BOE Discusses Title VI Compliance

During the April 7, 2024, Board of Education meeting, member Aaron Hoffman made a motion to add a new item to the agenda: a discussion of “Certification of Compliance with Title VI of the Civil Rights Act.” The motion passed and discussion ensued, but before we dive into it, some background information is needed.

According to the Department of Justice (DOJ), “Title VI, 42 U.S.C. § 2000d et seq., was enacted as part of the landmark Civil Rights Act of 1964. It prohibits discrimination on the basis of race, color, and national origin in programs and activities receiving federal financial assistance.” 

So, why is this an issue now? As NPR explains, “In a letter to state leaders across the country, the U.S. Education Department said Title I funding, which is targeted to schools with a high proportion of low income students, would be threatened if schools failed to follow its interpretation of civil rights laws.” 

Stafford falls under that umbrella and receives Title I funds. According to this year’s budget documents, the school district received $263,330 of Title I money in the 2024-2025 budget year. Specifically, the feds want to know that schools are complying with the responsibilities outlined in Students for Fair Admission v. Harvard. Given that there are no admission requirements for public schools, Stafford Public Schools are, by default, in the clear on that front. Interim Superintendent, Dr. Laura Norbut, said Stafford also does not favor any race in its hiring decisions.

She explained Connecticut’s superintendents were waiting on guidance from the Connecticut Commissioner of Education on how to proceed. When BOE member Chris Paradiso asked if a percentage of Title I needs to be spent on supplies, Dr. Norbut explained Stafford primarily uses Title I funds to offset salaries but has also been granted permission by the state to utilize some of it for Amplify CKLA resources.

Hoffman asked if superintendents were planning on providing feedback to the Connecticut State Department of Education (CSDE) to certify as quickly as possible, “given our tenuous budgetary situation…”?

Dr. Norbut explained that Title I funding is a two-year grant, and those funds are already in place for 2025. She, however, expressed concern over Title II, based on information shared with superintendents, which is unrelated to the Title I funding and certification. In 2024-2025, Stafford budgeted to receive $36,602 of Title II money.

Hoffman asked if the district still has a “Diversity and Inclusivity Coalition” in place. Dr. Norbut explained that the group was never called that and was instead referred to as the “Equity and Inclusion Coalition.” She further explained that the coalition focuses on access for students in the high-needs category, including those with learning disabilities, students who receive free or reduced lunch, and those with a multilingual learner status. 

Hoffman continued, “We’ve talked about the naming of that coalition as potentially divisive within the community...” He said the board has received messages from the community about it. He then said the “federal mandate is targeting two of those letters that you’re using in the coalition.” He expressed concern that a community member might report the district to the DOE due to the Equity and Inclusion Coalition, and trigger a federal investigation. He spoke about the “divisive” name, though he admitted the group does not engage in the “polarizing” work he fears it could be accused of doing. 

Dr. Norbut said the “Dear Colleague Letter” shared with districts specifically prohibits “denying students the ability to participate fully in the life of a school.” She also noted that CABE’s recent guidance on this topic clearly says districts’ Equity and Inclusion Coalitions do not deny students’ or staff’s ability to participate fully. Ultimately, she says, she believes Stafford is in full compliance with Title VI, as the work the Equity and Inclusion Coalition does is about leveling the playing field for all students.

At the time of the meeting, Dr. Norbut stated that the CSDE has a legal team investigating the Title XI matter and is in direct communication with the federal government, and that school districts would follow the CSDE's recommendations. Since then, the CSDE has said it will join other states in declining to comply. 

During the meeting, BOE chair Sara Kelley asked a rhetorical question: “There is a concern that cutting funds could happen at any moment… Are we prepared to fight for our staff and students to ensure we keep that funding? Again, it doesn’t have to be with the executive order that just came out. It could be something else. Just think, are we ready to stand for our staff and students if these mandates keep coming?”

While the full impact of the CBDE’s decision is, as yet, unknown, Dr. Norbut did say during the meeting that the majority of funding for Connecticut schools comes from the state and local levels. The state’s response to the potential loss of federal funding is also unknown, but, as Dr. Norbut has noted several times recently, the loss of Title I funds would be catastrophic.