After Congress authorizes a federal education program such as Impact Aid through legislation and it is signed into law by the president, the U.S. Department of Education (ED) develops regulations to determine how it will operate. To strengthen implementation of Impact Aid and other programs and to monitor the administrative burden of laws and regulations, NAFIS works closely with ED, educates the Administration and issues comments on proposed regulations. NAFIS also responds to Requests for Information and non-regulatory guidance issued by ED.

Comments on Department of Education Rural Report Draft (2/20/18)
NAFIS responds to the request for public comment on the U.S. Department of Education’s draft report on rural education required under Section 5005 of the Every Student Succeeds Act (ESSA). NAFIS supports proposed recommendations in the draft report, including creating an intra-agency rural workgroup, simplifying the grant application process and providing appropriate training to rural schools and school districts. The draft report’s failure to list findings of listening sessions and incorporate that feedback should be included in the final report, along with several other regulatory recommendations.

Department of Education Regulatory Priorities Letter (11/13/17)
NAFIS responds to the request for public comment on the Secretary’s Proposed Supplemental Priorities for Discretionary Grant Programs, sharing concern that the Secretary’s first priority to maximize educational choice will advance school privatization schemes, such as vouchers, rather than invest in public schools. NAFIS calls on the Department to instead prioritize resources for existing formula-based programs, such as Impact Aid.

Agency Reform Taskforce Letter (8/3/17)
NAFIS responds to the request for recommendations from the Agency Reform Taskforce with ideas on how the Federal government can efficiently and effectively run the Impact Aid program.

Department of Education Regulatory Reform Agenda Letter (6/29/17)
NAFIS provides input on the Impact Aid program as the U.S. Department of Education engages in an agency-wide directive to review all regulations per Executive Order 13777, the Enforcing the Regulatory Reform Agenda, urging ED to prioritize the Impact Aid office and the modernization of the information technology system. NAFIS also offers additional recommendations to improve Impact Aid as part of the regulatory reform initiative.

Letter to Secretary DeVos (2/28/17)
NAFIS congratulates Secretary DeVos on her confirmation, shares information on Impact Aid, requests a meeting and invites the Secretary to tour a federally impacted school district.

NCPE DeVos Confirmation Sign-on Letter (1/17/17)
NAFIS joins over 60 other organizations on a letter organized by the National Coalition for Public Education (NCPE) requesting that during the confirmation hearing for Betsy DeVos, nominee for Secretary of the U.S. Department of Education, leadership of the Senate HELP committee inquire about her history advocating for the use of public dollars to support private schools and seek clarity regarding her plans to support public education.

ESSA Supplement Not Supplant Letter (11/7/16)
NAFIS responds to the notice of proposed rulemaking related to the U.S. Department of Education’s draft “supplement not supplant” regulation under Title I of the Every Student Succeeds Act (ESSA), noting that the proposed regulation will create a huge administrative burden, encourage decision-making driven by compliance targets rather than sound education policy and undermine local governance. The implications could be more acute for federally impacted LEAs because of the nature of their student populations, their geographic location, the variable timeline of Impact Aid funding and the potential for significant cost shifts between the start and end of the school year.

ESSA Guidance Letter (5/25/16)
NAFIS responds to the request for stakeholder feedback from the U.S. Department of Education regarding non-regulatory guidance under the Every Student Succeeds Act (ESSA) in the areas of Tribal Consultation, the Military Student Identifier, the need for an Impact Aid digital student count and the need for an Impact Aid application handbook.

ESSA Accountability Regulations Letter (8/1/16)
NAFIS responds to the Notice of Proposed Rulemaking related to the U.S. Department of Education’s proposed regulations on accountability under the Every Student Succeeds Act (ESSA), requesting clarity without overly prescriptive regulations or guidance outside the scope of the law and that ED consult directly with individuals responsible for implementing the law. NAFIS also requests that ED be mindful of the parallel tracts of ESSA regulations and guidance and the forthcoming final rule on the Notice of Proposed Rulemaking for pre-ESSA Impact Aid changes.

Impact Aid Notice of Proposed Rulemaking Comments (2/16/16)
NAFIS responds to the Notice of Proposed Rulemaking for the draft Impact Aid regulations, supporting aspects of the proposal that will improve the timeliness of payments and expressing concern that additional requirements to the Impact Aid application process will make it more difficult and time-consuming for federally impacted school districts to comply with the regulations. NAFIS comments reflect feedback from NAFIS subgroups and a survey of NAFIS members.

NPRM Impact Aid Digital Count Letter (2/16/16)
NAFIS led 15 organizations in responding to the Notice of Proposed Rulemaking for Impact Aid, focusing on regulation 222.35, which relates to methods for school districts to count Federally Connected Children. Signing organizations believe that there are a variety of technologies that school districts can successfully implement as an alternative to the parent-pupil survey and encourage the Impact Aid Program Office to coordinate and work directly with the Office of Education Technology and the U.S. Digital Services, as well as with the Impact Aid community and the private sector, to develop viable solutions to update this program.

Impact Aid Notice of Proposed Rulemaking Summary (2/16/16)
NAFIS summarizes proposed changes to the Impact Aid regulations, which were released for public comment on December 30, 2015.

U.S. Department of Education’s Request for Information on ESSA Comments (1/21/16)
NAFIS, the Military Impacted Schools Association (MISA) and the National Indian Impacted Schools Association (NIISA) respond to the Request for Information on Implementing Programs under Title I of the Elementary and Secondary Education Act (ESEA), noting the need for the U.S. Department of Education to work with Impact Aid recipient school districts right away and to consult directly with those individuals – and organizations representing those individuals – that will be responsible for implementing the new law, including school superintendents, school business officials and school board members. The groups also made recommendations regarding Tribal Consultation and the Military student identifier.


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