 CCSD principals would need to begin the professional development in August 2016, less than two months from now.

The estimated costs of the trainings for principals have not yet been calculated, nor has any funding thus far been earmarked for them.


In its final report, the Advisory Committee should consider:

  • Allocating additional funding to schools with high numbers of ELLs or use a weighted per pupil funding formula, in which the dollar amount assigned to an ELL would be higher than the base amount. Strembitsky proposal will require schools to pay Central Services for certain in-demand programs and services. It will be necessary to use a weighted funding formula to ensure that ELL programming and staffing in high-need schools does not come at the expense of other programs those schools may require.
  • Providing additional funding for schools with older facilities, especially since many older schools serve low-income and ELL students. Maintaining or upgrading school facilities should not come at the expense of programs or services that could benefit at-risk populations.
  • Establishing spending guidelines for schools with high populations of ELLs. Under the reorganization plan, principals are expected to lead the charge in creating their specific schools’ budget. The Central Services should train and provide principals with the necessary tools and information for them to choose and implement the right programs and high the necessary personnel to meet the specific needs of their ELL population.
  • Allowing schools to determine how to best deliver instruction to ELLs, but giving responsibility for holding schools accountable for academic outcomes to the Central Services.