In 2020 the Michigan Department of Education began the process of revising its State Determined Performance Levels (SDPLs) for the Strengthening Career and Technical Education for the 21st Century Act (Perkins V) as a result of the COVID-19 (Coronavirus) pandemic. This blog post features a discussion with Dr. Jill Kroll, Supervisor for the Grants, Assessments, Monitoring and Evaluation Unit, and Dr. Yincheng Ye, Research Consultant, at the Michigan Department of Education’s Office of Career and Technical Education.
Michigan is one of the first states to make adjustments to its Perkins V SDPLs as a result of the Coronavirus pandemic. Can you explain what changes you are proposing and why? 
We are proposing to reduce our SDLP for 3S1—Secondary Post-Program Placement from 95 percent to 75 percent for 2020-2021 and to 80 percent for 2021-2022, returning it to the original SDLP of 95 percent in 2022-2023.
Our reasoning for requesting this change is that we expect that student placement in both employment and continuing education will be adversely affected by the pandemic. This is based on a review of employment projections from the University of Michigan, U.S. Bureau of Labor Statistics projections, and research reports and other reports indicating a reduction in postsecondary enrollment, especially among first-year college students and low-income students.
We also requested and received a waiver from the U.S. Department of Education (USED) for reporting the academic indicators 2S1 and 2S2 because our state did not administer the 11th grade tests in Spring 2020, which will affect the data for students graduating in Spring 2021. We are awaiting the decision on the Spring 2021 assessments. If our state receives a waiver for the Every Student Succeeds Act (ESSA), the waiver will also apply for Perkins (Our state already had a waiver from reporting the Science indicator 2S3 because we have a new assessment).
We did not feel that we needed a waiver for our indicator of program quality, 5S1—Attained Recognized Postsecondary Credential because our SDPL was already set quite low in our state plan due to the fact that we will be phasing in approval of credentials over several years. This info page for our State Board of Education and for public comment summarizes the proposed changes and includes citations for our evidence.
With conditions changing so rapidly under the Coronavirus pandemic, projecting data over the next few years can be like trying to hit a moving target. How were you able to make these projections work?
We were lucky that the University of Michigan produces solid quarterly economic and employment projections. We participated in several webinars beginning in Spring 2020 on the economic impact of the pandemic so we were aware of the resources available. We felt that it was important to follow procedure and propose reduced SDPLs where appropriate, and take the proposed levels for public comment, even if we had to base the proposed levels on estimated impact.
How are you explaining to the public why Michigan’s SDPLs need to be adjusted? 
We cited the available data. We found, during the initial public comment period for our Perkins V state plan, that stakeholders and the public were very receptive as long as we provided our reasoning for our recommendations, so we anticipate the same will be true for our proposed modifications. Here is what we have listed on the info sheet for public comment:
Both employment and postsecondary enrollment have been negatively influenced by the COVID-19 pandemic and economic shutdown in 2020. The Post-program Placement indicator needs to be adjusted to reflect these impacts.

• In November, the Michigan Economic Outlook 2020-2022 showed the actual unemployment rate as 8.66% in Q3 2020; and forecasted the unemployment rate to drop to 7.85% for Q4 2020, declining to an average of 7.01% in 2021, reaching 5.60% by the end of 2022, but still higher than 2019-year average (Ann Arbor: University of Michigan).
• Nationally, the data from U.S. Bureau of Labor Statistics shows the unemployment rate for youth was 18.5% in July 2020, down from 26.9% in April but still about twice as high as a year earlier. 
• An article in Inside Higher Edcites a study by the NSC research center is showing 16% fewer freshman have enrolled this fall compared to last year. The community colleges had an even steeper enrollment drop of 23% among first-year students.
• Additionally, estimates in Michigan indicate that low-income students may have an 8-10 percentage point drop in college enrollment.

States have to go through the same public comment process to adjust their SDPLs as when they first developed their Perkins V plans. How has this process been similar or different to the original public comment period? 
We are following the same process as we did for our Perkins V state plan, presenting the proposal to stakeholder groups, taking the recommendations out for virtual public hearings, and publicizing the public comment opportunity through an online survey on our website. We also had to present to our State Board of Education prior to the public comment period and will have to present to them again after public comment, including the public comments.
What advice would you give states that are considering whether or not to change their Perkins V SDPLs? 
My advice would be to continue to regularly review the data related to each of the indicators. If it appears that the pandemic (or any other unanticipated circumstance) may affect the state’s ability to meet the SDLPs, develop a timeline for revising the SDLPs and then do it. I think it is important that school districts feel that the SDLPs are fair and reasonable and if they are unattainable due to circumstances outside the control of the districts and/or colleges they lose their value as engines of program improvement. I also think it is important for state offices to do our due diligence to maintain the faith and trust of our educators, districts, colleges and the public.
My other recommendation is to plan, plan, plan. A timeline is critical. As soon as we realized we needed to revise our SDLP we did two things. First, we contacted the Office of Career, Technical and Adult Education (OCTAE) at USED to verify that we could adjust the SDPL and to get the deadline for submitting the adjustment. Contact information for OCTAE Perkins Regional Coordinators is listed here. Second, we immediately worked out a timeline (this was in August) and quickly realized how long the process would take, with two State Board Meetings required as part of the process. It was only because we worked out the timeline so early that we will be able to make the OCTAE deadline for revising state plans and SDPLs on May 21.
Today, Advance CTE and the Association for Career and Technical Education released Mitigating Unanticipated Circumstances: Resetting Perkins V State Determined Performance Levels During the COVID-19 Pandemic, a guide to help states revise their Perkins V SDPLs. Dr. Kroll served on the workgroup that helped produce the guide.