TISA Evaluation

A Closer Look at the Tennessee Investment in Student Achievement Act (TISA)

The Education Trust in Tennessee launched our Dollars and Sense Learning series in early 2021, along with fact sheets and other resources to equip advocates on elements of school finance and what it would take to modernize K-12 funding in our state.

Learn More About School Funding

TISA FAQs

TISA Rulemaking

Our Review

Our analysis is based on TISA’s passed language, legislative hearings, documents referenced below, and Governor Lee and Commissioner Schwinn’s press conference on Feb. 24, 2022. This analysis is designed to allow stakeholders to see how TISA measures up to our recommendations and provide additional context for the new formula by component.

What’s Next?

HB2143/SB2396 passed through the legislature on 4/28/22 and was signed by Governor Lee on 5/2/22. Check here for more details on the legislative process.

TISA rulemaking is already under way in Tennessee. Check out our TISA Rulemaking Analysis for our rulemaking recommendations, timeline, and other resources to promote a stronger and more equitable funding formula for all Tennessee’s students.

Legend

Meets Criteria

Partially Meets Criteria

Doesn't Meet Criteria

Additional Allocation of Funding to K-12 Education	RATING \| Meets criteria
Our Recommendations	TISA
A generous, recurring allocation	TISA Press Conference reference a $750M recurring increase starting in FY24
Analysis
The proposal contains a new and substantial recurring allocation, but it is subject to appropriations

Base Funding for Every Student	RATING \| Meets criteria
Our Recommendations	TISA
A generous base for every student that is, at minimum, at or above the national median ($6,000)	TDOE Press Conference reference $6,860 per student and $6.6B overall in allocated base funding The base is the same for every student in the state
Analysis
TDOE has provided more clarity on how they determined the base amount and its calculation, but it is subject to appropriations Same and generous base supports all students’ learning and allows the weights to effectively support students based on need
Questions for Consideration
How will the base be adjusted for inflation?

Additional Weights for Student Groups	RATING \| Meets criteria
Our Recommendations	TISA
Generous weights are added to the base and determined by student need Students may qualify for more than one weight	TISA Press Conference referenced $1.8B in overall funding for weights Weights are not mutually exclusive and can be "stacked," meaning a student may qualify for and receive the funding of multiple weights
Analysis
Funding weights are stackable across categories to meet individual students’ unique learning needs, but weights are based on the allocated base amount

Weight 1: Economically Disadvantaged & Concentrated Poverty	RATING \| Partially meets criteria
Our Recommendations	TISA
A substantial weight for students from low-income backgrounds that is in line with national best practices (e.g., Common Sense and Fairness Report) Weights are applied in addition to the base amount for students who are identified by direct certification and TennCare enrollment Additional weighted funding based on the percentage of students in a district that are from low-income backgrounds	25% weight for students from low-income backgrounds (definition references TN ESSA; includes students experiencing homelessness, migration, or in the foster care system, FRLP eligibility, or direct certification) 5% additional weight for concentrated poverty defined as a Title I eligible schools
Analysis
25% weight almost doubles current funding for students from low-income backgrounds Concentrated poverty weight adds $343 additional funding per student in a Title I eligible school Approximately two-thirds of students in TN are enrolled in Title I eligible schools. As a result of this broad definition, this weight's effect may be reduced
Questions for Consideration
How would measuring a district’s percentage of students from low-income backgrounds, rather than using a school's Title I status, change the number of students impacted by the concentrated poverty weight? Can direct certification be expanded to include TennCare recipients to ensure measure is inclusive for student need?

Weight 2: Rural Schools	RATING \| Partially meets criteria
Our Recommendations	TISA
A substantial weight for students in rural schools in line with national best practices (e.g., Common Sense and Fairness Report) A sliding-scale weight for each student enrolled in a sparse district, as defined by the number of students per square mile	5% weight for students in sparse districts (defined as a local education agency (LEA) in a county with less than 25 students per square mile) 5% weight for small districts (1,000 students or fewer)
Analysis
Sparsity weight measure is based on students per square mile to address diseconomies of scale and other challenges in rural districts Small and sparse weight adds $343 additional funding per student in rural schools The specific small district weight may incentivize districts to consider subdividing, decreasing efficiency and economies of scale
Questions for Consideration
How might the rural weight increase if the small-district weight was eliminated or if the number of students per square mile were adjusted to support a more powerful weight for rural districts?

Weight 3: English Learners	RATING \| Partially meets criteria
Our Recommendations	TISA
A substantial weight for English Learners in line with national best practices (e.g., Common Sense and Fairness Report) Students are assigned to one of 3 tiers based on student characteristics, including, at a minimum, levels of English proficiency	15-150% weight for Unique Learning Needs (ULN) with 10 different levels established and categorized by TDOE rulemaking English learners must have an individual learning plan and ULN rulemaking must align with TNSBE's rules Students can qualify for multiple ULN weights TDOE provided documentation on how ELs may be identified and distributed across the 10 ULN categories (EL 1 = 20%, EL 2 = 60%, EL 3 = 70%) currently based on English proficiency, years identified as an EL, and formal schooling using multiple assessments TNSBE will issue a positive, negative, or neutral recommendation on TDOE proposal before rulemaking
Analysis
20-70% ULN weight adds $1,372 to $4,802 in additional funding for each English learner as proposed Assigning English Learners across multiple levels allocates resources to schools and students to support different needs, but is subject to rulemaking Increased TNSBE involvement encourages more collaboration for a potentially stronger result
Questions for Consideration
How will stakeholder engagement be included to determine and evaluate ULN categorization?

Weight 4: Students with Disabilities	RATING \| Partially meets criteria
Our Recommendations	TISA
A substantial weight for students with disabilities in line with national best practices (e.g., Common Sense and Fairness Report) Students are assigned to the 5 tiers based on the skills and abilities listed in an IEP or 504, increasing funding for students with more significant needs	15-150% weight for Unique Learning Needs (ULN) with 10 different levels established and categorized by TDOE rulemaking ULN includes students with disabilities, with characteristics of dyslexia, identified as gifted Students can qualify for multiple ULN weights TDOE provided documentation on how students with disabilities may be distributed across the 10 ULN categories currently based on hours of services per week and other select factors (e.g., homebound) TNSBE will issue a positive, negative, or neutral recommendation on TDOE proposal before rulemaking
Analysis
15-150% ULN weight adds $1,029 to $10,290 in additional funding for each student with disabilities and other identified groups as proposed Assigning students with disabilities across multiple levels allocates resources to differentiate support, but it is still subject to rulemaking Increased TNSBE involvement encourages more collaboration for a potentially stronger result Funding primarily based on time does not capture cost nuances because one hour of services can cost vastly different amounts based on teacher to student ratio and other factors During legislative hearings, TDOE stated they anticipate revising the current Special Education Option Codes based on best practices (e.g., identifying students with disabilities through IEP and 504 skills) during rulemaking
Questions for Consideration
How is TDOE considering the different identification options to determine which students will be in each of the 10 ULN categories (e.g., IEP/services, diagnosis, time, and placement)? What specific auditing and monitoring procedures will the State use to ensure that students are not under- or over-identified based on their categorization? How will the State address any monetary incentives that place students in more restrictive environments? How will stakeholder engagement be included to determine and evaluate ULN categorization?

Direct Funding	RATING \| Meets criteria
Our Recommendations	TISA
Large majority of funding should be allocated through the base and weights to ensure stability and flexibility for districts	TDOE will promulgate rules on direct funding amounts TNSBE will issue a positive, negative, or neutral recommendation on TDOE proposal before rulemaking Allocates additional funding for: 4th-grade literacy tutoring for students who score 'below' or ‘approaching’ on 3rd-grade ELA TCAP CTE based on tier and student year Postsecondary readiness assessments (i.e., ACT & retake) K-3 students Charter students (previously included as a weight) Allocated per student to LEAs (excluding postsecondary readiness assessments) TISA Press Conference referenced $376M overall for this component
Analysis
TDOE outlines direct funding categories in the legislation Increased TNSBE involvement encourages more collaboration for a potentially stronger result Including students who scored ‘approaching’ provides funding for districts to provide interventions required under the 2021 Learning Loss Remediation and Student Acceleration Act TDOE and legislators shared in multiple legislative hearings that the charter direct funding would be the same as its current allocation, around $16M, but it depends on annual budget allocations Moving funding sources outside the BEP into TISA direct funding increases stakeholder transparency Based on the TISA Press Conference, direct funding will make up approximately 4% of the total $9B in state and local funding for 2024
Questions for Consideration
How will the State adjust or modify different initiatives that receive direct funding in the future? How will stakeholder engagement be included? How will the State evaluate the impact of programs receiving direct funding?

Outcomes-Based Funding	RATING \| Partially meets criteria
Our Recommendations	TISA
Large majority of funding allocated through base and weights Metrics tied to growth on research-based indicators of student success Ensure students from low-income backgrounds, in rural schools, with disabilities, and English Learners are identified for additional outcomes-based funding	TDOE allocates funding per student to LEAs, subject to available appropriations and relative to students in other LEAs using previous year’s data TDOE determines outcome goals based on rulemaking TDOE will convene relevant stakeholders (based on member list in legislation) to advise on outcome incentive dollars and outcomes goals TNSBE will issue a positive, negative, or neutral recommendation on TDOE proposal before rulemaking TDOE projects $104.4M in outcome-funding TDOE provided documentation on potential outcomes-based funding that includes 3rd-grade reading proficiency and workforce credentials or ACT or significant improvement with double funding for students who qualify as ‘economically disadvantaged’
Analysis
Based on the TISA Press Conference, outcomes-based funding will make up approximately 1% of the total $9B in state and local funding for 2024 Increased TNSBE involvement encourages more collaboration for a potentially stronger result Requiring an advising group with diverse stakeholders will increase transparency and stakeholder engagement TDOE indicated their interest in growth through the ACT retake, but does not currently include other proposed measures Additionally, outcomes-based funding includes additional funding for students from low-income backgrounds, but does not include other student groups identified for additional funding in the weights (e.g., English learners, students with disabilities, and in sparse schools
Questions for Consideration
How will TNGA determine outcomes-based funding allocations every year? What role will TDOE and other stakeholders play? What factors should be considered? How will TDOE effectively incorporate stakeholder convening feedback into rulemaking? Will the meetings be recorded and summarized to increase stakeholder transparency? What formula or allocation strategy will TDOE use annually to distribute outcomes-based funding? WIll they share this publicly? Will TDOE publish how much funding is available each year for outcomes funding, how districts performed on each of the goals, which districts were awarded funding, and how much overall and per student?

Local Fiscal Capacity	RATING \| Partially meets criteria
Our Recommendations	TISA
Clear proposal or plan for local fiscal capacity is addressed in TISA Greater transparency in fiscal capacity calculation Districts must maintain current level of funding effort without allowing additional state dollars to supplant local funding No decrease in funding for districts that have a substantial percentage of students are from low-income backgrounds, have disabilities, are in a rural school, or are English learners	70/30 split between state and local share LFC calculation, underlying data, each county’s LFC, must be reported publicly and annually State will cover all direct, outcomes, and fast-growing funding outside of the formula Gradually decreases the difference in funding over four years (100-25%) to ease transition to new formula If an LEA's funding decreases more than 5% in one year, TDOE will allocate funds to cover the difference (not stackable with temporary hold harmless) CBER & TACIR will establish fiscal capacity measure based on combined average and the Comptroller will evaluate, and TNSBE will approve TISA Press Conference referenced no changes to Maintenance of Effort Adds a Cost Differential Factor (CDF) grant funding for counties that have a higher nongovernmental wages than the statewide average
Analysis
Fiscal capacity addressed in legislation Increased LFC transparency promotes meaningful stakeholder engagement Shifts from a single fiscal capacity measure back to two fiscal capacity measures, decreasing transparency and stakeholder engagement Districts must maintain their current funding effort The Sycamore Institute found TISA is unlikely to grow the statewide total for mandatory local spending over the next decade and, compared to the BEP, could require fewer district-level increases.
Questions for Consideration
Who is responsible for publishing the LFC calculation, underlying data, each county’s LFC, that must be reported publicly and annually? How, if at all, will CBER and TACIR revise their current indices? How are they considering measuring fiscal capacity at the county versus district level and absolute versus relative funding models? How will the State increase local fiscal capacity transparency given the shift back to two measures?

Transparency & Accountability, & Reporting	RATING \| Partially meets criteria
Our Recommendations	TISA
Majority of funding is flexible and tied to local needs Funding is provided to districts to assist transition to new formula and reporting requirements (e.g., administration, systems, training) Longitudinal and comparative school and district-level funding and district, state, and federal-level per-pupil expenditure data reporting in transparent and interactive formats, including on the State Report Card	Transparency: LEA will have an opportunity to give feedback on TISA to TDOE and Comptroller TISA Review Committee, similar to the current BEP Review Committee, evaluates TISA annually with report with recommendations TDOE competitively procures and offers TISA professional development to various local and state officials Accountability: Funding is flexible other than potential teacher salary and raises requirement State Board Committee: Authorizes TNSBE or appointed committee to hold hearings on any school district or public charter with D or F on State Report Card, with these potential outcomes: LEA completes corrective action plan and TDOE reports to the State Board TDOE audits and investigates district or public charter school's programming and spending and reports it to the State Board No recommended action TNSBE promulgates rules on process Progress Review Board: Sets a goal for each LEA to increase 15% towards an overall 70% 3rd-grade ELA TCAP proficiency over three years Creates a Progress Review Board that may recommend an LEA complete additional training Reporting: LEA will submit annual accountability report to TDOE on budget and 3rd-grade ELA TCAP proficiency and other student achievement goals TDOE will produce annual report Comptroller's OREA will provide TISA report and recommendations to TNGA by 12/31/24 TISA Press Conference referenced publicly posted and federally required school and district level funding will be added to annual report cards
Analysis
TISA Review Committee ensures continuous monitoring to support improvement, particularly in the formula’s initial stages Increased TNSBE involvement encourages more collaboration and expertise for a potentially stronger end result Majority of funding is flexible for districts to meet their students’ needs Multiple accountability processes in addition to existing accountability system may decrease efficiency and collaboration District reporting is required, but it is unclear if the State will report longitudinal and comparative school and district-level funding and district, state, and federal-level per-pupil expenditure data reporting in transparent and interactive formats
Questions for Consideration
How will the new accountability measures in the House and Senate amendment versions align with existing Tennessee's accountability system? Will there be dedicated funding for districts to transition to the new formula and reporting requirements?