SALAMANCA — After more than a year of revision and review, a decades-old federal program impacting the Indian reservation-based Salamanca school district received an official update this fall.
The Salamanca Board of Education on Tuesday approved the updated Indian Policy and Procedures (IPP) document for application of Federal Impact Aid for the 2017-18 school year.
The Salamanca City Central School District was required to update their IPP document through the Title 7 program. Previously Title 8, the program was converted into Title 7 statute under the Every Student Succeeds Act (ESSA).
According to district superintendent Robert Breidenstein, the IPP review is necessary under the ESSA updates and reauthorizations of the Elementary and Secondary Education Act of 1965.
Although Title 7 deals with several different areas, the school district’s concern is with the Impact Aid program run through the health and human services, education and bureau of Indian Affairs departments for districts impacted with federal lands related to tribal territories.
Congress reauthorized the federal program in 2015 with an official implementation in July of this year. However, the program guidelines didn’t come out until the end of October 2016. Since then, after further governmental review, the district has been going over what the IPP updates mean specifically for Salamanca.
“Our Indian Policy and Procedures document has been in place since we were first eligible for Impact Aid back in the 2012-13 school year,” explained Breidenstein.
Breidenstein said the district has consulted with the National Indian Impacted Schools Association and had conversations with the National Association of Federally Impacted Schools (NAFIS), the Impact Aid office for New York state and the Impact Aid program office in Washington, D.C.
“This is the latest, greatest, best advice and guidance from everyone who is working in this field,” he said.
Previously, the IPP document had eight standards. Those eight standards were merged into six policies. Those six policies now must have procedures attached to each one of them. In the previous eight-standards format, there was not a requirement to have procedures in place, but the Salamanca school district did anyway.
“We weren’t required to, but we did. So for us, this transition was relatively easy,” Breidenstein said. “We just needed to make sure that our procedures were properly aligned.”
The four Western New York districts affiliated with the Seneca Nation of Indians — Silver Creek, Lake Shore, Gowanda and Salamanca — have been in constant conversation discussing what the revised IPP means, Breidenstein added.
“Most of the changes from our previous documents are, in almost every instance, wordsmithing changes,” he explained. “For some of those changes, the federal folks said it doesn’t matter and we can pick (either term).”
Breidenstein said there were only about six separate statements that needed to be corrected throughout the document.
Although the document has to be titled “Indian Policy and Procedures,” one significant change is choosing to refer to Native American students, families or tribal associations as “Native American” throughout the document instead of “Indian” as it was in previous versions.
“In conversation with tribal officials and community members, they felt strongly that it should be reflective of Native American,” Breidenstein said. “So that was a wordsmithing change that was reflective of community conversation and input.”
Federal government officials suggested changing the term “tribe” as recommended previously to “tribal officials” or “tribal designees.” Another minor change was replacing “LEA” — which stands for “Local Education Agency” and is code for school district — with the full name of the school district in its first reference and then “the district” in every reference thereafter.
Board of Education member Kerry John noted an inconsistency in the language with both “Native American parents” and “parents of Native American children” used interchangeably. John recommended “parents of Native American children” be the definitive term because the program affects all Native American children even if they have a non-Native parent.
A final change under Policy 5, Procedure 5.2, the district must list: “If after receiving input from tribal officials/designees and parents of Native American children, the district determines the need to amend the IPP, within 90 days the plan will be amended.”
Within 30 days of that timeframe, the district officials or designees must distribute a revised IPP to the tribal officials or designees and directly to Impact Aid.
“Previously, we could make the changes. There was no recording mechanism into getting that back to tribal officials or to the folks in Washington,” Breidenstein explained. “That is now a requirement, which means we made the adjustments based on input, based on the best information from the webinars and the changes.”
Because the document was approved by the school board at the meeting on Tuesday, it will next go to the tribal officials and designees. The document must have two district official signatures and two tribal official signatures on it in order to be authorized.
“This must be included in the Jan. 31 Impact Aid application,” Breidenstein said. “This change and the speed in which it is implemented to get that protection from the federal government for impact money is a significant development for impacted districts.”
