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
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
Attachment: Opportunity to Learn Index
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