Proposed Update to Vermont's Significant Disproportionality Methodology

Background

Beginning in 2020, federal law includes a requirement for states to monitor whether students from particular racial or ethnic groups are identified for special education, placed in certain educational settings, or disciplined at rates that are significantly different from their peers. This requirement, known as significant disproportionality, is intended to ensure that all students are treated equitably and that school systems examine and address policies or practices that may contribute to disparities.

Vermont established its current methodology for identifying significant disproportionality in 2020. This methodology uses a statistical measure called a risk ratio, which compares the likelihood that students from a particular racial or ethnic group experience a given outcome (such as special education identification or disciplinary action) to the likelihood for all other students in the same supervisory union or district (SU/SD).

When the population of other racial or ethnic groups within a district is too small to make a reliable comparison, Vermont uses an alternate risk ratio that compares the district's rate to the statewide rate for other students. Significant disproportionality is identified when the calculated risk ratio exceeds a threshold of 3.0 for three consecutive years.

To ensure calculations are statistically meaningful, Vermont also applies minimum group sizes before calculating risk ratios.

If a district is identified, they complete a root cause analysis and action plan with support from the Agency. The district is then required to set aside 15% of their IDEA-B Basic and IDEA-B Pre-K grant funds to implement their action plan for a number of years corresponding to the number of years they are identified.

The Agency recently identified an issue with the methodology used since 2020. As described below, a new methodology will be used going forward to accurately measure disproportionality. Note that Vermont's IDEA application is also currently posted for public comment. View the IDEA application public comment.

Identified Methodology Issue

Through a collaborative process of data review with the field, the Agency identified issues related to both the data sources used since 2020 in the calculations and the communication process with districts.

The methodology relies on federally required data collections reported through EDFacts, a U.S. Department of Education initiative to centralize data from all states and territories. However, these data sources count students in different ways.

In most cases:

• Membership data counts students based on their district of enrollment.
• Special education child count data counts students based on their district of residence.

Because Vermont has a number of districts that tuition students to other districts or independent schools, this difference can create inconsistencies between the groups being compared in the calculations. In some cases, students may be counted in the numerator (students experiencing an outcome) under one district but counted in the denominator (students eligible to experience that outcome) under another. These discrepancies can affect the accuracy of risk ratio calculations and may create uneven comparisons across supervisory unions and districts.

In addition, the Agency planned to notify districts when their calculated risk ratio exceeded the established threshold through annual warning letters. However, these warning letters were never distributed. As a result, communication between the Agency and districts with elevated risk ratios did not occur prior to identification, limiting opportunities for early dialogue before sanctions applied.

The Agency is addressing both the technical data issue and the communication process to ensure that districts receive timely and clear information going forward.

Proposed Methodology Update

To address this issue and improve consistency, the Agency proposes to count all students according to their district of residence when calculating significant disproportionality.

This approach aligns with federal IDEA requirements, which generally place responsibility for special education services with the district of residence. Using district of residence for all calculations will ensure that the numerator and denominator in risk ratio calculations are based on the same district population.

This change will:

• Create internally consistent risk calculations
• Provide a more accurate comparison across districts
• Ensure that supervisory unions and districts are evaluated on a more level playing field

Implementation

The Agency has recalculated risk ratios for the three-year data window (the 2021-2022 school year through the 2023-2024 school year) used to determine significant disproportionality for the 2023-2024 school year identification cycle using this updated approach.

The Agency intends to use these revised calculations for determinations of significant disproportionality for the 2024-2025 school year identification cycle and future cycles. Applying this new methodology impacts three districts: two are being removed from this designation, and one that was not previously identified has been listed as identified.

Commitment to Transparency and Equity

Monitoring significant disproportionality is an important component of ensuring equitable educational opportunities for all Vermont students. The Agency is committed to maintaining transparent methodologies, continuously reviewing data practices, and making adjustments when necessary to ensure that analyses accurately reflect district conditions.

Submit a Comment

Public input is an important part of this process, and the Agency welcomes feedback on this proposed update. Send comments or questions by email to [email protected]. Comments will be considered through May 18, 2026.