A r c h i v e d  I n f o r m a t i o n

Biennial Evaluation Report - FY 93-94

Chapter 109

Impact Aid: Maintenance and Operations

(CFDA No. 84.041)

I. Program Profile

Legislation: P.L. 81-874, as amended (20 U.S.C. 236-241-1 and 242-244) (expires September 30, 1999).

Funding History

Fiscal Year Appropriation Fiscal Year Appropriation
1951 $28,700,000 1986 665,975,000
1965 332,000,000 1987 695,000,000 3/
1970 507,900,000 1988 685,498,000
1975 636,016,000 1989 708,396,000
1980 792,000,000 1/ 1990 717,354,000
1981 706,750,000 1991 754,361,000
1982 437,000,000 1992 763,708,000
1983 460,200,000 1993 738,250,000
1984 580,300,000 2/ 1994 786,304,000
1985 675,000,000
1/ Includes $20 million supplemental appropriation for disaster assistance.
2/ Includes $15 million supplemental appropriation for disaster assistance.
3/ Includes $20 million supplemental appropriation for disaster assistance.

II. Program Information and Analysis

Population Targeting

Purpose: Impact Aid is intended to compensate local school districts for burdens placed on their resources by Federal activity, either through Federal ownership of property in the district (which, because it is tax-exempt, may decrease funds available for education), or through the addition of "federally-connected children" to the number of students that it would ordinarily need to educate. Federally-connected children include "a" children, those who bothlive and have parents who work on Federal property, and "b" children, those who either live on Federal property or have parents who work on Federal property. Included in these categories are children living on or having parents who work on Indian lands and children who have a parent who is on active duty in the uniformed services.

Section 2 provides aid to districts with significant amounts of federally-owned property, generally based on the Department of Education's estimate of the local revenue that the local education agency (LEA) would have received from the eligible Federal property if that property had remained on the tax rolls.

Section 3 provides aid to districts with federally-connected children; the amount varies with the classification of the children and is highest for "a" children, who presumably create the greatest burden on local resources. Higher payments are made for children living on Indian lands and for children with disabilities. Payments are also increased for districts with higher proportions of federally-connected children, i.e., 15 percent or more "a" children in the district or 20 percent or more "b" children. A minimum of 3 percent or 400 children in average daily attendance in a district must be federally-connected for a district to be eligible to receive aid.

In addition, Section 6 schools that primarily serve children of military families who reside on Federal property, although authorized by P.L. 81-874, are currently operated and funded by the Department of Defense (DoD).

Section 7(a) authorizes assistance to LEAs for increased current operating expenses and/or replacement of lost revenues that result from damage caused by disasters in areas that are eligible for Federal public assistance as designated in presidential declarations. The repair and replacement of physical facilities are the responsibility of the Federal Emergency Management Agency.

Population Targeting

Impact Aid is paid directly to eligible school districts and becomes part of their general operating funds. The only restriction on its use is that the extra payments made on behalf of children with disabilities must be used for special educational services designed to meet the needs of those children. In addition, disaster assistance funds must be used for allowable and approved costs related to a presidentially-declared disaster.

One of the most pressing problems in the Impact Aid program is inequity in the distribution of Section 3 payments. First, payments for "b" children, who generally do not impose a real burden on their school district, divert scarce Federal resources away from districts that are more truly burdened by Federal activities. Most "b" children have parents who work on Federal property but live on non-Federal property that is on the local tax rolls and generates property tax revenues for the district. For example, Fairfax County, Virginia receives Section 3 funds for many "b" children whose parents work at the Pentagon in Arlington County but live and pay taxes in Fairfax County; these children place no greater burden on Fairfax County than any other child whose parents commute to a private-sector job in a neighboring county. Because appropriations have historically been well below total entitlements and payments must be pro-rated, payments for "b" children divert scarce funds from districts with "a" children, who represent a far greater burden on their districts.

Further, several statutory provisions have the effect of providing substantially larger payments to districts with only slightly more Section 3 students. For example, districts that meet the eligibility threshold are compensated for all of their federally-connected students, while districts that fall just below the threshold receive nothing. Similarly, districts that have high concentrations of federally-connected students ("super a" and "sub-super a" districts) are currently entitled to a higher payment rate for all of their federally-connected students.

A 1988 analysis (III.1) examined the distribution of Impact Aid funds among school districts that differ in size, wealth, and spending, as measured by student enrollment, property valuation per pupil, and current operating expenditures per pupil. The study found that, in general, a larger than expected proportion of Impact Aid goes to districts that are small, low in property wealth, or high in per-pupil expenditures. For example, the highest-expenditure districts, with 25 percent of total enrollment, received over 37 percent of program funding, whereas the lowest-expenditure districts, with 24 percent of enrollment, received only about 15 percent of program funding. Because this study did not examine the distribution of Impact Aid relative to other district revenues, no conclusion was reached on whether high-expenditure districts would have high revenues without Impact Aid. Further study would be needed to determine whether Impact Aid recipients tend to be high-expenditure districts due to other Federal, State, and local resources, or whether their relative affluence is largely due to Impact Aid revenues.

In FY 1992, ED commissioned a set of papers (III.2) on topics related to the implementation of Section 5(d)(2), which allows States with school finance systems that ED has certified as "equalized" to reduce State aid to school districts that receive Impact Aid (under the rationale that in States with equalized funding systems, the State is assuring that districts are not unfairly burdened due to Federal activities). Under the current 5(d)(2) standards, States may be certified as equalized under one of three tests: 1) a disparity test, which considers differences in per-pupil funding among school districts in the State (to qualify, the difference between the 95th and 5th percentiles must be no greater than 25 percent), 2) a wealth neutrality test, which is based on the principle that the same level of tax effort should yield the same level of funding per pupil, and 3) an exceptional circumstances test.

For the commissioned papers, authors were asked to analyze and critique the current 5(d)(2) standards and develop alternative standards. In addition, authors were asked to consider how the 5(d)(2) standards could incorporate incentives for encouraging States to increase equalization, standards emerging from recent school finance litigation, alternative measures of school resources and inputs, cost-of-education adjustments to educational expenditures, and ways to address the problem of educational overburden in large, urban school districts. Authors all agreed that improvements in the current 5(d)(2) equalization standards should be made. Each paper noted that specific equalization standards would contain implicit value judgements, and each presented distinctly different approaches to the problems. Authors expressed concern about the appropriateness of the current "wealth neutrality" standard because it measures taxpayer equity; authors felt the Impact Aid program should focus more on student equity. Authors also advocated incorporating a vertical equity component to recognize that some students have greater needs.

Services

For FY 1993, 2,451 school districts received Section 3 payments totaling $721,957,000 and 260 districts received Section 2 payments totaling $16,293,000, which became part of the general operating funds of the districts. In addition, 14 school districts received disaster assistance totaling $41,185,000 (III.3).

Program Administration

Calculating Section 2 entitlements currently requires a cumbersome computation of a "need-based entitlement," based on current revenue, expenditures, total assessed value of real property in the district, and estimated current assessed value of the Federal property, as well as a "maximum entitlement," based on estimated current assessed value of Federal property and the district's tax rate. The lesser of the two entitlements is then pro-rated to determine the actual payment. Because the fiscal data needed to compute the need-based entitlement do not become available until after the fiscal year for which the payments are made, Section 2 payments are delayed for many months. Furthermore, the need-based entitlement calculation usually has little effect on the final payment amount. Basing Section 2 payments solely on the maximum entitlement would substantially improve the efficiency of Section 2 administration and allow more timely payments.

Management Improvement Strategies

A 1989 study of the Impact Aid computer system recommended that the system be reorganized and updated to improve the efficiency of information processing and to increase access to data for program staff. The study described two alternative types of computer systems that would achieve the desired improvements (III.4). After reviewing these recommendations, the Department decided to redevelop the entire system. Improvements to date include automation of front-end data preparation, entry and error-correction, and redevelopment of system outputs; redevelopment of internal processing is in progress.

To improve the timeliness of Impact Aid awards, the Department proposed to use prior year student counts and related data to calculate current year payments, and Congress included language in the FY 1993 appropriations bill to permit this change. Use of prior year data enables the program to award funds 6 to 8 months earlier than when the law required payments to be based on current year data.

III. Sources of Information

  1. Joel Sherman, Analysis of the Wealth of School Districts that Receive Impact Aid (Washington, DC: Pelavin Associates, April 1988).

  2. Joel Sherman, "Review of School Finance Equalization Under Section 5(d)(2) of P.L. 81-874, the Impact Aid Program"; Richard Salmon, "Equity Standards for State School Finance Programs: Philosophies and Standards Relevant to Section 5(d)(2) of the Federal Impact Aid Program"; K. Forbis Jordan, "Equalization and Impact Aid: National Leadership or Maintenance of the Status Quo"; Allan Odden, "Broadening Impact Aid's View of School Finance Equalization"; Robert Berne and Leanna Stiefel, "Equity Standards for State School Finance Programs: Philosophies and Standards Relevant to Section 5(d)(2) of the Federal Impact Aid Program" (Washington, DC: Pelavin Associates, June 1992).

  3. Program files.

  4. Dave Naden, Office of Impact Aid Computer System: Feasibility Study (Washington, DC: Decision Resources Corporation, 1989).

IV. Planned Studies

None.

V. Contacts for Further Information

Program Operations:
Charles Hansen, (202) 260-2002

Program Studies:
Stephanie Stullich, (202) 401-1958

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[Follow Through--Grants to Local Education Agencies and Other Public and Private Nonprofit Agencies, Organizations and Institutions to Provide Comprehensive Services to Low-Income Children in Kindergarten and the Primary Grades] [Table of Contents] [Impact Aid: Construction]