Friday, August 26, 2016

NYSAPE and Class Size Matters to NYSED re their accountability plan for schools: slow down! & consider our Opportunity to Learn Index

Here's a letter we just sent today to Commissioner Elia and the Board of Regents about the state's proposed Accountability plan for schools, required under ESSA. 

We urge them to slow down the process to allow for more public input and also to consider including an Opportunity to Learn index in their proposed plan.

August 26, 2016

MaryEllen Elia, Commissioner of Education
NYS Education Department
89 Washington Avenue
Albany, New York 12234

Dear Commissioner Elia,

New York State Allies for Public Education is a coalition of more than fifty parent and educator organizations from throughout the state.  Class Size Matters is a parent advocacy group focused on reducing class size, increasing parental engagement and strengthening student privacy.  We are submitting these recommendations as part of the public comment process for the state’s accountability system that NYSED is required by Every Student Succeeds Act (ESSA) to submit to the U.S. Department of Education.  Rather than fill out your survey with extremely constrained choices, we thought it preferable that we explain in more detail how we believe that the process of drafting the state’s plan should improve, and what we hope you will consider including in the accountability plan itself.

First of all, we strongly urge you to slow down the drafting of the state’s plan.  Most parents and teachers are not paying attention over the summer, and in order to fully engage their input, hearings and a more inclusive public comment process should occur over the fall and winter months before the State begins to draft its accountability plan.  The deadline for this Accountability proposal is not due until July 2017, therefore it would be best to take advantage of these months to hear from parents, educators and other stakeholder groups before drafting your proposal.  In addition, the final regulations are not expected to be issued by the US Department of Education until sometime in late October.  It is unwise to try to draft even your initial proposal until all concerned have had a chance to read and analyze these regulations.

Second, we believe that the state’s apparent intention to draft a system based on a particular notion of “effective schools” is excessively vague and would be impossible to objectively assess.  Factors such as “visionary instructional leaders”, “cultural responsiveness” and “engaging curricula” are all important, no doubt; but are very difficult to measure.  We are also apprehensive that other factors, including “curricula…tied to appropriate formative and summative assessments, which are aligned to State learning standards” may lead to even more testing, detracting from the learning environment.

Instead, we suggest you consider adopting a system based on “Opportunity to Learn” index, with evidence-based factors that have been tied to better learning conditions, are discrete and measurable, including but not limited to class size, suspension rates, teacher experience levels and attrition.  Many of these factors are already reported to NYSED for the purpose of completing the state report cards.  We attached a list that we believe should be included in such an index, and that parents in our networks consider essential to providing their children with a quality education.

It appears from the survey that NYSED may be contemplating adopting some sort of “Opportunity to Learn” index when they intervene in struggling schools, but it seems preferable instead to encourage schools to provide their students with the conditions for success before they slip into the struggling status.   What gets measured and reported in the state’s accountability should be those factors that help our children learn and thrive in the years to come.

Sincerely yours,

Lisa Rudley, Executive Director – New York Allies for Public Education

Leonie Haimson, Executive Director - Class Size Matters

Cc: Board of Regents

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