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THE EFFECTS OF A PERFORMANCE-BASED FUNDING INCENTIVE PROGRAM
ON THE PER-PUPIL FISCAL EQUITY OF
A STATE FOUNDATION FINANCE SYSTEM













By

BRIAN KENNETH MARCHMAN


A DISSERTATION SUBMITTED TO THE GRADUATE SCHOOL
OF THE UNIVERSITY OF FLORIDA IN PARTIAL FULFILLMENT
OF THE REQUIREMENTS FOR THE DEGREE OF
DOCTOR OF PHILOSOPHY

UNIVERSITY OF FLORIDA
























Dedicated to the students of Florida's public schools -- past, present, and future --

the inspiration for this research.














ACKNOWLEDGEMENTS


I had the fortune of completing this research project under the supervision of a

talented and insightful group of educators. I thank, first and foremost, the chair of my

committee, Dr. R. Craig Wood, who developed in me a keen interest for public school

law and finance, and guided me to the completion of a study in which I am quite proud.

Dr. James L. Doud, who always saw the promise of an education leader in me, and let me

know it every time we met, was also instrumental. Dr. David M. Miller was a

tremendous asset in the quantitative sections of this study. In addition to his expertise,

Dr. David S. Honeyman always saw the scholar in me I sometimes struggled to see in

myself. And Dr. Richard K. Scher, from whom I initially learned about the tremendous

challenges facing our public schools, helped motivate and inspire me to work toward

solutions.

My mentors at P.K. Yonge Developmental Research School are also especially

worthy of acknowledgement. Without the continual support and encouragement of Dr.

Frances Vandiver, Director, and the warmth and nurturing of Mrs. Chris Morris,

Principal, this study would not have materialized. Both have immeasurably enriched my

professional life.

This research project would not have been possible without the love and

encouragement of my family, most of all my parents Frederick K. and Gail Marchman,








and my brother Brent H. Marchman. All three proved to be constant sources of support

in this endeavor, invaluable in its completion.

My grandparents, Fred K. Marchman and Marguerite Marchman, as well as

Joseph D. Love (deceased) and Leila Ruth Love, also supported my work. "Pop" (Fred

K. Marchman), in particular, who was unquestionably capable of doing so, never

completed a doctorate degree in his distinguished career as a public school educator.

Duties to his country, family, and a booming school system kept him from its completion,

but not from encouraging his grandson to complete his.

Lastly, I wish to express my deepest appreciation, respect, and love to my wife,

Stephanie Marusak Marchman, who always believed in me and my work.














TABLE OF CONTENTS


PAGE

ACKNOWLEDGEMENTS.................... ........................................iii

ABSTRACT.............................. .... ....................................... vii

CHAPTER 1 INTRODUCTION........................... .............................

Introduction............................................................ .. .............
Statement of the Problem ................................................4
Purpose of the Study............................. ... .............................5
Significance of the Study................................ .............................5
Definition of Terms................................ ............................5
Delimitations and Limitations of the Study............................................9
Summary.................... .........................................9
Design of the Study................... .................................. 10
Notes..................... ............ ....... 10

CHAPTER 2 REVIEW OF THE LITERATURE.....................................14

Introduction.......................... ......... ............................... 14
Equity: A Theory of Social Justice.................... ....................14
The Theory of Per-Pupil Funding Equity.............................................16
History of the Theory of Equity in Education Finance..............................17
Litigation Related to Equity of School Finance.......................................22
The Florida Formula: The Florida Education Finance Plan........................51
The Theory of Performance-Based Funding Incentive Programs.................53
The Florida School Recognition Program.............................................55
Summary........................ ..... .. ...........................58
Notes................................. .........................................58

CHAPTER 3 METHODOLOGY................. .................................73

Introduction................. .... ........ ................................73
Research Design .............. .............................................74
Measures of Horizontal Equity................................ ....................74
Measures of Wealth Neutrality............................ ......................82
Summary................................... ........................................ ........ 85








Notes...................................... ............................ 85

CHAPTER 4 RESULTS............................. .................................88

Introduction........................... ........ .................................. 88
Measures of Horizontal Equity.......................... ..................... ...89
M measures of W health Neutrality..................................................... 107
Interpretation of Results................................... ............... 112
Summary.............................................. 116
Notes...... .... .....................................17

CHAPTER 5 SUMMARY, CONCLUSION AND IMPLICATIONS................121

Introduction...............................................................................121
Summary of Research Questions...................... ........................121
Conclusions........................... ... ......................................124
Implications.......................... ..... ....................................126
Notes................................................ 127

REFERENCES............... ......... ....... ................................128

BIOGRAPHICAL SKETCH............................. ..............................135













Abstract of Dissertation Presented to the Graduate School
of the University of Florida in Partial Fulfillment of the
Requirements for the Degree of Doctor of Philosophy

THE EFFECTS OF A PERFORMANCE-BASED FUNDING INCENTIVE PROGRAM
ON THE PER-PUPIL FISCAL EQUITY OF
A STATE FOUNDATION FINANCE SYSTEM

By

Brian Kenneth Marchman

August 2004


Chairperson: R. Craig Wood
Major Department: Educational Leadership, Policy and Foundations

The purpose of this research was to extend fiscal equity analysis to include

performance-based incentive funds dispersed in addition to the general state education

fund distributed through a state foundation finance system. Both horizontal equity and

wealth neutrality were evaluated. The study included analysis of the equity of the

distribution of public funds through the Florida Education Finance Program (FEFP) both

without and with the advent of performance-based incentive funds distributed to Florida's

public school districts by way of the Florida School Recognition Program (FSRP).

Research questions addressed possible shifts in equity of the FEFP over a five-

year period from 1998-99 and 2002-2003, as a result of the inception of the FSRP

incentive funds. Program funding increased steadily over each year of the five-year

period, growing from $27,603,881 in 1998-1999 to $137,958,067 in 2002-2003.








The effects of a performance-based incentive funding program on the fiscal equity

of school funding in Florida since the inception of the FSRP was determined using

statistical measures. The results of the study indicated that, without performance-based

incentive funds, the FEFP was a highly equitable funding distribution system.

Conversely, performance-based incentive funds increased the variation in the distribution

of public revenues and indicated a disequalizing effect on per-pupil school funding in the

state of Florida.

A number of measures of univariate dispersion were employed to examine the

horizontal equity of the funding formula. Calculations of the mean, median, range,

restricted range, federal range ratio, variance, standard deviation, coefficient of variation,

relative mean deviation, McLoone Index, and Gini Coefficient all generally indicated a

decreased equity in the distribution of funds among Florida public school districts for

each of the five years since the inception of the FSRP. In addition, calculations of the

wealth neutrality also indicated a general trend toward decreased fiscal neutrality as a

result of FSRP performance-based incentive funding in the state of Florida. The analysis

found an increasingly positive relationship between funding per student and property

wealth per student in Florida's public school districts over the first five fiscal years since

the inception of the FSRP.













CHAPTER 1
INTRODUCTION


Introduction

The United States of America is commonly referred to as the "land of

opportunity." Public education is considered an essential institution for providing

opportunity for every young person in the United States.'

Equality, as it relates to educational opportunity, is a fundamental
principle in U.S. education. Democracy is best served by extending to all
children not only the ability to read, write, numerate, and compute but also
by providing an equal opportunity to attend schools that are adequate for
the achievement of self-realization, economic sufficiency, civic
responsibility, and satisfactory human relationships.2

The Tenth Amendment to the Constitution of the United States enables the states, by way

of state legislatures, to enact a system of public education for all of the American people.3

State legislatures in each of the fifty states are required by a state constitution to create

and maintain "thorough," "efficient," "effective," adequate," or "equal" systems of public

education.4

The state of Florida is required by its own state constitution to provide for a

"uniform, efficient, safe, secure, and high quality system of free public schools."5 Florida

carries out this constitutional requirement in part through the Florida Education Finance

Program (FEFP), which is the primary mechanism for the allocation of funds for the

operation of public schools in Florida.6 Since its enactment by the Florida Legislature in

1973, the formula-driven FEFP has established the following statute on equalized








funding: "To guarantee to each student in the Florida public educational system the

availability of programs and services appropriate to his or her educational needs which

are substantially equal to those available to any similar student notwithstanding

geographic differences and varying local economic factors."7

To ensure an equalization of educational opportunity, the FEFP formula accounts

for district disparities in (1) the local property tax bases; (2) education program costs; (3)

costs of living; and (4) costs for equivalent educational programs due to sparsity and

dispersion of the student population. Thus, the formula accounts for the disparate costs

of education programs, as well as the students' geographic location within the state. The

primary purpose of the FEFP is to determine financial allocation for education based

upon the unit of individual students participating in a specified educational program

rather than upon numbers of teachers or classrooms.8 At the time of its inception, the

FEFP was considered by education finance scholars to be "a national model for inter-

district equity."9

The financing of public schools has been considered in terms of fiscal equity for

nearly a century.10 An equitable distribution of public education is "one that offsets those

accidents of birth that would otherwise keep some children from having an opportunity to

function fully in economic and political life of the community."" Thus, the principle of

fiscal equity in education finance is generally defined as a "standard that reflects a

fundamental sense of fairness" to all students, who by definition, have varying

educational needs.12

Equity, as it relates to education funding, can be specifically defined in several

ways. Literature in the field of education finance refers primarily to three kinds of








equity: horizontal equity, vertical equity, and equal opportunity (also referred to as

"wealth neutrality" or "fiscal neutrality").13 Horizontal equity implies that all students

who are substantially equal should be entitled to an equal share of resources.14

Conversely, vertical equity recognizes the disparate educational needs of students and is

based on the principle that students, who are unequal by way of ability and need, require

unequal amounts of funding.15 Wealth neutrality describes the condition in which every

student has an equal opportunity to receive state funding, regardless of such factors as

property wealth, household income, or any other measures of"fiscal capacity."'6 Chapter

2 of this study provides a more thorough and complete review of the literature addressing

the development of the theory of equity as it relates to financing public education.

In 1997, the Florida's legislature enacted a performance-based funding incentive

program entitled the "Florida School Recognition Program" (FSRP).'7 The program was

created based on the Legislature's perceived need for a statewide device for recognizing

"outstanding faculty and staff in highly productive schools."18 The Legislature based its

rationale for the creation of FSRP on the fact that performance-based incentive programs

are "commonplace in the private sector and should be infused into the public sector as a

reward for productivity.""19 By enacting the FSRP, the Legislature intended "to provide

greater autonomy and financial awards to schools that sustain high performance or that

demonstrate exemplary improvement due to innovation and effort."20 By statute, the

Commissioner of Education establishes "statewide objective criteria for schools to be

invited to apply" for the program.21 Schools recognized by the program are considered

based on a minimum two (2) years of stipulated program data.22 All of Florida's public

schools, including charter schools, are eligible to participate in the program.23 Criteria








for recognition of schools, relying on both individual school and statewide data, "must

include, but are not limited to: (a) Improvement in the school's student achievement data;

(b) Statewide student achievement data; (c) Student learning gains when data becomes

available; (d) Readiness for postsecondary education data; (e) Dropout rates; (f)

Attendance rates; (g) Graduation rates; and (h) Cohort graduation rates."24 Recognized

schools "receive financial awards depending on the availability of funds appropriated and

the number and size of schools selected to receive an award.25 Florida Statutes, Section

231.2905, also stipulates the FSRP "shall utilize the school performance grade category

designations," described in Section 229.57.26

This study examines the effects of a performance-based funding incentive

program, specifically the FSRP, on the fiscal equity of a state finance system, namely the

FEFP. The effects of the FSRP on both horizontal equity and wealth neutrality will be

measured in this study.

Statement of the Problem

The purpose of this study was to extend equity analysis to include the effects of a

performance-based funding incentive program, the Florida School Recognition Program.

The study includes analysis of the effects on equity of the Florida Education Finance

Program without and with the Florida School Recognition Program for each of the five

(5) fiscal years most recently available since its inception, 1998-1999, 1999-2000, 2000-

2001, 2001-2002 and 2002-2003.








Purpose of the Study

The following three (3) research questions were addressed in this study:

1. Has the Florida Education Finance Program demonstrated changes in horizontal
equity with the advent of the Florida School Recognition Program between fiscal year
1998-1999 and 2002-2003?

2. Has the Florida Education Finance Program demonstrated changes in wealth
neutrality with the advent of the Florida School Recognition Program between fiscal
year 1998-1999 and 2002-2003?

3. What trends exist, if any, with regard to equity of the Florida Education Finance
Program since the inception of the Florida School Recognition Program?

Significance of the Study

As government increasingly looks to the private sector for models to increase

effectiveness, ensure accountability, and reward effort, more and more performance-

based incentive programs are being implemented. Programs such as the Florida School

Recognition Program have been implemented "to provide greater autonomy and financial

awards to schools that sustain high performance or demonstrate exemplary improvement

due to innovation or effort."27 Such implementation raises the issue of fiscal distribution

with regard to a system of funding public education established on the basis of equity, the

Florida Education Finance Program. This investigation serves as an examination of the

effects of a performance-based funding incentive program on the fiscal equity of a state

finance system.

Definition of Terms

The following list of alphabetized terms are frequently employed in this study and

are therefore defined in this chapter to establish their consistent meaning throughout the

paper:








Base Student Allocation (BSA) is the amount of funding, per student participating in the

Florida Education Finance Program, determined annually by the Florida Legislature.28

District Cost Differential (DCD) refers to the index computed annually by the Florida

Commissioner of Education used to adjust the amount of funding to each of the school

districts in accordance with variations in the cost of living. DCDs are calculated by

averaging each district's Florida Price Level Index for the most recent three years, thus

reducing the immediate impact of sudden changes in the index.29

Eouitv refers to the condition for students, without regard to their geographic location or

socioeconomic status, in which an equal educational opportunity exists. Generally, the

literature on education finance defines equity as "the concept of a fair and just method of

distributing resources" to all of the children in the public school system.30 The condition

of equity accounts for the funds necessary to provide equal educational opportunity for

students after consideration of their differing needs.31

Equity issue refers to the extent to which the funds from the FSRP, in addition to the

allocations of the FEFP, had an effect on the equitable distribution of education funds in

the state.

Flat grant is a specified amount paid to a local school district without consideration for

either the local ability to pay for the educational services it funds or the varying needs of

individual districts. Qualification for flat grants was based exclusively on whether a

school district existed.

Florida Education Finance Program (FEFP) refers to the State of Florida's formula-

driven system of allocating of funds used to finance public K-12 education. The program








accounts for varying program costs, as well as implementing such programs in varying

parts of the state.33 A detailed explanation of the FEFP can be found in Chapter 2.

Florida School Recognition Program (FSRP) "provides financial awards and greater

autonomy to schools that sustain high performance or demonstrate exemplary

improvement due to innovation and effort. The Department of Education publicizes the

accomplishments of recognized schools for review and possible adoption by other

schools."34 A detailed explanation of the FSRP can be found in Chapter 2.

Full-time equivalent (FTE) is a calculation used to arrive at a total number of students

within a given district based upon the number of contact hours of instruction received by

each student annually in the FEFP. "An FTE for FEFP funding purposes is one student

in membership in one or more FEFP programs for a school year or its equivalent."35

Horizontal equity means that students who are alike are entitled to equal shares. This is

commonly referred to in the literature as an "equal treatment of equals."36 Horizontal

equity is a concept applied at the level of the individual student, meaning students who

are "equally situated" in varying programs, whether general education, "at-risk" or

"educationally disadvantaged," or special education.37

Program cost factors are included in the funding formula so that each program is

allocated an "equitable share of funds in relation to its relative cost per student." This

mechanism accounts for the varying expense of operating different programs.38

Property-poor districts are those public school districts below the mean when compared

to funding level for all districts.

Property-rich districts are those public school districts above the mean when compared to

funding level for all districts.








Public education refers to educational programs financed on behalf of the state of Florida

and its sixty-seven (67) school districts, for the collective good of the state and those

districts, for grades pre-kindergarten through twelve. Thus, the term "public education"

in this study does not include adult education, higher education, or private education.

School district refers to the government entity in Florida that is synonymous, in terms of

geographic boundaries and representation, with its sixty-seven (67) counties. This study

includes all of Florida's sixty-seven (67) public school districts.

Student refers to any individual in the state in attendance in a public school district in

grades pre-kindergarten through twelve. Not included in this definition are students in

private schools, community colleges, universities, or adult education programs.

Vertical equity is the principle that asserts that students, both as individuals and when

considered collectively, have varying educational needs.39 Thus, the concept of vertical

equity "recognizes that students are different and states the positive requirement that

unequals receive appropriately unequal treatment.'"4

Wealth neutrality, or fiscal neutrality, is the extent to which the amount of funding per-

pupil in each school district is dependent upon the amount of property wealth per student

in each district. Wealth neutrality is commonly referred to in the education finance

literature as "equality of opportunity."41

Weighted full-time equivalent (WFTE) refers to the sum of the products of FTEs and the

corresponding weight of each program based on individually attributable program

expenses as a result of special student characteristics. Thus, the FTE of each program is

multiplied by the corresponding cost factor for that program, "reflecting the relative costs

of the programs as represented by the program cost factors."42








Delimitations and Limitations of the Study

Much attention in the field of education finance has turned to the study of

adequacy. However, this dissertation does not address the concept of adequacy. The

question of whether an appropriate or sufficient level of educational expenditures is being

provided to every student has not been studied. The focus of this study is the extent to

which resources have been distributed with regard to equity, not the extent to which

enough educational resources exist.

Furthermore, within this focus on equity, student equity, rather than taxpayer

equity, is addressed. No credence is given in this study to those who bear the

responsibility of taxation.

Additionally, while this study examines the effects of horizontal equity of the

distribution, as well as the wealth neutrality for students across the state of Florida, the

effects on vertical equity were not studied.

Also, while assessments of the effects on fiscal equity are made between districts,

no effort has been made in this study to examine the effects on equity within each district

(intra-district), nor on equity from individual school to school.

Summary

The FEFP was formulated by the state of Florida with the intent of equitably

distributing financial resources for public education. Consideration is given in the

formula to provide for both horizontal equity and wealth neutrality among the sixty-seven

(67) public school districts in Florida. Beginning in fiscal year 1998-1999, the Florida

Legislature employed the FSRP to financially recognize high achieving schools within

these districts. The purpose of this study was to examine the equity of the FEFP without








and with the implementation of the FSRP in the five (5) years 1998-1999 through 2002-

2003. The investigation centered on the per-pupil horizontal equity of the distribution, as

well as the per-pupil wealth neutrality of the distribution.

Design of the Study

Chapter 1 was presented as an introduction to the nature of the problem, as well as

the research questions that are addressed within this study. Chapter 2 contains an

extensive review of the literature pertaining to the field of education finance, with

particular attention given to the issue of equity. Chapter 3 includes a description of the

methodology employed in this study. Chapter 4 details the results of the investigation.

Chapter 5 serves as a summary, provides conclusions, and discusses the implications and

recommendations resulting from the study.


Notes

Robert Berne and Leanna Stiefel. "Concepts of School Finance Equity: 1970 to
the Present," in Equity and Adequacy in Education Finance: Issues and Perspectives,
edited by Helen L. Ladd, Rosemary Chalk, and Janet S. Hansen (National Academy
Press, Washington, D.C., 1999), 7.

2 Vern Brimley, Jr. and Rulon R. Garfield, Financing Education in a Climate of
Change (Boston: Allyn and Bacon, 2002), 59.

3 U.S. Constitution, amendment X.

4 David C. Thompson, R. Craig Wood, and David S. Honeyman, Fiscal
Leadershipfor Schools: Concepts and Practice (New York: Longman, 1994), 282-286.

5 Florida Constitution, article IX, section 1.

6 Florida Statutes 236.012, art. 1.

SIbid

8 Florida Department of Education, 2001-2002 Funding for Florida School
Districts (Tallahassee, FL: Florida Department of Education, Statistical Report, EIAS
Series 2002-03, August 2001), 1.









9 Yasser Nakib and Carolyn D. Herrington, "The Political Economy of K-12
Education Finance: The Context of a Fast Growing Large State," Journal ofEducation
Finance 23 (1998): 352.

10 James W. Guthrie, Walter I. Garms, and Lawrence C. Pierce, School Finance
and Education Policy: Enhancing Educational Efficiency, Equality, and Choice, 2nd ed.
(Englewood Cliffs, NJ: Prentice Hall, 1988), 13.

Berne and Stiefel. "Concepts of School Finance Equity," 7.

12 R. Craig Wood and David C. Thompson, Education Finance Law:
Constitutional Challenges to State Aid Plans-An Analysis ofStrategies, No. 50 in the
NOLPE Monograph Series (Topeka, KS: National Organization on Legal Problems in
Education, 1993), 1.

13 Robert Berne and Leanna Stiefel, The Measurement of Equity in School
Finance (Baltimore: Johns Hopkins University Press, 1984), 13.

14 Ibid.

15 Ibid., 13-17.

6 Ibid., 17.

7 Florida Statutes, 231.2905. See also Evaluation Systems Designs of
Tallahassee and Florida Department of Education, Florida School Recognition Program
1999-2000: Best Practices for Higher Student Achievement (Tallahassee, FL: Florida
Department of Education, 2000), 1.

Florida Department of Education, Florida School Recognition Program
(Tallahassee, FL: Florida Department of Education). Retrieved June 17, 2002, from
http://www.fim.edu/doe/bin00048/leg.htm.

19 Florida Department of Education, Florida School Recognition Program
(Tallahassee, FL: Florida Department of Education). Retrieved June 17, 2002, from Ibid.

2o Ibid.

21 Ibid.

22 Ibid.

23 Ibid.


24 Ibid.









25 Ibid.

26 Ibid.

27 Florida Statutes 231.2905, art. 1.

28 Florida Department of Education, 2001-2002 Funding for Florida School
Districts (Tallahassee, 2001), 12.

26 Florida Statutes, sec. 236.081, art. 2.

30 Thompson, Wood, and Honeyman, 56-57.

31 James W. Guthrie, Walter I. Garms, and Lawrence C. Pierce, School Finance
and Education Policy: Enhancing Educational Efficiency, Equality, and Choice, 2nd ed.
(Englewood Cliffs, NJ: Prentice Hall, 1988), 130.

32 Thompson, Wood, and Honeyman, 216.

33 Florida Statutes, sec. 236.012, art. 1.

34 Florida Department of Education Technical Assistance Document GE356,
Florida's System for High-Quality Schools: The Basics of: Student Accountability,
School Accountability, and Educator Accountability (Tallahassee, FL: Office of Policy
Research and Accountability and the Division of Public Schools Florida Department of
Education, 1999), 14.

35 Florida Department of Education, 2001-2002 Funding for Florida School
Districts (Tallahassee, FL, 2001), 10.

36 Percy E. Burrup, Vern Brimley Jr., and Rulon J. Garfield, Financing Education
in a Climate of Change, 7" ed., (Boston: Allyn and Bacon, 1999), 63.

37 Robert Berne and Leanna Stiefel, The Measurement of Equity in School
Finance (Baltimore: Johns Hopkins University Press, 1984), 18.

38 Florida Department of Education, 2001-2002 Funding for Florida School
Districts (Tallahassee, FL, 2001), 10.

39 Burrup, Brimley, and Garfield, 63.

40 Berne and Stiefel, 1984, 13.

41 Ibid., 26.





13


42 Florida Department of Education, 2001-2002 Funding for Florida School
Districts (Tallahassee, FL, 2001), 12.













CHAPTER 2
REVIEW OF THE LITERATURE


Introduction

The purpose of this study was to examine the effects of a performance-based

funding incentive program, the Florida School Recognition Program (FSRP), regarding

the equity of a state education finance system, the Florida Education Finance Program

(FEFP). This chapter is a review of the relevant literature, including discussions of

equity as a theory of social justice, the theory of per-pupil funding equity, the history of

equity in education finance, litigation relevant to equity in education finance, the theory

of performance-based funding incentive programs, as well as a thorough description of

the FEFP and the FSRP.

Equity: A Theory of Social Justice

Equity is not necessarily the same concept as equality. According to Thompson,

Wood, and Honeyman, "equity is not blind equality."' Thus, equity is the concept of a

"fair and just method of distributing resources"2 to each student in public education,

regardless of social or economic standing. Equity, therefore, implies "distributive

justice,"3 the philosophy that holds that although social and economic inequalities are

permissible, they may only exist if they are to the benefit of "the least advantaged

members of society."4

Political and legal philosopher John Rawls formulated a theory of social justice.

Rawls equated justice with the concept of "fairness."5 According to Rawls, "justice is the








first virtue of social institutions, as truth is of systems of thought."6 Thus, to achieve

justice, or equity, society must function with regard to the "difference principle" which

holds, "all social primary goods-liberty and opportunity, income and wealth, and the

bases of self-respect-are to be distributed equally unless an unequal distribution of any

or all of these goods is to the advantage of the least favored."7

Rawls's "difference principle" necessitates a system of public education that

accounts for differences among its students. He rejects the notion that there may be times

or circumstances when the entire society may benefit from certain restrictions on equality

of opportunity.8 Thus, Rawls underscores an emphasis on fair opportunity for all in

society and assumes that all will benefit from particularized attention to the least

advantaged. Additionally, he claims that equality necessarily "requires equal life

prospects in all sectors of society for those similarly endowed and motivated."9 While

Rawls asserts that equal or fair opportunity may require a greater assistance of society to

children of deprived circumstances, he acknowledges that equal outcomes can never be

assured.'1

Rawls makes the case that an "equal treatment of equals" is a natural and basic

necessity in the general theory of justice. He claims government has the inherent

responsibility to treat all persons in like circumstances equally." Furthermore, he claims

if government fails to treat equals in an equal manner, it must provide "sufficient reason

not to do so."12 Rawls also asserted the coincidence of a child's geographical location or

whether it was born to poor parents would not be a sufficient reason to justify a disparity

in school revenues that would have the effect of creating an educational disadvantage.13








The Theory of Per-Pupil Funding Equity

By definition, an equitable system of education funding requires the state to bear a

greater burden of the cost of a public education for a child in a less wealthy district than

that of a child in a wealthier district. In a 1906 groundbreaking monograph based on his

doctoral dissertation, Ellwood P. Cubberley became the first modem scholar to address

the concept of equity in education finance. Based on the assumption that all children are

equally important, Cubberley claimed society owed to each child an equal share of state

wealth. Additionally, Cubberley supported the concept that all children within a state

were entitled to the same educational advantages and opportunities.14 Cubberley argued,

"the duty of the state is to secure for all as high a minimum of good instruction as is

possible."15

Instead of using a census measure of total children in a given state or district,

Cubberley advised the use of enrollment figures in the schools. A census measure,

Cubberley claimed, "has no educational significance in that it does not place a premium

on any effort that makes for a better education."'6 As a result, the most putative units to

measure educational needs and to distribute state financial resources have been some

variation of per-pupil allocation formulas.17 Thus, Cubberley established the theoretical

foundation for the allocation of public funds based upon the number of students rather

than the ability to pay taxes or any other measure. In fact, Cubberley claimed the

distribution of state funds based on the amount of taxes raised in each school district

would have the effect of "producing very unequal and unjust results."'8 Thus, in order to

ensure equal educational opportunity to every child in the state, Cubberley theorized the








"state as a whole" should assume the responsibility of allocating the necessary funds to

districts that lack the ability to generate revenue equivalent to other districts in the state.19

History of the Theory of Equity in Education Finance

Harlan Updegraff advanced Cubberley's theories of equity in education finance

by maintaining that state aid should be advanced to poorer school districts. Furthermore,

he became known as the first scholar to raise questions pertaining to the most appropriate

distribution of financial resources among school districts.20 Updegraff proposed the

theory that districts should not be punished for providing equal tax yield for equal tax

effort. Such a system, he claimed, would accomplish the aims of upholding equity, as

well as maintaining local control of education.21 This was the first time a system was

envisioned in which every child could be assured at least a minimum level of education

funding in relation to the levels of other children in the state, regardless of location within

a state.2 Thus, Updegraff's work served to advance the idea that it is the responsibility

of the state to allocate enough financial resources to individual school districts so as to

provide a minimum level of educational programs for each child in the state.

The theory of fiscal equity was furthered developed by George Strayer and Robert

Haig, who proposed characteristics of an ideal funding formula, one that would result in

an equitable system for funding education.23 This revolutionary concept was formulated

on the principle of equality of educational opportunity. This perfectly equitable funding

formula would: (1) ensure equal educational facilities to every child in the state, (2)

provide for uniform tax effort throughout the state, (3) ensure that tax effort is related to

the ability to pay, and (4) in no way hinder the ability of local districts to raise revenues








above an established minimal level for the purpose of providing a better education for

their children.24

Strayer and Haig became known as the first to advance the concept of a

"minimum foundation" program for funding public education.25 This concept,

considered momentous in the early 1920s, was based on three governing principles.

First, the state bears the responsibility to provide every child some uniformly available

minimum level of education. Additionally, the state must account for the ability of local

school districts to generate tax revenue for public schools. Lastly, Strayer and Haig

called for the distribution of funds for public education through a state department of

education. Thus, for the first time, it was proposed that state funds would provide the

initial foundation for the funding of public schools, rather than the historical reliance on

predominantly local tax revenues.26 Clearly, this was a considerable break from the past

as public education had been financed nearly exclusively by local tax efforts until that

time.

Strayer and Haig, who were opposed to the use of flat grants to finance schools

because of the failure of such funding devices to account for the varying need of districts,

advanced the concept of a minimum foundation approach to financing schools. A

minimum foundation program of financing schools combines the financing efforts of

local school districts with financing efforts of the state, with the state bearing the

responsibility of providing a required minimum educational program. The local district,

based on the ability to pay, contributed to this base level through a required local effort.27

Strayer and Haig established four goals for their minimum foundation formula: (1) the

wealthiest district was used as the base for defining the minimum educational program to








be provided throughout the state, (2) local initiatives in raising revenue were encouraged,

(3) local efficiency was rewarded, and (4) local districts were to be fiscally competitive

so that differences among them would indicate local choices, rather than the effects of

ability to pay.28 Thus, a minimum foundation program "embodies the ideal that all pupils

throughout each state, regardless of their geographic location, should be entitled to

participate and receive a minimum level of educational services... Unfortunately, all too

often state legislatures have focused on the term minimum which has resulted in minimal

programs that have failed to achieve adequacy or a high level of fiscal equalization."2 A

pure foundation program, according to Strayer and Haig, had to guarantee a minimum

per-student funding amount, generate a uniform local tax effort, as well as provide for the

capacity of local school districts to generate "local leeway funds."30

A state foundation finance system is designed to bring all of the school districts in

the state to a specified minimum spending level per pupil. Stated mathematically, the

formula for the foundation program was stated as

Si = (EPi x Fstae)- (Val- state)

where Si was the state aid to the i district; Pi was the sum of the number of students as

calculated in the state for the i district; Fstte was the foundation dollar-per-pupil

expenditure set by the state; Vali was the assessed valuation for the, district; and rsta was

the tax rate established by the local school district. Foundation systems are currently the

chosen method for financing public education by a majority of the states.31 In fact, forty

of the fifty states employed the used of some variation of the foundation system at the

conclusion of the Twentieth Century that was first proposed by Strayer and Haig in the

early 1920s.32








Unlike Cubberley and Updegraff, who believed the state should reward effort in

raising revenue on behalf of the local district and provide incentives for local support,

Strayer and Haig adamantly opposed such a notion. Strayer and Haig challenged the

theories which had been advanced by Cubberley and Updegraff, stating that "any formula

which attempts to accomplish the double purpose of equalizing resources and rewarding

effort must contain elements which are mutually inconsistent. It would appear to be more

rational to seek to achieve local adherence to proper educational standards by methods

which do not tend to destroy the very uniformity of effort called for by the doctrine of

equal educational opportunity."33 Thus, even at the outset of education finance research

and theory, a fundamental rift in beliefs developed. While some theorists have

subscribed to the concept that wealthier local districts should not be penalized for the

ability to raise revenue in excess of that of poorer districts, others have contended doing

so will result in increasing inequities. Such theoretical debate has continued in the field

of education finance, leaving resolutions only to the courts.34

Paul J. Mort advanced the work of foundational programs of Strayer and Haig by

developing mechanisms for quantifying educational need. In doing so, Mort defined

educational need of a school district as "the composite of all of those elements in the

community that would affect the cost of the public educational offering demanded by a

state program making available to all children a satisfactory minimum educational

opportunity. The relative weighing of each element would be determined by its effect on

the cost."35 The state, according to Mort, should be responsible for meeting the

educational need of each child in a district, by providing the necessary resources. Mort

believed that the cost for an educational opportunity should take into account the measure








of educational need.36 Thus, Mort contributed to the study of equity in the field of

education finance by introducing a concept for making allowances for the variations

among and between student populations.

These adjustments, which usually result in additional costs, include programs for

those students classified with exceptional needs, as well as those enrolled in vocational,

magnet, or compensatory education programs.37 The adjustments defined by Mort also

apply to such variations in economies of scale, or the sparsity factor.38 Mort has been

credited with creating the "weighted pupil" measure, or adjusted instruction unit, used as

part of most foundation programs to this day.39

Roe L. Johns and Edgar L. Morphet, two ofMort's disciples, later expanded on

his theory of equalization of educational opportunity based on educational need. They

did so by identifying additional variables that had an effect on district educational costs,

including such factors as population sparsity and density.40

Henry C. Morrison, unlike Mort, became known for advocating a full state

funding model in which all revenues for public schools would be raised and allocated at

the state, rather than the district, level. Due to his belief that funding inequities stemmed

from the flawed mechanism of localized financing of schools through a property tax,

Morrison supported the concept of funding education exclusively by way of state

revenues rather than through any reliance on a localized property tax.41 According to

Morrison, state revenues to support a full state financing model could be derived from a

combination of sources including general property taxes levied at the state level, a state

income tax, state corporate taxes, and income from state school lands or invested school

funds.42 Morrison further concluded that public education was inherently a state








function,43 a constitutional responsibility most efficiently addressed by the various state

governments, rather than local school districts.4 Due to the innate conflict he identified

in the distribution of state funds to districts of varying wealth, while simultaneously

ensuring an equal tax burden for each district, Morrison became a staunch advocate for a

full state funding model as a means of ensuring an equitable education for all children.

As the theory of equity in education finance has continued to be developed, the

states have accordingly modified the distribution formulas. The theories credited to

Cubberley, Updegraff, Strayer, Haig, Mort, Johns, Morphet, and Morrison serve as the

basis for ever-evolving state education funding formulas, many of which have become

the basis of legal challenges. The following section contains a description of the

litigation related to equity in school finance.

Litigation Related to Equity of School Finance

Litigants have challenged the apportionment of state funds for public schools

under the federal or state constitution in virtually every state,45 making the way for both

federal and state courts to significantly influence the way schools are financed in this

country.46 As early as 1859, in a case involving land that the Northwest Ordinances of

1785 and 1787 had set aside to fund schools, the United States Supreme Court decided

that this Indiana school finance law "[was] a perfectly just one ... those plaintiffs have

no right to call on this court to interfere with the power exercised by the state legislature

in laying and collecting taxes and in appropriating them for educational purposes, at its

discretion."47 In the Kalamazoo case of 1874, the Michigan Supreme Court's decision

established a legal system of taxation for funding secondary education.48 And in 1954,

the Supreme Court tackled the constitutionality of segregation in schools under the equal








protection clause of the Fourteenth Amendment to the United States Constitution.49 In

Brown v. Board ofEducation, the Court ruled that the "separate but equal" doctrine

established by Plessy v. Ferguson had no place in public education and segregation in

schools was unconstitutional.5

Legal challenges to state funding formulas with regard to equity have largely been

filed by parents, or coalitions of parents, of children in property-poor school districts over

the methods states use to distribute revenues among school districts.51 In cases where

systems of state school finance have been deemed unconstitutional, the courts have held

that "(1) education is a state function and the legislature is responsible for its equitable

provision; (2) all children are children of the state and not the locality; and (3) all taxes

are state taxes regardless of where they are actually levied."52 Additionally, in cases

decided in favor of the plaintiffs based on a marked difference between districts in terms

of per-pupil funding, courts have held "the legislature violates the state constitution when

it statutorily creates educational privilege for some and disadvantage for others."53

Since 1960, scholars have described "three waves" of school finance litigation.54

First, litigation focused on whether disparities in school financing violated the Equal

Protection Clause of the Fourteenth Amendment to the United States Constitution.5 The

second wave of cases challenged the inequitable distribution of state funds to public

schools on the basis of state constitutional provisions, including the states' equal

protection clauses and particular education articles.56 And the final phase of school

finance litigation concerned whether schools were adequately funded.57 The following

table (2-1) provides a summary of the cases relating to school finance litigation discussed

in this section.








Table 2-1. School Finance Equity Cases Listed in Chronological Order


Case
Springfield Township v.
Quick

Stuart v. School District
No. 1 of the Village of
Kalamazoo

State ex rel. Clark v.
Henderson


Brown v. Board of
Education

Mclnnis v. Shapiro




Burruss v. Wilkerson




Serrano v. Priest



Van Dusartz v. Hatfield



Shofstall v. Hollins




San Antonio Independent
School District v
Rodriguez


State Year Court Significance
Indiana 1859 Federal Upheld state school
finance law

Michigan 1874 State Established a legal system
of taxation for funding
secondary education


Florida



Kansas


Illinois


1935 State Court applied broad
meaning to term
"uniform" schools

1954 Federal Segregation in schools is
unconstitutional

1969 Federal Disparities in funding
school districts did not
violate the equal
protection clause


Virginia 1969 Federal Disparities in funding
school districts did not
violate the equal
protection clause

California 1971 State Disparities in funding
school districts violated
the equal protection clause

Minnesota 1971 Federal Disparities in funding
school districts violated
the equal protection clause

Arizona 1973 State Disparities in funding
school districts did not
violate the equal
protection clause


Texas


1973 Federal Disparities in funding
school districts did not
violate the equal
protection clause








Table 2-1. Continued

Case State Year Court Significance
Robinson v. Cahill New Jersey 1973 State School finance system
violated "thorough and
efficient" clause of state
education article


Milliken v. Green




Thompson v. Engelking




Olsen v. State



Horton v. Meskill



School Board ofEscambia
County v. State

Gindl v. Department of
Education


Pauley v. Kelly




Board ofEducation v.
Walter


Michigan




Idaho


1973 State Disparities in funding
school districts did not
violate the state equal
protection clause

1975 State Upheld funding system
under state education
article and equal
protection clause


Oregon 1976 State Upheld funding system
under state education
article

Connecticut 1977 State Held that the funding
system violated the state's
equal protection clause


Florida


Florida



West
Virginia



Ohio


1977 State Court defined "uniform
system" of schools

1979 State Upheld funding system
under state education
article

1979 State School finance system
violated "thorough and
efficient" clause of state
education article

1979 State Upheld funding system
under state education
article and equal
protection clause








Table 2-1. Continued


State Year Court Significance
Colorado 1982 State Upheld funding system
under state education
article and equal
protection clause


Georgia


Case
Lujan v. Colorado State
Board of Education



McDaniel v. Thomas




Board ofEducation v.
Nyquist



Hornbeck v. Somerset
County Board of
Education


DuPree v. Alma





Fair School Finance
Council of Oklahoma v.
State


Richlandv. Campbell




Helena Elementary School
District v. State


New York 1982 State Upheld funding system
under state education
article and equal
protection clause

Maryland 1983 State Upheld funding system
under state education
article and equal
protection clause

Arkansas 1983 State Disparities in funding
school districts violated
the state equal protection
clause and education
article

Oklahoma 1987 State Upheld funding system
under state education
article and equal
protection clause


South
Carolina



Montana


1988 State Upheld funding system
under state education
article and equal
protection clause

1989 State School finance system
violated "equality of
educational opportunity"
clause of state education
article


1982 State Upheld funding system
under state education
article and equal
protection clause








Table 2-1. Continued

Case State Year Court Significance
Edgewood v. Kirby Texas 1989 State School finance system
violated "efficient" clause
of state education article


Kukor v. Grover




Rose v. Council for Better
Education


Abbott v. Burke



St. Johns County v.
Northeast Florida Builders
Association

Coalition for Equitable
Funding v. State


Florida Department of
Education v. Glasser


Tennessee Small School
Systems v. McWherter


Roosevelt Elementary
School District v. Bishop


Wisconsin 1989 State Upheld funding system
under state education
article and equal
protection clause


Kentucky


1989 State School finance system
violated "efficient" clause
of state education article


New Jersey 1990 State School finance system
violated "efficient" clause
of state education article


Florida


1991 State Court defined meaning of
"uniform" schools


Oregon 1991 State Upheld funding system
under state's "uniform"
clause of education article

Florida 1993 State Upheld funding system
under the state education
article

Tennessee 1993 State School finance system
violated state's equal
protection clause

Arizona 1994 State School finance system
violated "uniform" clause
of state education article


City ofPawtucket v.
Sundlum


Rhode Island 1995 State


Upheld funding system
under state education
article and equal
protection clause





Early Litigation Under the Federal Equal Protection Clause

Federal courts have consistently held that disparities in educational funding do not

violate the Equal Protection Clause of the Fourteenth Amendment to the United States

Constitution. For instance, in Mclnnis v. Shapiro, students in Cook County, Illinois

challenged the constitutionality of their state's school finance laws.58 The students

claimed that the state laws violated their Fourteenth Amendment right to equal protection

because they allowed for differences in funding per student from district to district,


Table 2-1. Continued

Case
Campbell County School
District v. State



DeRolph v. State



Vincent v. Voight




Lake View School District
v. Huckabee




Claremont School District
v. Governor


Campaign for Fiscal
Equity v. State


State Year Court Significance
Wyoming 1995 State School finance system
violated state's equal
protection clause and state
education article

Ohio 1997 State School finance system
violated "efficient" clause
of state education article

Wisconsin 2000 State Upheld funding system
under state education
article and equal
protection clause

Arkansas 2002 State School finance system
violated state's equal
protection clause and
"efficient" clause of
education article

New 2002 State School finance system
Hampshire violated "adequate" clause
of state education article

New York 2003 State School finance system
violated state education
article








thereby providing some students with a better financed education than other students who

had equal or greater educational needs.59 The federal district court recognized that

inequities in funding were "readily apparent" in this case, however the crucial question

was whether such inequities were unconstitutional.60 The court ruled that states have

wide discretion in enacting laws that affect some groups differently than others, and the

Fourteenth Amendment is "offended only if the classification rests on grounds wholly

irrelevant to the achievement of the State's objective."61 In applying this standard, the

court held that unequalul educational expenditures per student, based upon the variable

property values and tax rates of local school districts, do not amount to an invidious

discrimination. Moreover, the statutes which permit these unequal expenditures on a

district to district basis are neither arbitrary nor unreasonable."62

A similar conclusion was reached in Burruss v. Wilkerson, a federal district court

case in which Virginia parents and students claimed that the disparities in educational

funding between counties denied students an equal opportunity to education, thus

violating the Fourteenth Amendment to the United States Constitution.63 The court

concluded that "courts have neither the knowledge, nor the means, nor the power to tailor

the public moneys to fit the varying needs of these students throughout the State. We can

only see to it that the outlays on one group are not invidiously greater or less than that of

another. No such arbitrariness is manifest here.""6 Although both Mclnnis and Burruss

were appealed to the United States Supreme Court, both were affirmed without

comment.6

The merits of the use of the federal Equal Protection Clause in school finance

reform litigation reached the United States Supreme Court in 1973.66 In San Antonio








Independent School District v Rodriguez, parents brought suit on behalf of their children

who attended elementary and secondary schools in an urban school district in San

Antonio, Texas.67 They claimed that Texas' school finance system, which provided

poorer districts with less funding, violated the Equal Protection Clause of the Fourteenth

Amendment.68 In deciding whether or not Texas' school finance system was

constitutional, the Court had to determine whether it should apply "strict judicial

scrutiny" because the system discriminated against a suspect class, the poor in this case,

or because the system involved a fundamental constitutional right, namely education.69

The Court concluded that Texas's system should not be subjected to strict judicial

scrutiny because the system did not particularly disadvantage a suspect class70 and it did

not involve a fundamental right.71 The Court stated that it was "in complete agreement

with the conclusion of the three-judge panel below that 'the grave significance of

education both to the individual and to our society' cannot be doubted,"72 but in

determining whether a right is 'fundamental' or not did not turn on its societal

importance, but on "whether there [was] a right to education explicitly or implicitly

guaranteed by the Constitution."73 The Court held that because the system did not

involve a suspect classification or fundamental right, Texas' school finance system must

"be shown to bear some rational relationship to legitimate state purposes."74 In refusing

to interfere with an area traditionally handled by state legislatures,75 the Court upheld

Texas's educational funding scheme because it had a rational basis.76 In sum, the Court

held that

to the extent that the Texas system of school financing results in unequal
expenditures between children who happen to reside in different districts,
we cannot say that such disparities are the product of a system that is so
irrational as to be invidiously discriminatory. Texas has acknowledged its








shortcomings and has persistently endeavored--not without some success--
to ameliorate the differences in levels of expenditures without sacrificing
the benefits of local participation. The Texas plan is not the result of
hurried, ill-conceived legislation. It certainly is not the product of
purposeful discrimination against any group or class. On the contrary, it is
rooted in decades of experience in Texas and elsewhere, and in major part
is the product of responsible studies by qualified people.77

The United States Supreme Court's decision in Rodriguez closed the door to

litigants seeking to challenge disparities in educational funding between schools based on

the Equal Protection Clause of the Fourteenth Amendment. Consequently, litigants

pursuing equity in education funding have had to employ other legal arguments in court.

For instance, many litigants have argued that inequity in school funding violates various

state constitutional provisions.

Litigation Under State Constitutional Provisions

After the Rodriguez decision, rather than laying claim that education is a

fundamental right or the equal protection clause has been violated under the United States

Constitution, a second wave of school finance litigation emerged, focusing primarily on

state constitutions and the states' equal protection and education provisions." All state

constitutions include some type of provision for free public education within the state,79

thus providing litigants grounds to claim their state's school finance system violates the

state's education article.

The California Supreme Court's decision in Serrano v. Priestso is a seminal case

for legal challenges to public school finance systems. At issue in this case was whether

the equal protection clauses of the state and federal constitutions were violated because of

the disparities among districts in the amount of per-pupil funding caused by variations in

local property wealth.81 The court ruled that the right to education was a fundamental








right that could not be conditioned on property wealths The public school finance

system in this case failed the strict scrutiny standard applied by the court because the

gross disparities in district funding were not necessary to further local administrative

control. Significantly, for the first time in Serrano, a court applied the doctrine of fiscal

neutrality, the concept that local property wealth and educational revenues cannot be

correlated.83

Wealth neutrality was upheld when the court reviewed Serrano 11.84 In 1976, the

California Supreme Court addressed the matter of whether the state legislature adequately

dealt with the school finance inequities at issue in Serrano L The court established a

manageable standard for measuring educational opportunity by using the cost quality

concept. The court decided that "equal expenditure level per pupil in every district is not

educationally sound or desirable because of differing educational needs, equality of

educational opportunity requires that all school districts possess an equal ability in terms

of revenue to provide students with substantially equal opportunities for learning."85 As a

result of the court devising a wealth neutrality concept in Serrano, the foundation for

legal challenges based on equal protection was created.86 And significantly, since

Serrano, "many states made an effort to improve their method of financing education,"87

particularly by increasing the states' share in funding schools.88 In fact, only seven years

after Serrano, the costs of education were being shared almost equally by state and local

governments as states tried to correct disparities in funding between districts by

increasing the portion of education funding provided by the state."9

In Van Dusartz v. Hatfield,90 decided six weeks after Serrano, a United States

District Court in Minnesota held that the state's system of public school finance violated








the Equal Protection Clause of the Fourteenth Amendment. The court held that students

attending public school had a right to have their education unaffected by the variations in

the taxable wealth in their school district.91 The court did not require absolute uniformity

in expenditures, but looked to the state legislature to provide a more equitable public

school funding scheme.92

In Shofstall v. Hollins,93 the Arizona Supreme Court addressed the

constitutionality of the state's public school finance system. The court recognized that

the state constitution provided every child in its state with the fundamental right to a

basic education.94 The court held that in this case students were not being denied a right

to a basic education. Further, the court ruled that the school finance system need only be

rational, reasonable, and neither discriminatory or capricious to meet the requirements set

forth in the state's equal protection clause.95

Just thirteen days after the United States Supreme Court's decision in Rodriguez

and the year after the Serrano decision, the New Jersey Supreme Court announced its

landmark decision in Robinson v. Cahill,96 further promoting the concept of litigants

using state constitutional provisions to reform education finance. In Robinson, the court

found the New Jersey school finance system, which relied on local taxation to fund two-

thirds of its financing of public schools, to violate the state legislature's constitutionally

mandated public education provision.97 The court rejected the plaintiffs claim that

wealth constituted a suspect classification under the state constitution, thereby subjecting

the state's funding formula to heightened scrutiny.9' Similarly, the court refused to

recognize education as a fundamental right.99 Accordingly, the court held that the

funding formula did not violate the state's equality provision.'00 However, the court was








willing to order school financing reform based on the state constitution's education clause

which required provision of a "thorough and efficient system of free public schools for

the instruction of all the children in the State."1'0 The court held that the funding

disparities within the state proved that the state had failed to fulfill its obligation to

provide for the type of schools mandated by the state's constitution.102 Having found that

the state's school funding program violated the state constitution, the court eventually

ordered the implementation of a funding equalization plan.'03

In Milliken v. Green,'4 the Michigan Supreme Court was confronted with the

issue of whether the state's system of public school financing, which relied on the wealth

of local districts, thereby creating inequalities among schools, violated the equal

protection clause of Michigan's constitution.105 The court held that the state met its

constitutional obligation to provide its citizens with a basic system of public schools and

the Michigan Constitution did not require equal educational expenditures for all students

for there to be equal educational opportunity. Therefore, the court held that Michigan's

public education funding scheme was constitutional because absolute equality in funding

among schools was not required by the state's constitutional06

In 1975, the Idaho Supreme Court found the state's public educational finance

program to be constitutional in Thompson v. Engelking.107 At issue in the case was

whether the disparity in per-pupil funding among districts due to substantial reliance on

local ad valorem taxes to fund education violated the state's constitution, which required

a uniform system of public schools,'08 and whether the funding scheme denied the

plaintiffs equal protection of the law.1' The court held the present system of school

financing in the state neither denied the plaintiffs of their rights to equal protection of the








law under the state or federal constitution, nor violated the mandate of the education

article in the state constitution."0 The court stated that "[t]o do otherwise would be an

unwise and unwarranted entry into the controversial area of public school financing,

whereby this Court would convene as a 'super-legislature', legislating in a turbulent field

of social, economic and political policy.""' In this case, the court refused to classify the

right to education as fundamental and applied a rational basis standard of review.12

Once more, in 1976, the constitutionality of a state education funding system was

upheld in Olsen v. State."13 The issue in this case was whether the disparity in per-pupil

funding due to reliance on local wealth to fund schools, violated the state's constitutional

education provision. The court held that the Oregon Constitution only required the state

to provide a basic level of education to all students and did not dictate uniform per-pupil

funding throughout the state.14

In 1977, the Connecticut Supreme Court held that the state's public school

finance system violated the state constitution, but not the federal constitution in Horton v.

Meskill.s1 In relying on both Rodriguez and Robinson, the court concluded that "in

Connecticut the right to education is so basic and fundamental that any infringement of

that right must be strictly scrutinized."'16 The court went on to hold that "in Connecticut,

elementary and secondary education is a fundamental right, that pupils in the public

schools are entitled to the equal enjoyment of that right, and that the state system of

financing public elementary and secondary education as it presently exists and operates

cannot pass the test of "strict judicial scrutiny" as to its constitutionality."''7

In Pauley v. Kelly,"8 the West Virginia Supreme Court relied on the state

constitution's equal protection clause and education clause, which mandated the








legislature to provide a "thorough and efficient system of free public schools,""'9 to

determine the constitutionality of the state's school funding system. The court held that

the state's funding scheme was discriminatory and violated the state's education

clause.120 The court defined a thorough and efficient system of schools as a system that

"develops, as best the state of education expertise allows, the minds, bodies and social

morality of its charges to prepare them for useful and happy occupations, recreation and

citizenship, and does so economically."'21

In Board ofEducation v. Walter, 122 the Ohio Supreme Court examined whether

the state's education finance system violated the state constitution's equal protection and

education clauses. The court held that the objective of promoting local control of the

state's schools was a rational basis for the disparities in funding that existed between

districts.123 The court went on to further explain that "[b]y local control, we mean not

only the freedom to devote more money to the education of one's children but also

control over and participation in the decision-making process as to how those local tax

dollars are to be spent."'24 The court also held that the state's statutory system to fund

public schools did not violate the provision of the Ohio Constitution which requires the

General Assembly to secure a thorough and efficient system of common schools.125

In Lujan v. Colorado State Board of Education,126 the Colorado Supreme Court

upheld the state's school financing system as constitutionally permissible. The court

declared that

[a] heartfelt recognition and endorsement of the importance of an
education does not elevate a public education to a fundamental interest
warranting strict scrutiny. The constitutional mandate which requires the
General Assembly to establish "a thorough and uniform system of free
public schools," is not a mandate for absolute equality in educational
services or expenditures. Rather, it mandates the General Assembly to








provide to each school age child the opportunity to receive a free
education, and to establish guidelines for a thorough and uniform system
of public schools.127

In applying the rational basis test, the court went on to hold that disparities in wealth

between school districts was not enough to find that the state's school finance system

violated the equal protection clause of the state's constitution.128

In McDaniel v. Thomas,129 the Georgia Supreme Court addressed whether the

state's system of funding public education conformed to the mandates of the Georgia

Constitution.130 The plaintiffs, who were parents, students, and school officials who

resided in districts with low property tax values, alleged the current education funding

scheme violated the equal protection clause of the state constitution and deprived their

children of their right to an "adequate education" in contravention of the state

constitution."13 The court concluded "that the "adequate education" provisions of the

constitution d[id] not restrict local school districts from doing what they can to improve

educational opportunities within the district, nor d[id] they require the state to equalize

educational opportunities between districts."132 The court decided that "[i]n the absence

of evidence to show that existing state funding for public education deprive[d] students in

any particular school district of basic educational opportunities, cross-appellants'

contention that low wealth districts failed] to provide an "adequate education" must be

rejected."'33 Finally, the court held that the equal protection clause of the state's

constitution was not violated because the state could show some rational basis for the

disparities in funding between districts.134

New York's highest state court also addressed the constitutionality of the state's

education finance system under equal protection clause of the state and federal








constitutions and the state's education article in Board of Education v. Nyquist.35 In this

case, the court relied on Rodriguez and applied the rational basis test in holding that the

disparities in education funding between property-rich districts and property-poor

districts did not violate the equal protection clauses of either the state or federal

constitution.136 The court ruled that although education is high on the governmental

priority list, that fact does not make education a fundamental right, therefore invoking

strict judicial scrutiny.137 The court also held that the state's education financing scheme

did not violate the state's education article, which required that "[t]he legislature shall

provide for the maintenance and support of a system of free common schools, wherein all

the children of this state may be educated."138 The court interpreted the state's education

article to only require a "state-wide system assuring minimal acceptable facilities and

services in contrast to the unsystematized delivery of instruction then in existence within

the State."'39

In Hornbeck v. Somerset County Board ofEducation,140 the Maryland Court of

Appeals considered whether the state's public education finance formula was

constitutional under the state's education clause and the equal protection clause of the

state and federal constitutions. The court ruled that exact per-pupil funding levels were

not required. 141 And relying on Rodriguez, the court held that education was not a

fundamental right and the appropriate standard of review was rational basis.142 In

applying the rational basis test, the court held that the state had a rational basis for using

the formula to promote local control as denoted by the "thorough and efficient"

requirement in the state's education article. In applying the rational basis test, the court








also ruled that the state funding formula did not violate the equal protection clauses of the

state or federal constitutions.143

In DuPree v. Alma,'44 the Arkansas Supreme Court addressed the constitutionality

of the state's statutory method of financing public schools. The school districts in this

case claimed that the state's funding system violated the state constitution's guarantee of

equal protection and the state education article requirement that the state provide a

general, suitable and efficient system of education.145 The court held that the disparities

in funding between school districts due to revenue for districts being based on the local

tax base violated both constitutional provisions at issue. 46 In applying the rational basis

test, the court held that it could find no legitimate state interest for the disparities in

funding. The funding system bore no rational relationship to the needs of the individual

schools districts, rather it was based on the tax base of each district. The court noted that

suchuh a system only promotes greater opportunities for the advantaged while

diminishing the opportunities for the disadvantaged."147

In Fair School Finance Council of Oklahoma v. State,148 the Oklahoma Supreme

Court addressed the constitutionality of the state's system of funding its public schools.

The plaintiffs argued that the state's system violated the state's education article, which

required the state to establish and maintain a system of public schools, and the equal

protection clause of the state constitution. In relying on Rodriguez, the court held that the

state's funding system did not violate the equal protection clause because a rational

relationship existed between the finance plan and the legitimate state purpose to allow

local control of education and autonomy.'49 Moreover, the court found that the education








article did not require equal expenditures per-pupil, it merely mandated the establishment

and maintenance of a public school system.'50

In Richlandv. Campbell,s5' the South Carolina Supreme Court found the state's

school finance system to be constitutional under the state's equal protection clause and

education article. In this case, the appellants argued that the state's funding formula,

which took into account the individual wealth of the school districts, produced disparities

in school funding and unequal educational opportunities.152 In upholding the state's

funding system, the court decided that "the framers of the Constitution have left the

legislature free to choose the means of funding the schools of this state to meet modem

needs."'53 Further, the court distinguished the state's funding formula from the systems

addresses in Robinson and Serranno. The school districts in South Carolina "which lack

a sufficient tax base receive proportionally more state funds and are required to pay

proportionately less local revenue for public school operation," thus remedying the extent

of the inequities.154

In 1989, the Montana Supreme Court declared that the state's school finance

program was unconstitutional in Helena Elementary School District v. State.'55

Montana's constitution provides for equalityiy of educational opportunity for each

person of the state."156 The court concluded that "as a result of the failure to adequately

fund the Foundation Program, forcing an excessive reliance on permissive and voted

levies, the State ha[d] failed to provide a system of quality public education granting to

each student the equality of educational opportunity guaranteed" under the state

constitution's education article.157 The court did not address whether the state's program








violated the equal protection clause because it was unnecessary after finding the program

unconstitutional under the education article.'58

The Texas Supreme Court in Edgewood v. Kirby ruled that the state's constitution

was violated because the state failed to provide an efficient public school finance

system.'59 In this case, there were "glaring" disparities in the ability of various school

districts to raise revenues because property value varied greatly from district to district.'60

The disparity between the wealthiest and poorest districts was a 700 to 1 ratio.'61 The

state attempted to alleviate these disparities through its Foundation School Program,

however the Program failed to even cover the costs of the state-mandated minimum

education requirements.162 The Texas Constitution provides "[a] general diffusion of

knowledge being essential to the preservation of the liberties and rights of the people, it

shall be the duty of the Legislature of the State to establish and make suitable provision

for the support and maintenance of an efficient system of public free schools."'63 The

state argued that the word "efficient" was intended to mean a simple and inexpensive

school system.64 In disagreeing with the state, the court found that the term "convey[ed]

the meaning of effective or productive of results and connote[d] the use of resources so as

to produce results with little waste."165 The court found that

in mandating "efficiency," the constitutional framers and ratifiers did not
intend a system with such vast disparities as now exist. Instead, they stated
clearly that the purpose of an efficient system was to provide for a
"general diffusion of knowledge." (Emphasis added.) The present system,
by contrast, provides not for a diffusion that is general, but for one that is
limited and unbalanced. The resultant inequalities are thus directly
contrary to the constitutional vision of efficiency.166








Therefore, the court held that the state's financing system was neither financially efficient

nor efficient in the sense of providing for a "general diffusion of knowledge" statewide,

thereby violating the state's education article.'67

In Kukor v. Grover,16 the Wisconsin Supreme Court upheld the constitutionality

of the state's school funding system against allegations that it violated the state

constitution's uniformity requirement and equal protection clause. Although the court in

this case recognized education as a fundamental right, the court applied a rational basis

review because the disparities in funding did not result in a complete deprivation of the

right to an education.169 Under rational basis review, the state's funding system did not

violate the equal protection clause. Additionally, the court found the state's system to be

consistent with the state education article requiring schools to be uniform statewide

because the uniformity requirement was meant to apply to a uniform basic education, not

to provide adequate or additional funding for districts with special needs.'70

In 1989, the Kentucky Supreme Court in Rose v. Council for Better Education"7

confronted the issue of whether the Kentucky General Assembly complied with its

constitutional obligation to "provide an efficient system of common schools throughout

the state."172 The court held that it was "crystal clear" that the Assembly had fallen short

of its duty to provide for an "efficient" system of education in Kentucky.'73 The court

interpreted the state's education article to require the General Assembly to "establish a

system of common schools that provides an equal opportunity for children to have an

adequate education."l74 The court declared that

[t]he system of common schools must be adequately funded to achieve its
goals. The system of common schools must be substantially uniform
throughout the state. Each child, every child, in this Commonwealth must
be provided with an equal opportunity to have an adequate education.








Equality is the key word here. The children of the poor and the children of
the rich, the children who live in the poor districts and the children who
live in the rich districts must be given the same opportunity and access to
an adequate education. This obligation cannot be shifted to local counties
and local school districts.175

Based on the evidence, which showed substantial disparities and inadequacy in funding

for the state's schools, the court ruled that the state's public school system was

constitutionally deficient and directed the General Assembly to recreate and redesign a

system that would comply with the standards the court set forth.176

In Abbott v. Burke,177 the New Jersey Supreme Court addressed the issue of

whether the state's plan for funding public schools violated the thorough and efficient

clause of the state constitution. In sum, the court found that

under the present system the evidence compels but one conclusion: the
poorer the district and the greater its need, the less the money available,
and the worse the education. That system is neither thorough nor efficient.
We hold the Act unconstitutional as applied to poorer urban school
districts. Education has failed there, for both the students and the State.
We hold that the Act must be amended to assure funding of education in
poorer urban districts at the level of property-rich districts; that such
funding cannot be allowed to depend on the ability of local school districts
to tax; that such funding must be guaranteed and mandated by the State;
and that the level of funding must also be adequate to provide for the
special educational needs of these poorer urban districts in order to redress
their extreme disadvantages. 17

In Coalitionfor Equitable Funding v. State,'79 the Oregon Supreme Court held

that the state's method of funding schools did not violate the state constitution, which

required a uniform and general system of common schools. The court ruled that the

Safety Net amendment to the state's constitution provided a remedy for funding

disparities between school districts by giving local districts the ability to levy local taxes

without voter approval if the money was not available from state sources.'80








In Tennessee Small School Systems v. McWherter,'"' the Tennessee Supreme

Court held that the state's public school funding system was unconstitutional under the

state's equal protection clause. The court declared that local control of public schools

was not a rational basis for the state's funding scheme which resulted in disparities in

educational opportunities by district.'82

In 1994, the Arizona Supreme Court in Roosevelt Elementary School District v.

Bishop held that the state's public school funding scheme violated the state constitutional

requirement to provide a general and uniform system of public schools.'83 The court

ruled that to meet the state constitutional requirement, the state does not need to remedy

all disparities within the school system, however "the system the legislature chooses to

fund the public schools must not itself be the cause of substantial disparities."1

In 1995, the Supreme Court of Rhode Island held in City ofPawtucket v.

Sundlum'85 that the state's method of funding public schools neither violated the

education nor the equal protection clause of the state constitution. The court ruled that

the state education clause conferred no fundamental right to education and it did not

guarantee an "equal, adequate, and meaningful education."'86 The constitution simply

required the General Assembly to "promote" education, conferring great discretion to the

state legislature in funding public schools.'"7 Further, the court held that the state's

funding system, where children in poorer districts received less funding than those in

wealthier districts, was rationally related to legitimate state interests of encouraging local

control of school districts and balancing competing funding needs in the state.'88

In 1995, the Wyoming Supreme Court addressed the constitutionality of the

state's school finance system in Campbell County School District v. State.'9 The








plaintiffs claimed that the system violated the state's education article, which required a

complete and uniform system of public instruction and thorough and efficient system of

public schools, as well as the state constitution's equal protection clause.'19 The court

recognized that the state's education article conferred upon its citizens the fundamental

right to education and ruled that the right should be construed broadly. In applying strict

scrutiny, the court held that the state's system violated both the state constitution's

education article, as well as its equal protection clause."19

In 1997, the Ohio Supreme Court held in DeRolph v. State'92 that the state's

public school finance system violated the state's constitutional provision which mandated

the state to provide a thorough and efficient system of schools. In this case, local school

districts lacked sufficient funds to provide for the constitutionally mandated education,

therefore the state was required to rectify the situation.193 However, the court noted that

the state education article requiring a thorough and efficient system of schools did not

require the state to provide for equal educational opportunities for all and did not impose

spending ceilings on wealthier school districts.194

In 2000, the Wisconsin Supreme Court in Vincent v. Voight195 contended with the

constitutionality of the state's public school funding system. The plaintiffs alleged that

the system violated the state's education article, which required a uniform system of

public schools, and the state constitution's equal protection clause.196 The court ruled

that the plaintiffs did not prove that the state failed to provide all students with an equal

opportunity for a basic education, in contravention of the state's uniformity clause.197

Additionally, the court, in treating the state's equal protection clause as equivalent to the








federal equal protection clause, found the state funding system to be constitutional

because it was rationally related to some legitimate state interest.198

In 2002, the Arkansas State Supreme Court in Lake View School District v.

Huckabee,199 held that the state's system of funding public schools was unconstitutional.

The court declared that the state had "not fulfilled its constitutional duty to provide the

children of this state with a general, suitable, and efficient school-funding system."20 In

applying the rational basis standard, the court further ruled that the state's interest in

providing for local control of schools and the state's need to fund non-educational

programs failed to provide a rational basis for the classification of school districts on the

basis of wealth in the public school funding system, thereby violating the equal protection

clause.20'

In 2002, the New Hampshire Supreme Court in Claremont School District v.

Governor202 held that the state failed to develop a system to ensure the delivery of a

constitutionally adequate education. The court ruled that "it is the State's duty to

guarantee the funding necessary to provide a constitutionally adequate education to every

educable child in the public schools in the State" under the state's education article.203

In 2003, in Campaign for Fiscal Equity v. State,204 New York's highest court

ruled that the plaintiffs had established that the state education funding system failed to

provide a basic education to its students, in violation of the New York Constitution.

However, the court held that students had the right to receive a basic education, not a

right to equal state funding.205 The court defined a basic education as one in which

students could acquire the basic literacy, calculating, and verbal skills necessary to be

productive citizens in society.206








As evidenced by the cases discussed above, litigants have had mixed success in

resolving inequities in school funding through the state courts. Depending on which state

litigants bring their legal challenges to address the inequities in school funding, they may

or may not find success in relying on the state education article or equal protection

clause.

Equity Challenges to Florida's Education Funding Program

In contesting Florida's education funding system, litigants often rely on Florida's

constitution, which requires that adequate provision be made for uniform system of

public schools.207 Challenges based on the constitution's uniformity clause fail though

because Florida courts have consistently applied a broad meaning to the word "uniform."

For instance, in 1935, the Florida Supreme Court in State ex rel. Clark v. Henderson said

that a uniform system "means that a system of public free schools, as distinguished from

the authorized State educational institutions, shall be established upon principles that are

of uniform operation throughout the State and that such system shall be liberally

maintained."208 Consequently, in School Board ofEscambia County v. State the Court

defined "uniform system" as one where "the constituent parts, although unequal in

number, operate subject to a common plan or serve a common purpose."209 And in 1991,

in St. Johns County v. Northeast Florida Builders Association,210 the Court again gave

meaning to the term "uniform" in Florida's constitution. The Court held that

[t]he Florida Constitution only requires that a system be provided that
gives every student an equal chance to achieve basic educational goals
prescribed by the legislature. The constitutional mandate is not that every
school district in the state must receive equal funding nor that each
educational program must be equivalent. Inherent inequities, such as
varying revenues because of higher or lower property values or difference
in millage assessments, will always favor or disfavor some districts.211








More recently, in Florida Department of Education v. Glasser, the Florida

Supreme Court expressly declined to define the meaning of "a uniform system of free

public schools" provided for in Article IX, section 1 of the state's constitution.212 In so

doing, the Court reasoned that the legislature should give this term meaning, not the

courts.213 In Justice Kogan's concurring opinion in this case, he summarized the Court's

stance on the meaning of uniformity, stating that:

Florida law now is clear that the uniformity clause will not be construed as
tightly restrictive, but merely as establishing a larger framework in which
a broad degree of variation is possible ... [V]ariance from county to
county is permissible so long as no district suffers a disadvantage in the
basic educational opportunities available to its students, as compared to
the basic educational opportunities available to students of other Florida
districts.214

While the state has survived challenges to its education funding system partly

because the Florida Supreme Court has applied a broad meaning to the word "uniform,"

Florida has also been successful in defending its school funding system on the basis of

equity because of its current financing program, the Florida Education Finance Program

(FEFP), which was enacted shortly after Serrano and had a highly equalizing effect on

the state's distribution of funding to schools.215 For example, in 1979, the Florida

Supreme Court addressed its first challenge to Florida's FEFP in Gindl v. Department of

Education.216 Members of the School Board of Escambia County, a property-poor

district, challenged the utilization of the "leeway" millage provision in the FEFP under

the federal and state constitution's equal protection clauses and under the state's

education article which provides for a "uniform system of free public schools."217 The

school board alleged that this provision, which allowed districts to levy discretionary








millage, resulted in funding disparities between property-rich and property-poor

districts.2t8 The Court held that the

district cost differential [was] not arbitrary, capricious, or unreasonable
and unrelated to the goal of providing substantially equal educational
opportunities; and that the Florida education funding formula, in allowing
leeway millage, [did] not violate the equal protection clause, and
substantial equality of education [was] not prevented by the use of leeway
millage.219

In 1993, the Florida Supreme Court again upheld the constitutionality of the FEFP

in Department ofEducation v. Glasser.22o In this case, the property-rich Sarasota school

district also challenged the discretionary millage provision in the FEFP, but based its suit

on the opposite perspective resolved in Gindl.221 Based on Article VII, section 9 of the

Florida Constitution, which allows school districts to levy ad valorem taxes if authorized

by law and further provides that such taxes "shall not be levied in excess of the following

millages[:]... for all school purposes, ten mills,"2' the district argued that it was

authorized by the state constitution to levy taxes in excess of .51 mills, the limit set by the

FEFP. The Court ruled that Article VII only set parameters for which the legislature

could authorize discretionary millage, it did not itself authorize ten mills.223

Because litigants in Florida have found little success by filing "uniformity" or

"equality suits," they began to follow the trend developing in other states and have

initiated challenges to the state's education funding system based on "quality" or

"adequacy" grounds.224

Litigation Relating to Adequacy of School Funding

In 1989, the third wave of school finance litigation began, focusing chiefly on

education articles in state constitutions which require schools to be adequately funded.225

Litigants focus these adequacy arguments "on whether the amount of money appropriated








for public education in general is enough to meet the costs of providing the standard

guaranteed in the state constitution."226 For example, in Rose, Abbott, City ofPawtucket,

and Claremont, litigants successfully argued that their state's school finance system was

inadequate under their state constitution education articles.

In Florida, litigants have been unsuccessful in their adequacy challenges thus far.

The Florida Constitution's education article language prior to the state's constitutional

revision in 1998 required that "adequate provision shall be made by law for a uniform

system of free public schools."227 In 1998, the citizens of Florida amended the state's

education article, making it the "paramount duty of the state to make adequate provision

for the education of all children residing within its borders."28 The constitution also

requires that adequateae provision shall be made by law for a uniform, efficient, safe,

secure, and high quality system of free public schools."229 Seemingly, the change in the

language of Florida's education article, where it is now the "paramount duty" of the state

to provide an adequate education and where the word "adequate" is mentioned twice, has

made the state's education article stronger, providing litigants in Florida with the

possibility to attack the adequacy of Florida's school finance system under the new

language.230

In 1996, Florida's Supreme Court in Coalitionfor Adequacy & Fairness in School

Funding v. Chiles upheld the state's education system against an adequacy challenge

under the state's 1968 education article.231 The Court agreed with the trial court that

"courts cannot decide whether the Legislature's appropriation of funds is adequate in the

abstract."232 Furthermore, the Court held that

[t]o decide such an abstract question of "adequate" funding, the courts
would necessarily be required to subjectively evaluate the Legislature's








value judgments as to the spending priorities to be assigned to the state's
many needs, education being one among them. In short, the Court would
have to usurp and oversee the appropriations power, either directly or
indirectly, in order to grant the relief sought by Plaintiffs.233

In Justice Kogan's concurring opinion in Coalition, he suggested that if the

plaintiffs "quantify" how the Florida education system were inadequate, the Court may

then find that the system is unconstitutional because it fails to meet a basic level of

adequacy.234 Taking Justice Kogan's suggestion to heart, the plaintiffs filed a new

adequacy case in Florida in December of 1999.235 In this case, the plaintiffs presented

data demonstrating the inadequacy of Florida's schools and argued that Florida's high

rates of illiteracy proved that Florida has failed to provide adequate schools under the

state's constitution.236

Although future litigants may find success in challenging Florida's public school

funding scheme via the state constitution's adequacy clause, it is clear that the Florida

Education Finance Program has helped the state survive any challenges based on equity

grounds. The following section describes the Florida Education Finance Program in

greater detail, beginning with a brief history.

The Florida Formula: The Florida Education Finance Program

Devised as a replacement for the state's Minimum Foundation Program, which

had been in effect since 1947, the Florida Legislature enacted the FEFP in 1973. The

purpose of the program was "to guarantee to each student in the Florida public

educational system the availability of programs and services appropriate to his or her

educational needs which are substantially equal to those available to any similar student

notwithstanding geographic differences and varying local economic factors."237








At the time of its creation, the FEFP was recognized as "a national model for

inter-district equity."238 Since its inception, the Florida Legislature has revised the FEFP

numerous times in attempts to arrive at a more equitable distribution plan of state funds

for public education. The FEFP currently distributes over 13 billion dollars annually to

Florida's approximately 2.4 million students in its 67 member public school districts.239

While the FEFP technically qualifies as a foundation program, in effect the

formula provides defacto full state funding. This is due to the fact that limitations, or

caps, on local property taxes and other controls have been enacted on individual districts

by the State of Florida.240 In fact, the FEFP calls for what is known as the required local

effort, the specified amount each local school district is required to contribute in the

FEFP, which is subtracted from state and local FEFP funds.241 This equalization factor is

one of the reasons the FEFP is generally considered to be a highly equitable distribution

formula when compared to those of other states.

The FEFP distributes funds for education on the basis of the number of full-time

equivalent pupils (FTEs). A full-time equivalent is defined by Florida Statute as one

student "membership," or enrollment in a school district, for 900 hours of annual

instruction.242 The FEFP also employs the use of several program cost factors to account

for the varying costs of delivering varied educational programs. This component of the

FEFP was established to ensure "each program receives its equitable share of funds in

relation to its relative cost per student."243

Despite the fact that the FEFP has undergone various supplements and

adjustments since its creation, the core calculation formula remains essentially

unchanged. This formula is FTE student membership multiplied times program cost








factors, multiplied times base student allocation (BSA).24 For each of Florida's school

districts, the program cost to educate each pupil is multiplied by the number of students

to derive a district's state funding. The formula also contains another multiplier, the

district cost differential (DCD), which accounts for disparate costs of living in the local

communities served by the various school districts.245

Florida's system of public schools is compromised of 67 fiscally independent,

countywide school districts and 5 "special" districts, each responsible for demonstrating

an effort to maintain its own school program.246 However, in order to provide for

"equalization of educational opportunity," the FEFP recognizes differing: (1) district

property tax bases; (2) educational program costs; (3) costs of living; and (4) costs for

equivalent educational programs due to sparsity and dispersion of student population

between the school districts.247

The State of Florida, by way of the FEFP, provides categorical funding to each of

its districts based on the specific educational needs of individual students. Rather than

basing funding upon the number of schools, teachers, or classrooms, the FEFP allocates

financial resources in accordance with the needs of "the individual student participating

in a particular educational program."248

The Theory of Performance-Based Funding Incentive Programs

Driven in large measure by a barrage of critiques regarding public education two

decades ago, schools in the United States have been scrutinized by American citizens,

politicians, and educators themselves.249 The combination of the response of research,

resolution, and reform that followed resulted in state and local governments rapidly








enacting an array of performance-based incentive plans designed to improve the quality

of public education through financial rewards to schools and teachers.250

The theoretical basis for these performance-based funding incentive reforms were

thought to be generally consistent with common sense and proven practice in business,

industry, and higher education. A review of the reforms suggests such reforms were

derived from a theory of motivation and productivity, namely expectancy theory, which

posits that individuals and groups are more likely to "strive in their work" if there is an

anticipated reward that they value, such as a financial bonus, than if there is none.251

Expectancy theory has provided a theoretical justification for the use of performance-

based incentive programs in public education.

Expectancy theory holds that "people can be expected to act in anticipation of

achieving favorable outcomes or rewards and avoiding unfavorable outcomes or

penalties."252 Victor Vroom, who has been credited with first advancing expectancy

theory, held that it is possible to predict a worker's behavior once it is known what

valences (favorable or unfavorable) and probabilities (likely or unlikely) he or she

attached to that outcome.253 In other words, an individual or group who desires a reward

that is thought to be attainable is believe to shape his or her behavior to increase the

likelihood of achieving that reward.

Performance-based funding incentive programs have gained popularity largely

due to the perceived simplicity of the systems. Although the trend among state

legislatures is to enact more and more market-based financial incentive programs in

public education, some research suggests such efforts may be ineffective or misguided.254








The Florida School Recognition Program

In 1997, the Florida Legislature created the Florida School Recognition Program

(FSRP) "in response to the need for a performance incentive program for outstanding

faculty and staff in highly productive schools."255 The Florida Legislature based the need

for such a program on its findings that performance-based incentives were commonplace

in the private sector and should be infused into the public sector "as a reward for

productivity."256 In conjunction with public recognition, the FSRP provides financial

awards to schools that have "sustained high student performance" or to schools that

"demonstrate substantial improvement in student performance." Whereas at the inception

of the FSRP, criteria such as dropout rates, attendance rates, graduation rates, and

readiness for postsecondary education data were used, school performance is now

measured solely by results from the Florida Comprehensive Assessment Test (FCAT).257

The FSRP was designed to "provide greater autonomy and financial awards to

schools that demonstrate sustained or significantly improved student performance."258

Funds for the program were first appropriated at the conclusion of the 1998-1999 school

year. Schools designated an "A" performance grade or schools "improving at least one

performance grade" from the previous year were eligible for recognition and financial

awards. All public schools, including those public schools designated as "charter

schools," that received the stipulated grade of "A" or demonstrated an improvement of at

least one letter grade were eligible to participate in the FSRP.259

In accordance with statute, schools have the option of utilizing reward funds for

"staff bonuses or nonrecurring expenditures to support increased student performance."

Each FSRP recipient school received $100 per full-time equivalent (FTE) student each








year of qualification, based on the previous year's enrollment. Schools did not have to

apply to receive the award as the designation was based solely on meeting the program

criteria. However, the Florida Department of Education did ask award schools to provide

information on successful practices and programs to share with other schools.

Additionally, schools were asked how the financial awards were used by each of the

recognized schools.260

In accordance with statute, staff at a recognized school, jointly with its school

advisory council (SAC), shall decide how to use the financial award. Since the Florida

Legislature recognizes, everyey school is different and has unique needs," the legislation

does not stipulate a specific decision making process for schools to follow.26' Guidelines

for determining how a decision is to be reached by the school's staff in conjunction with

SAC, as well as for determining how any conflicts may be resolved in reaching the

decision, may be developed at the local level.262 Statute stipulates the awards must be

designated "for nonrecurring faculty and staff bonuses, for nonrecurring expenditures for

educational equipment and materials, for temporary personnel to assist in maintaining or

improving student performance, or for any combination of these."263

Florida Statutes stipulates if a school's staff in conjunction with its SAC is unable

to reach an agreement as to how to appropriate the FSRP funds by the first day of

November of each year, the award "must be equally distributed to all classroom teachers

currently teaching in the school." Classroom teachers are defined by statute as "staff

currently assigned to the school who hold a valid educator certificate and are classified as

instructional personnel."264 Florida Statutes also states, "notwithstanding statutory

provision to the contrary, incentive awards are not subject to collective bargaining."265









The vast majority of FSRP recipient schools used the designated award funds in

the areas of staff incentive or bonuses, staff development, and technology, including the

acquisition of computers, software, computer laboratories, integrated instructional

systems, and other technologically advanced instruction materials. In addition, recipient

schools chose to purchase instructional materials for classrooms and media centers,

including specific program materials in the areas of reading, writing, and math.266

During the first full year of its inception, 1998-1999, a total of 319 public schools,

in fifty-one (51) of Florida's school districts, received FSRP awards. Awards per school

ranged from $6,750 to $316,364, depending on individual school FTE. Total FSRP funds

for 1998-1999 were $27,603,881.267 As illustrated in Figure 2-1, since 1998-1999, the

FSRP grew substantially, as funding more than quadrupled since the program's inception.

By the 2002-2003 school year, 1,618 of Florida's schools were recognized and received

financial awards totaling $137,958,067.


$1M0,000,000 --- 7 U


$121 ,051,7
$120,000,000

I100,000 000 ----- 0_

80,707.004


40,000,000 .




020,000.000 20 0-- 00 0 0 0


1BBB-1S8B IBBS-2000 2000-2001 2001-2002 2002-2003


Figure 2-1: Total FSRP Funding Distributed to Florida Public Schools








Summary

Florida has long been noted for its relative high degree of inter-district equity

afforded through the Florida Education Finance Program. As a result, Florida has

avoided much of the same judicial controversy and public scrutiny as other states.

However, the advent of performance-based incentive programs and the resulting effects

of such systems on per-pupil equity have recently raised both interest and concern.

Performance-based incentive programs such as the Florida School Recognition Program

represent a potentially dramatic counterbalance to a state finance system like that of

Florida, once lauded for its relative high degree of inter-district equity.

This chapter began with a discussion of per-pupil equity as a foundation for social

justice, followed by a description of the theory of equity in education finance. A

summary of litigation related to equity of school finance was also provided in this

chapter, in addition to a thorough discussion of the Florida Education Finance Program.

An overview of the Florida School Recognition Program was also presented in this

chapter. The following chapter provides a discussion of the methodology used in the

present study to measure the per-pupil equity of the Florida Education Finance Program

both before and after the inception of the Florida School Recognition program.


Notes

David C. Thompson, R. Craig Wood, and David S. Honeyman, Fiscal
Leadership for Schools: Concepts and Practice (New York: Longman, 1994), 57.

2 Ibid, 56-57.

3John Rawls, A Theory ofJustice (Cambridge, MA: Harvard University Press,
1971), 274.









4 Ibid., 15.

5 Ibid., 12.

6 Ibid., 3.

7Ibid., 303.

SIbid., 301.

9Ibid.

0o Ibid.

"1 Kern Alexander and Richard G. Salmon, Public School Finance (Needham
Heights, MA: Allyn & Bacon, 1995), 27.

12 Isaiah Berlin, "Equality", in Concepts and Categories, Philosophical Essays
(New York: The Viking Press, 1978), 82.

13 Alexander and Salmon, 27.

14 Ellwood P. Cubberley, School Funds and Their Apportionment (New York:
Teachers College, Columbia University, 1906), 17-18.

15 Ibid., 17.

16 Ibid., 123.

17 Alexander and Salmon, 194.

18 Cubberley, 90-91.

19 Ibid., 4, 52.

20 Harlan Updegraff, Rural School Survey ofNew York State: Financial Support
(Ithica, NY: The Joint Committee on Rural Schools, 1922), 110.

21 Ibid., 136.

22 Harlan Updegraff and Leroy King, Survey of the Fiscal Policies of the State of
Pennsylvania in the Field of Education (Philadelphia: University of Philadelphia, 1922),
119-122.









23 George D. Strayer and Robert Murray Haig, Financing ofEducation in the
State ofNew York, Report of the Educational Finance Inquiry Commission, Vol. 1 (New
York: Macmillan Publishing Company, Inc., 1923), 176.

24 Ibid., 173.

25 David C. Thompson, R. Craig Wood, and David S. Honeyman, Fiscal
Leadership for Schools: Concepts and Practice (New York: Longman, 1994), 219-223.

26 Strayer and Haig, 174.

27 Thompson, Wood, and Honeyman, 219-223.

28 Ibid., 219.

29 Alexander and Salmon, 201.

30 Ibid.

31 Thompson, Wood, and Honeyman, 223.

32 Steven D. Gold, David M. Smith, Stephen B. Lawton, and Andrea Hyary, eds.,
Public School Finance Programs of the United States and Canada, 1993-1994, vol. 1 and
2 (New York: American Education Finance Association, Nelson A. Rockefeller Institute
of Government, 1995), 196.

33 George D. Strayer and Robert Murray Haig, Financing ofEducation in the
State ofNew York, Report of the Educational Finance Inquiry Commission, Vol. 1 (New
York: Macmillan Publishing Company, Inc., 1923), 175.

34 R. Craig Wood and David C. Thompson, Education Finance Law:
Constitutional Challenges to State Aid Plans-An Analysis ofStrategies, No. 50 in the
NOLPE Monograph Series (Topeka, KS: National Organization on Legal Problems in
Education, 1993), 8.

35 Paul R. Mort, The Measurement of Educational Need (New York: Teachers
College, Columbia University, 1924, 1.

36 Ibid., 6.

37 Ibid., 63-66.

38 Thomas H. Jones, Introduction to School Finance: Technique and Social Policy
(New York: Macmillan Publishing Company, Inc., 1985), 200.









39 Roe L. Johns, Edgar L. Morphet, and Kern Alexander, The Economics and
Financing ofEducation, 4t ed. (Englewood Cliffs, NJ: Prentice Hall, 1983), 209-211.

40 Roe L. Johns and Edgar L. Morphet, The Economics and Financing of
Education, 3rd ed. (Englewood Cliffs, NJ: Prentice-Hall, Inc., 1975), 234.

41 Henry C. Morrison, School Revenue (Chicago: University of Illinois Press,
1930), 214.

42 Ibid., 200-201.

43 Ibid., 221.

44 Ibid., 231.

45 Kern Alexander and Richard G. Salmon, Public School Finance (Needham
Heights, MA: Allyn & Bacon, 1995), 26, 36-37.

46 Vem Brimley, Jr. and Rulon R. Garfield, Financing Education in a Climate of
Change, 8h ed., (Boston: Allyn and Bacon, 2002), 218.

47 Springfield Township v. Quick at al., Supreme Court, December Term, 1859,
pp. 56-60.

48 Stuart v. School District No. I ofthe Village ofKalamazoo, 30 Mich. 69 (1874).

49 Brown v. Board of Education, 347 U.S. 483 (1954).

50 Ibid. at 495.

51 Kern Alexander and Richard G. Salmon, Public School Finance (Needham
Heights, MA: Allyn & Bacon, 1995), 37.

52 Ibid.

53 Ibid.

54 Carolyn D. Herrington and Virginia Weider, "Equity, Adequacy and Vouchers:
Past and Present School Finance Litigation in Florida," Journal ofEducation Finance 27
(2001), 517,519.

5s Ibid.

56 Ibid. See also Thompson, Honeyman, and Wood, 267.










7 Ibid.

58 Mclnnis v. Shapiro, 293 F. Supp. 327, 328-329 affirmed mem., 394 U.S. 322
(1969).

9 Ibid.

60 Ibid. at 331.

61 Ibid. at 332.

62 Ibid. at 336.

63 Burruss v. Wilkerson, 310 F. Supp. 572, 573 (W.D. Va. 1969), affirmed per
curiam, 397 U.S. 44 (1970).

SIbid. at 574.

65 Burruss v. Wilkerson, 90 S. Ct. 812 (1970), Mclnnis v. Shapiro, 394 U.S. 322
(1969).

66 San Antonio Independent School District v Rodriguez, 93 S. Ct. 1278, 1282
(1973).

67 Ibid.

68 Ibid.

69 Ibid. at 1288.

70 Ibid. at 1294.

71 Ibid. at 1295.

72 Ibid.

3 Ibid. at 1296.

74 Ibid. at 1300.

75 Ibid.

76 Ibid. at 1304.










77 Ibid. at 1308.

78 William E. Thro, "To Render Them Safe: The Analysis of State Constitutional
Provisions In Public School Finance Reform Litigation," Virginia Law Review 75
(November 1989): 1639-1679.

79 Ala. Const. art. XIV, 256; Alaska Const. art. VII, 1; Ariz. Const. art. XI,
1; Ark. Const. art. XIV, 1; Cal. Const. art. IX, 1; Colo. Const. art. IX, 2; Conn.
Const. art. VIII, 1; Del. Const. art. X, 1; Fla. Const. art. IX, 1; Ga. Const. art. VIII,
1, 1; Haw. Const. art. X, 1; Idaho Const. art. IX, 1; Ill. Const. art. X, 1; Ind. Const.
art. VIII, 1; Iowa Const. art. IX, 2d, 3; Kan. Const. art. VI, 1; Ky. Const. 183; La.
Const. art. VIII, 1; Me. Const. art. VIII, pt. 1, 1; Md. Const. art. VIII, 1; Mass.
Const. pt. 2, ch. 5, 2; Mich. Const. art. VIII, 2; Minn. Const. art. XIII, 1; Miss.
Const. art. VIII, 1; Mo. Const. art. IX, l(a); Mont. Const. art. X, 1; Neb. Const. art.
VII, 1; Nev. Const. art. XI, 2; N.H. Const. pt. 2, art. LXXXIII; N.J. Const. art. VIII,
4, 1; N.M. Const. art. XII, 1; N.Y. Const. art. XI, 1; N.C. Const. art. IX, 2; N.D.
Const. art. VIII, 1; Ohio Const. art. VI, 3; Okla. Const. art. XIII, 1; Or. Const. art.
VIII, 3; Pa. Const. art. III, 14; R.I. Const. art. XII, 1; S.C. Const. art. XI, 3; S.D.
Const. art. VIII, 1; Tenn. Const. art. XI, 12; Tex. Const. art. VII, 1; Utah Const. art.
X, 1; Vt. Const. ch. 2, 68; Va. Const. art. VIII, 1; Wash. Const. art. IX, 1; W.Va.
Const. art. XII, 1; Wis. Const. art. X, 3; Wyo. Const. art. VII, 1.

s0 487 P. 2d 1241, 1244 (Cal. 1971) [Serrano I].

81 Ibid. at 1243.

82 Ibid. at 1244.

3 L. Dean Webb, Martha M. McCarthy, and Stephen B. Thomas, Financing
Elementary and Secondary Education (Columbus, OH: Merrill, 1988), 258.

84 Serrano v. Priest, 557 P. 2d 929 (Cal 1976) [Serrano II].

85 Ibid. at 939.

86 William E. Camp and David C. Thompson, "School Finance Litigation,"
Journal ofEducational Finance 14 (Fall 1988), 222.

7 William E. Thro, "The Third Wave: The Impact of the Montana, Kentucky, and
Texas Decisions on the Future of Public School Reform Legislation," Journal of Law and
Education 19 (Spring 1990), 242.

88 Herrington and Weider, 520.









89 Ibid.

90 334 F. Supp 870, 877 (Minn. 1971).

91 Ibid.

92 Ibid.

93 515 P.2d 590 (Ariz. 1973).

94 Ibid. at 592.

95 Ibid. at 592-593.

96 303 A.2d 273 (NJ 1973).

97 Ibid.

98 Ibid. at 283.

99 Ibid. at 282.

oo Ibid. at 287.

101 N.J. Const. art. VIII, 4.

102 Robinson, 303 A.2d at 295.

103 Robinson v. Cahill, 360 A.2d 400 (1976).

'04 212 N.W.2d 711 (Mich. 1973).

105 Ibid. at 714-716.

106 Ibid. at 720.

107 537 P.2d 635 (Idaho 1975).

10 I.D. Const. art VIV, 1.

109 Thompson, 537 P.2d at 636.

110 Ibid. at 640.









11 Ibid.
112 Ibid. at 647.

13 554 P.2d 239 (Oregon 1976).

114 Ibid. at 240-242.

15 376 A.2d 359 (Conn. 1977).

116 Ibid. at 373.

117 Ibid. at 374.

"8 255 S.E.2d 859 (W. Va. 1979).

19 W.V. Const. art XII, 2.
120 Pauley, 255 S.E.2d at 878-883.

121 Ibid. at 877.

122 390 N.E.2d 813 (Ohio 1979).

123 Ibid. at 820.

124 Ibid.

125 Ibid. at 822-823.

126 649 P.2d 1005 (Colo. 1982).

127 Ibid at 1018-1019.

128 Ibid. at 1023.

129 285 S.E.2d 156 (Ga. 1982).

130 Ibid. at 157.

131 Ibid.

132 Ibid. at 164.









133 Ibid. at 165.

134 Ibid. at 167.

35 439 N.E.S2d 643 (NY 1982).
136 Ibid. at 649.

137 Ibid. at 650.

138 Ibid. at 652; N.Y. Const. art XI, 1.

139 Ibid. at 653.

140 458 A. 2d 758 (Md. 1983).

141 Ibid. at 776.

142 Ibid. at 781.

143 Ibid. at 782.

44 651 S.W.2d 90 (Ark. 1983).

145 Ibid. at 91.

146 Ibid.

147 Ibid. at 93.

14s 746 P. 2d 1135 (Okla. 1987).

149 Ibid. at 1144.

150 Ibid. at 1149.

151 364 S.E. 2d 470 (S.C. 1988).

152 Ibid. at 471.

153 Ibid. at 472.

154 Ibid (emphasis supplied).









1'5 769 P.2d 684 (Mont. 1989).

'56 Mt. Const. art X, 1.

157 Helena, 769 P.2d at 690.

15 Ibid. at 691.

159 777 S.W.2d 391 (Tex. 1989).

160 Ibid. at 392.

161 Ibid.

162 Ibid.

163 Tx. Const. art VII, 1.

64 Edgewood, 777 S.W.2d at 394.
165 Ibid. at 395.

'" Ibid. at 396.
167 Ibid. at 397.

16 436 N.W.2d 568 (Wis. 1989).

169 Ibid. at 580.

17 Ibid. at 574-578.

171 790 S.W.2d 186 (Ky. 1989).

172 Ky. Const. 283.

173 Rose, 790 S.W.2d at 189.

174 Ibid. at 211.

175 Ibid.

176 Ibid.









'7 575 A.2d 359 (N.J. 1990).

178 Ibid. at 363.

79 811. P. 2d 116 (Or. 1991).

180 Ibid. at 121.

181 851 S.W. 2d 139 (Tenn. 1993).

182 Ibid. at 154.

183 877 P.2d 806 (Ariz. 1994).

'84 Ibid. at 815.

's 662 A.2d 40 (R.I. 1995).
186 Ibid. at 55.

187 Ibid. at 56.

188 Ibid. at 60.

89 907 P.2d1238 (Wyo. 1995).

'9 Ibid. at 1244.

19' Ibid. at 1265.

192 677 N.E.2d 733 (Ohio 1997).

193 Ibid. at 740-745.

194 Ibid.

195 614 N.W.2d 388 (Wis. 2000).

196 Ibid. at 396.

197 Ibid. at 408.

198 Ibid. at 415.









'9 91 S.W.3d 472 (Ark. 2002).

200 Ibid. at 495.

201 Ibid. at 499.

202 794 A.2d 744 (N.H. 2002).

203 Ibid. at 754.

204 796 N.Y.S.2d 106 (N.Y. 2003).

205 Ibid. at 126.

206 Ibid. at 110.

207 Fla. Const. art. IX, 1.

208 137 Fla. 666, 188 So. 351 (1939).

209 353 So. 2d 834, 837 (Fla. 1977).

210 583 So. 2d 635 (Fla. 1991).

211 Ibid. at 641.

212 622 So. 2d 944 (Fla. 1993).

213 Ibid. at 947.

214 Ibid. at 950 (citing St. Johns County v. Northeast Florida Builders Ass'n, 583
So. 2d 635 (Fla. 1991); School Board v. State, 353 So. 2d 834 (Fla. 1977); Penn v.
Pensacola-Escambia Governmental Center Authority, 311 So. 2d 97 (Fla. 1975)).
215 Ibid.

216 396 S. 2d 1105 (Fla. 1979).

217 Ibid. See also Florida Constitution, Article IX, section 1.

218 Ibid.

219 Ibid. at 1106.









220 622 So. 2d 944 (Fla. 1993).

221 Herrington and Weider, 522.

222 Article VII, section 9 (emphasis added).

223 Glasser, 622 So. 2d at 947 (Fla. 1993).

224 See Barbara J. Staros, "School Finance Litigation in Florida: A Historical
Analysis," Stetson Law Review 23 (Spring 1994), 497. See also Coalitionfor Adequacy
& Fairness in School Funding v. Chiles, 680 So. 2d 400, 407 (Fla. 1996).
225 Herrington and Weider, 520.

226 Ibid. at 523.

227 Fla. Const. art. IX, 1 (1968).

228 Fla. Const. art. IX, 1 (1998).

229 Ibid.

230 Herrington and Weider, 523.

231 680 So. 2d 400, 406 (Fla. 1996).

232 680 So. 2d 400, 407 (Fla. 1996).

233 Ibid

234 Ibid. at 409 (J. Kogan's concurrence).

235 Herrington and Weider, 527.

236 Ibid.

37 Florida Statutes, 236.013 (1998). This section of the Florida Statutes was
renumbered after the "Florida K-20 Education Code" rewrite, effective January 7, 2003.
238 Yasser Nakib and Carolyn D. Herrington, "The Political Economy of K-12
Education Finance: The Context of a Fast Growing Large State," Journal of Education
Finance 23 (1998): 360.









239 Florida Senate Appropriations Committee, A Statistical Review ofEducation in
Florida (Tallahassee, FL: Florida Senate Appropriations Committee, 2000).
240 Wood and Thompson, 36.

241 Florida Department of Education, 2002-2003 Funding for Florida School
Districts, EIAS Series 2003-06 (Tallahassee, 2002), 17; Florida Statutes, 1011.62
(2002).
242 Florida Department of Education, 2002-2003 Fundingfor Florida School
Districts, EIAS Series 2003-06 (Tallahassee, 2002), 8; Florida Statutes, 1011.62 (2002).

243 Ibid, 10.

244 Office of Program Policy Analysis and Government Accountability, Florida's
Education Funding System (Tallahassee, FL, 1996), 3.

245 Ibid, 14.

246 Ibid, 1.

247 Ibid.

248 Ibid, 2.

249 National Commission on Excellence in Education, A Nation at Risk
(Washington, D.C.: U.S. Government Printing Office, 1983); Education Commission of
the States, Task Force on Education of Economic Growth (Denver, CO: Education
Commission of the States, 1983); Earnest L. Boyer, High School: A Report on American
Secondary Education (New York: Harper & Row, 1983); The Twentieth Century Fund
Task Force on Federal Elementary and Secondary Policy, Making the Grade (New York:
Twentieth Century Fund, 1983).
250 U.S. Department of Education, The Nation Responds: Recent Efforts to
Improve Education (Washington, D.C.: U.S. Government Printing Office, 1984).
251 Victor Vroom, Work and Motivation (New York: John Wiley, 1964); E. E.
Lawler III, Pay and Organization Development (Reading MA: Addison-Wesley, 1983).
252 Susan Moore Johnson, "Incentives for Teachers: What Motivates, What
Matters," Educational Administration Quarterly, Vol. 22, No. 3 (Summer 1986), 56.
253 Vroom, Work and Motivation.








254 Alfie Kohn, Punished by Rewards: The Trouble with Gold Stars, Incentive
Plans, A's, Praise, and Other Bribes (Boston: Houghton Mifflin, 1993).

255 Florida Statutes, 1008.36, art. 1 (2003).

256 Ibid.

257 Florida Statutes, 231.2905, art. 1. This statute was renumbered and became
Florida Statutes, 1008.36 "Florida K-20 Education Code" rewrite, effective January 7,
2003.
258 Florida Statutes, 1008.36. This section of the Florida Statutes was
renumbered after the "Florida K-20 Education Code" rewrite, effective January 7, 2003.
259 Florida Statutes, 1008.36, art 3.

260 Florida Statutes, 1008.36.

261 Florida Department of Education, Office of Policy Research and
Improvement, "Florida School Recognition Program: Frequently Asked Questions"
Technical Assistance Document, August 2003. [Online]. Available:
http://www.mvfloridaeducation.com/opri/qa.htm [September 21, 2003].
262 Ibid.

263 Florida Statutes, 1008.36, art. 5.

264 Florida Statutes, 1008.36, art 4.

265 Florida Statutes, 1008.36, art 5.

266 Florida Department of Education, Florida School Recognition 1999-2000
Summary: Best Practices for Higher Student Achievement (Tallahassee, FL, 2000), 10.
267 Ibid, 3.













CHAPTER 3
METHODOLOGY


Introduction

The purpose of this study was to extend equity analysis to include the effects of a

performance-based funding incentive program, the Florida School Recognition Program

(FSRP), on the per-pupil fiscal equity of a state foundation finance system. In the

previous chapter, the literature relevant to this study was reviewed. This chapter includes

a discussion of the research design method with which the equity effects of the FSRP

were examined. Specifically, this chapter is focused upon the degree of horizontal equity

and wealth neutrality of education finance among the sixty-seven (67) Florida school

districts. The research design and the specific measures utilized to measure equity are

explained in this chapter, including those of horizontal equity and wealth neutrality.

The study includes analysis of the effects on equity of the Florida Education

Finance Program (FEFP) both without and with the FSRP for each of the five (5) fiscal

years most recently available since its inception, 1998-1999, 1999-2000, 2000-2001,

2001-2002 and 2002-2003.

This research was designed to provide the answer to the following three (3) questions:

1. Has the FEFP demonstrated changes in horizontal equity with the advent of the FSRP
between fiscal year 1998-1999 and 2002-2003?

2. Has the FEFP demonstrated changes in wealth neutrality with the advent of the FSRP
between fiscal year 1998-1999 and 2002-2003?








3. What trends exist, if any, with regard to equity of the FEFP since the inception of the
FSRP?

Research Design

This study was conducted to determine the effects of a performance-based

funding incentive program on the per-pupil fiscal equity within a state school finance

system. To conduct this study, two conditions were established as part of the research

design. Under the first condition, the per-pupil fiscal equity was determined without the

performance-based incentive funds in the state school finance system. Under the second

calculation, the per-pupil fiscal equity was determined with the performance-based

incentive funds in the state school finance system. The difference between the two

calculations was the effect of a performance-based funding incentive program on the per-

pupil fiscal equity of a state foundation finance system.

In the formulation of the research design, the five-year period of FEFP data of all

of its sixty-seven (67) school districts were evaluated for per-pupil fiscal equity before

and after FSRP incentive funds were added. Revenue from the FSRP received by

individual school districts had the potential of altering per-pupil fiscal equity within the

state finance system for education. Thus, the result of adding the performance-based

incentive funds to the general education fund for education in the state of Florida could

be a system that was more or less equitable. The overall design of the study established

the fiscal equity before and after the performance-based incentive funds were introduced

into the education finance system.

Measures of Horizontal Equity

Horizontal equity is the principle that equal resources are provided to pupils who

have similar needs.' The traditional univariate dispersion measures of horizontal equity








utilized in this study were mean, median, range, restricted range, federal range ratio,

variance, standard deviation, coefficient of variation, relative mean deviation, McLoone

Index, and Gini Coefficient.2 The variable measures for horizontal equity and vertical

equity were revenue per weighted FTE per individual school district in the state of

Florida.

Mean

The mean is a measure of central tendency. Within the context of the field of

education finance, mean represents the average value of revenue per weighted FTE in the

individual school district. A calculation of the mean served as a useful initial method of

identifying funding inequities, especially in terms of those school districts whose per-

pupil funding may vary widely from the mean.3 However, the mean served primarily as a

descriptive statistic, thus did not provide any substantial information concerning the

extent of equity of a particular distribution.4 Additionally, the mean tends to be a

measure especially sensitive to extreme values or spurious outliers, meaning results may

be skewed for distributions that are not normal in shape. So although the mean may not

prove to be as useful as other statistical measures in this study, it does provide an initial

foundation on which to build other measures.

The mean was calculated with the following formula:

SX,IN


where E represents the summation of all sixty-seven (67) districts, Xi is revenue

generated in each district i, and N represents the number of school districts.








Median

The median was an important indicator in this study as it is a critical component

of the McLoone Index, a formula specific to the field of education finance explained later

in this chapter. The median, another measure of central tendency, is a midpoint or middle

value of a distribution when the observations are placed in order from highest to lowest.

Like the mean, the median may be used to compare the level of funding between districts.

Less sensitive to spurious outliers than the mean, the median is also less distorted by a

skewed distribution. Thus, in cases where extreme values exist, the median may be a

more reliable measure for analyzing a distribution of data.5

Range

The range is the arithmetic difference between the highest and lowest values in

the formula distribution.6 The range calculated in this study was the difference between

the highest and lowest revenue distributed per-pupil to each of Florida's public school

districts, providing at least a basic indication of the degree of variation within the

distribution. A smaller range indicates a smaller variation in the distribution of per-pupil

fiscal equity. Thus, the smaller the variation from district to district, the better the equity

of distribution per-pupil in the state education finance system. However, the range has

limited utility since it is based on only two observations in the entire distribution, thus

making it unable to indicate the pattern of variation. The range is also not sensitive to

changes within the distribution.7

The range was calculated with the following formula:

Highest Xi Lowest Xi

where Xi is the average revenue in district i.8








Restricted Range

The restricted range is the difference between the observation at the 95d' and 5dh

percentiles of the distribution.9 The restricted range does not concern itself with values

below the 5th percentile and above the 95th percentile so as not to be so sensitive to

extreme values.10 The smaller the value of the restricted range, the smaller the variation

in the distribution of per-pupil funding per individual school district. Thus, the smaller

the variation of a distribution tends to be, the more equitable the per-pupil funding

distribution. However, the restricted range is prone to the same limitations as a measure

of fiscal equity as that of the range."

The restricted range was calculated with the following formula:

Highest Xi at 95th percentile Lowest Xi at 5th percentile

where Xi was the per-pupil revenue in district i. The per-pupil revenue was arranged in

ascending order to perform this operation.12

Federal Range Ratio

The federal range ratio is the difference between the per-pupil revenue at the 95th

and the 5h percentiles, divided by the per-pupil revenue at the 5t percentile. The value is

expressed as a ratio. As the restricted range decreases, fiscal equity increases. In other

words, in a perfectly equitable distribution, the federal range ratio would equal zero,

because the restricted range would be equal to zero. The federal range ratio is "a statistic

used by the federal government to determine eligibility for states to take into

consideration federal impact aid payments to local school districts."13 As a measure of

equity, the federal range ratio is subject to the same limitations as that of the restricted

range.








The federal range ratio was calculated with the following formula:

(restricted range) / (X, at or below 5h percentile)

where Xi was the per-pupil revenue in district i.14

Variance

The variance is the average of the squared deviations from the mean for each

value within the distribution.15 It holds that the smaller the value of the variance, the

smaller the variation of the distribution of per-pupil funding per district. The smaller the

variation, the better the equity of funding to individual school districts. Because the

variance takes into account all observations, it maintains advantages over those measures

previously discussed. However, the variance is sensitive to outliers and is sometimes

difficult to interpret because it is not expressed in original units.'6

The variance was calculated with the following formula:





where Y is the sum of the sum of per-pupil funding in all districts; P, is the per-pupil

funding in district i; X, is the mean of some tested variable for all pupils; and X, is the

funding per-pupil in district i.17

Standard Deviation

The standard deviation is the square root of the variance of the entire distribution.

The standard deviation is always a positive number, and may equal zero in the case of all

observations in the distribution being identical.s8 It holds that the smaller the calculated

value of standard deviation, the smaller the variation in the distribution of revenues per

district. The smaller the deviation, the better the equity of the distribution. The standard

deviation holds an advantage over some other measures in that all observations are








included in the calculation. Furthermore, the units of measurement for the standard

deviation are in the original scale. However, the standard deviation is sensitive to outliers

that could result in a skewed distribution.19

The standard deviation was calculated with the following formula:


p,( -x,)2 / y

where Y is the sum of the sum of per-pupil funding in all districts; P, is the per-pupil

funding in district i; Xp is the mean of some tested variable for all pupils; and X, is the

funding per-pupil in district i.20

Coefficient of Variation

The coefficient of variation is determined by dividing the standard deviation by

the mean value of the distribution, or the square root of the variance divided by the mean.

The coefficient of variation is expressed as the ratio of the standard deviation of the

distribution to the mean of the distribution. It holds that the smaller the coefficient of

variation, the smaller the variation in funding per-pupil. Thus, the smaller the value of

the coefficient of variation, the better the equity of the distribution of the state finance

system to its member school districts. The coefficient of variation is sensitive to outliers,

but not to changes in the scale of the distribution.21

The coefficient of variation was calculated with the following formula:


p ,(p X,)2 / i

where Xp is the mean of per-pupil funding for all districts.22








Relative Mean Deviation

The relative mean deviation is yet another measure of univariate dispersion. The

relative mean is calculated by taking the sum of the absolute value of the differences

between per-pupil revenue and the mean per-pupil revenue, as a proportion of the total

per-pupil revenue in the entire distribution.23 To measure the equity of the education

finance system using the relative mean deviation, the sum of the absolute values of the

differences in the average amount of per-pupil funding per school district from the mean,

and then dividing that sum by the total amount of revenue received collectively by all the

school districts in the system.24

The relative mean deviation was calculated with the following formula:





where P, represents the number of pupils in district i; X, represents the average revenues

per pupil in district i; and Xp represents the mean revenues per-pupil for all pupils in the

distribution.25

McLoone Index

The McLoone Index, designed specifically for the study of education finance,

measures equity for the lower half of the revenue distribution only. It is expressed as a

ratio of the actual revenue of all pupils below the median relative to the total revenue

those pupils would receive if they were at the median per pupil revenue level in the state.

The McLoone Index ranges from 0 to 1. As the McLoone Index increases, equity for the

lower half of the distribution increases.26 The McLoone Index is represented as the ratio

of the sum of a variable if each of the variables below the mean had values equal to the








mean of the population. The larger the value of the McLoone Index, the closer the lower

half of the distribution is to the median of the distribution.27

The McLoone Index was calculated with the following formula:


P=1 P ) i ,

where school districts 1 through J are below Mp, Pi represents the number of pupils in

district i, X, represents the mean funding per pupil in district i, and Mp represents the

median value of funding per pupil among all school districts.

Gini Coefficient

The Gini Coefficient is a measure that indicates how far the distribution of

revenues is from providing each proportion of a population with the same percentage of a

variable, in the case of this study, per-pupil funding. The Gini Coefficient measures from

0 to 1. The smaller the value of the Gini Coefficient, it holds that the more equitable the

distribution of revenues are in providing a specified percentage of pupils with the same

percentage of revenues. As the Gini Coefficient value decreases, equity increases. The

Gini Coefficient compares revenues at each level with revenues at every other level and

is sensitive to changes throughout the distribution, but not to outliers.2

The Gini Coefficient was calculated with the following formula:

N N
E PP, 1 I -X,) [2 P,


where P, represents the number of pupils in district i, P, represents the number of pupils in

district, X, represents the mean funding per-pupil in district i, Xj represents the average

funding per-pupil in district, andX, represents the median funding per-pupil for all

pupils.








Measures of Wealth Neutrality

Wealth neutrality is the principle that equity exists between the fiscal capacity of

a local school district and their respective per-pupil inputs.29 Simple correlation and

slope of the regression line were utilized to measure the equality of opportunity, or

wealth neutrality.30 The independent variable was revenue per weighted FTE per

individual school district in the State of Florida, as identified by the FEFP. The

dependent variable was the additional revenue added through the performance-based

incentive program, the FSRP.

The wealth neutrality of the FEFP, both without and with FSRP funds, was

evaluated using regression analysis, with property wealth per student as the independent

variable and funding per student as the dependent variable. This relationship is expressed

in the following statistical equation:

Yi=a+f X+ e

where Y represents the dependent (or outcome) variable, a represents the intercept term,

p represents the slope of the predicted line (also referred to as the regression

coefficient), and E represents the error term.

Correlation Coefficient

Simple correlation is a measure of the relationship that describes the degree to

which two variables are associated with one another. In this study, the two variables in

question are the amount of funding per-pupil and the amount of property wealth per

student, or fiscal capacity. These two variables are used to determine the fiscal neutrality

of a state school finance system.31 A fiscally neutral finance system is one in which no

statistical relationship exists between district wealth and per-pupil funding. On the other








hand, the presence of any statistical relationship between property wealth per student and

expenditures per student is considered a sign of inequality.

The correlation coefficient has values ranging from -1.0 to +1.0. When two

variables are positively related, larger values of one variable tend to be accompanied by

larger values of the other variable. In contrast, when two variables are negatively related,

larger values tend to be accompanied by smaller values of the other. In other words,

value of +1.0 indicates a perfect positive linear relationship, where a value of -1.0 a

perfect negative linear relationship, and value of 0.0 indicates no linear relationship

between the variables, or fiscal neutrality.32

The correlation coefficient was calculated with the following formula:

N ['ON
p(X, X)(W W) P,(X, X)2 P,(W W)2


where I represents the weighted FTE of pupils in all districts, P, represents the number

of weighted FTE in district i, Xrepresents the expenditures per weighted FTE in district i,

X, represents the mean expenditure per pupil for all districts, W, represents the wealth per

weighted FTE in district i, and W is the mean wealth per pupil for all districts.

Slope of the Regression Line

The slope of the regression line equation is used to describe the relationship

between two variables. The slope of the regression line equation indicates the magnitude

of the relationship between a district's per-pupil property wealth and funds raised locally

for education, in absolute terms. The slope indicates the size of the change in the

dependent variable associated with a one-unit change in the independent variable. A

fiscally neutral public school funding system has a slope equal to 0.0. As slope








decreases, equity increases, as does fiscal neutrality. Conversely, the higher the value of

positive slope, the more inequitable the relationship between per-pupil wealth and

expenditures per weighted FTE per school district.33

The slope of the regression line was calculated with the following formula:

Yi=a+P3X

where Y represents the estimated value, a represents the intercept (the value of Y

corresponding to X=0), and P represents the slope or regression coefficient, the line of

best fit describing the relationship between the independent and dependent variables.

Elasticity

Like the slope, elasticity measures the magnitude of the relationship that exists

between the fiscal capacity of a district and its per-pupil inputs. However, instead of

being reported in terms of absolute value, elasticity is expressed in terms of percentages.

Elasticities are determined using the same equations as correlations and slopes of the

regression line. Elasticities may vary from 0.0 to any amount. An elasticity of 0.0

indicates that no relationship exists between the fiscal capacity of a school district and

per-pupil expenditures for public education in that district. As elasticity increases, the

level of fiscal neutrality, or equality of opportunity, decreases.34

The formula for elasticity, calculated at the mean values of the variables, based on

the simple regression is the following:

e=b


where W, and X are the means (pupil unit of analysis) of per-pupil property values and

per-pupil dollar inputs, respectively.








Summary

This chapter detailed the design and statistical analyses that were implemented in

this study. Statistical measures of univariate dispersion to assess the horizontal equity of

the Florida Education Finance Plan, without and with the addition of performance-based

incentive funds of the Florida School Recognition Program, were discussed.

Additionally, measures of correlation and regression were employed in an effort to

evaluate the wealth neutrality of the Florida Education Finance Program, without and

with additional funds from the Florida School Recognition Program. In the following

chapter, results of the data analysis are presented.

Notes

SDavid C. Thompson, R. Craig Wood, and David S. Honeyman, Fiscal
Leadership for Schools: Concepts and Practices (New York: Longman, 1994), 178-179.

2 Robert Berne and Leanna Stiefel, The Measurement ofEquity in School Finance
(Baltimore: The Johns Hopkins University Press, 1984), 9-28.

3 Thompson, Wood, and Honeyman, 247.

4 Kern Alexander and Richard G. Salmon, Public School Finance (Boston: Allyn
and Bacon, 1995), 240.

5 Meredith D. Gall, Walter R. Borg, and Joyce P. Gall, Educational Research: An
Introduction (New York: Longman, 1996), 176-177.

6 Thompson, Wood, and Honeyman, 247.

7Ibid.

8 Ibid.

9 R Craig Wood and David C. Thompson, Education Finance Law:
Constitutional Challenges to State Aid Plans-An Analysis ofStrategies, No. 50 in the
NOLPE Monograph Series (Topeka, KS: National Organization on Legal Problems in
Education, 1993), 49.









10 Berne and Stiefel, 19.

Thompson, Wood, and Honeyman, 248.

12 Berne and Stiefel, 20.

13 34 C.F.R. Ch. 11 (11-1-89 Edition) Section 222.61 (a); Ker Alexander and
Richard G. Salmon, Public School Finance (Boston: Allyn and Bacon, 1995), 236.

14 Berne and Stiefel, 20.

15 Thompson, Wood, and Honeyman, 249-250.

16 Alexander and Salmon, 236.

17 Thompson, Wood, and Honeyman, 249.

18 Gall, Borg, and Gall, 178-179.

19 Thompson, Wood, and Honeyman, 249.

20 Ibid.

21 Ibid., 249-250.

22 Ibid., 249.

23 Beme and Stiefel, 19-20.

24 Ibid.

25 Ibid., 20.

26 Thompson, Wood, and Honeyman, 250.

27 Ibid.

28 Ibid., 251.

29 Alexander and Salmon, 238.

30 Beme and Stiefel, 17.

3 Ibid, 26.





87


32 Thompson, Wood, and Honeyman, 251-252.

33 Ibid.

34 Alexander and Salmon, 239.













CHAPTER 4
RESULTS


Introduction

The purpose of this study was to examine the effects on fiscal equity of a

performance-based funding incentive program, the Florida School Recognition Program.

The effects of the FSRP on both horizontal equity and wealth neutrality were measured in

this study. Statistical measurements for examining the degree of fiscal equity in the field

of public school finance were employed. The degree of horizontal equity of total revenue

per weighted full-time equivalent student for the sixty-seven (67) public school districts

in the state of Florida for the five-year period since the inception of performance-based

funding was determined. Total revenue was funding from the Florida Education Finance

Plan, derived from a combination of state and local sources. The years of the study were

1998-1999 through 2002-2003.

To conduct this study, the state of Florida's yearly total appropriation from the

Florida Education Finance Plan calculation was considered with and without the

performance allocations from the Florida School Recognition Program for each of the

five years since inception of the performance-based funding model. Revenue per-student

was calculated by taking the total revenue for public education and dividing it by the

weighted full-time equivalent student count (WFTE). Standard measures of horizontal

equity were applied and per-pupil revenues were examined across the five years of study

to determine the degree of fiscal equity in the Florida Education Finance Plan.








The previous chapter included a discussion of the methods that were utilized to

measure the equity and wealth neutrality of the Florida Education Finance Program since

the inception of the Florida School Recognition Program. This chapter presents the

results of the analysis beginning with the measures of horizontal equity and continuing

with the measures of wealth neutrality.

Measures of Horizontal Equity

The horizontal equity of the Florida Education Finance Program (FEFP) was

measured by comparing the levels of state and local funding among the sixty-seven (67)

public school districts since the inception of the Florida School Recognition Program

(FSRP) over a five-year period. The purpose of this analysis was to arrive at whether

pupils who were equal in their circumstances were receiving equal treatment by the state

as measured by the amount of funding per pupil.

A series of standard measures of univariate dispersion methods were utilized to

complete this study. These measures, defined in the previous chapter, included the mean,

median, range, restricted range, federal range ratio, variance, standard deviation,

coefficient of variation, McLoone Index, and Gini Coefficient. Measures of wealth

neutrality included the correlation coefficient, slope of the regression line, and elasticity.

The following sections describe the results of the analysis for each measure of horizontal

equity. At the end of this chapter, comprehensive assemblages of these are presented in

Table 4-1 and Table 4-2.

Mean

The mean, or arithmetic average, amount of state and local funding per weighted

full-time equivalent (WFTE) in the FEFP without performance-based funding increased








from $4678.35 in 1998-1999 to $5139.02 in 2002-2003. Therefore, the mean per-pupil

funding for the FEFP without the addition of FSRP funding increased by $460.67, or 9.8

percent over the first five years of inception of the FSRP.

The mean funding per WFTE in the FEFP with performance-based funding

increased from $4690.22 in 1998-1999 to $5194.18 in 2002-2003. There, the mean per-

pupil funding for the FEFP with the addition of FSRP funding increased by $503.96, or

10.7 percent over the first five years of inception of the FSRP.

While the mean itself is not considered an indicator of equity, it does provide for a

meaningful context in which to consider trends in equity during the five years since the

inception of the FSRP performance-based funding model. Figure 4-1 illustrates the mean

per-pupil expenditures without and with FSRP funds.


$5,300
$5,200 --Mean without FSRP
$5.100 --Mean with FSRP
$5,000
$4,900
$4,800
$4,700
$4,600
$4,500
$4,400
1998-99 1999-2000 2000-01 2001-02 2002-03


Figure 4-1: Mean Per-Pupil FEFP Expenditures Without and With FSRP Funds

Median

The median value of the distribution was a useful measure of central tendency,

since it serves to reduce the effect of spurious outliers in the data. In this study of 1998-









2003, the medians were somewhat smaller by comparison than the means for each of the

five years in question. These results served to suggest that the distribution of FEFP

revenue per WFTE was somewhat skewed toward the lower end of the distribution.

However, the median results followed the same general trends found in the mean values

from year to year in each of the five years of the study.

The median funding per WFTE without performance-based funding increased

from $4633.87 in 1998-1999 to $5111.94 in 2002-2003, or $478.07, over the five-year

period since the inception of the FSRP. Overall, the median increased steadily each of

the five fiscal years of the study. Comparatively, the median funding per WFTE with

performance-based funding increased from $4640.15 in 1998-1999 to $5163.63 in 2002-

2003, or $523.48, over the same span of time. While the median in itself does not serve

as a meaningful indicator of equity, it does provide a useful context for an analysis of

equity over the course of the five fiscal years contained in this study. Figure 4-2

illustrates the median per-pupil expenditures without and with FSRP funds.


$5,300
$5,200
-e0 Median without FSRP
$5,100 -
$5000 --ea.an w-0 FSRP
$4,00
$4,900
$4,800

$4,600
$4,500
$4,400
$4,300

1998-99 1999-2000 2000-01 2001-02 2002-03


Figure 4-2: Median Per-Pupil FEFP Expenditures Without and With FSRP Funds








Range

The range, which represents the arithmetic difference between the highest and

lowest points in the distribution, was a measure used to examine the spread of the per-

student revenue distribution.' To calculate the range, the sixty-seven (67) school districts

were arranged in ascending order according to per-student revenue and the lower per-

student revenue was subtracted from the highest per-student revenue. The smaller the

range value, the smaller the variation in the distribution of total revenue per WFTE, and

the greater the equity of the distribution of revenues per student.2 In other words, the

smaller the range, the more minimal the difference in funding between districts at the top

and bottom of the distribution.

The per-student funding range in 1998-1999 was $963.12 without performance-

based funding and $980.69 with performance-based funding, or a difference of $17.57

per-pupil. The per-student funding range in 1999-2000 was $844.34 without

performance-based funding and $878.04 with performance-based funding, or a difference

of $33.70 per-pupil. The per-student funding range in 2000-2001 was $927.63 without

performance-based funding and $979.82 with performance-based funding, or a difference

of $52.19 per-pupil. The per-student funding range in 2001-2002 was $1015.64 without

performance-based funding and $1059.44 with performance-based funding, or a

difference of $43.80 per-pupil. By 2002-2003, the funding range was $1117.19 without

performance-based funding and $1160.23 with performance-based funding, or a

difference of $43.04 per-pupil. Generally, the range both between funding without and

with performance-based funding increased over the five-year span of the study, indicating

less funding over the course of this study.




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