Re: School Improvement Grants – American Recovery and
Reinvestment Act of 2009; Title I of the Elementary and Secondary
Education Act of 1965 – Notice of Proposed Requirements – Docket ID
ED-2009-OESE-0010
Proposed Requirements for
“School Improvement Grants” Have Some Valuable Content, But Need
Substantial Revision
Re
Overview of the Secretary’s Proposal, 74 Fed. Reg. 43102, et seq. (Aug.
26, 2009)
The Forum on Educational Accountability (FEA)
appreciates the opportunity to respond to Education Secretary Duncan’s
“Notice of proposed requirements” for “School Improvement Grants.”
Fundamentally, FEA concludes that, while some of the proposed requirements
have merit, a number of them must be substantially revised.
FEA is an alliance of national education, civil
rights, religious, disability, parent, union and civic organizations
supporting comprehensive public school reform. FEA’s comments are rooted
in its two statements, the “Joint Organizational Statement on No Child
Left Behind (NCLB)” (2004) and “Empowering Schools and Improving Learning:
A Joint Organizational Statement on the Federal Role in Public Schooling”
(2009); and its two reports, “Redefining Accountabilty: Improving Student
Learning by Building Capacity” (2007) and “Assessment and Accountability
for Improving Schools and Learning: Principles and Recommendations for
Federal Law and State and Local Systems” (2007). The first two documents
are appended to the end of these comments. All published FEA materials
are on the web at
http://www.edaccountability.org.
The Secretary properly recognizes that many of the
chronically lowest-performing schools need intensive staff development,
technical assistance, tracking of reform strategies being implemented and
difficulties encountered, and a change in culture in order to turn
around. The proposed regulations take some useful steps in that
direction.
However, the draft requirements do not consistently
adhere to that capacity-building theory of change. Instead, in certain
key respects, the proposed requirements impose rigid and punitive
restrictions on staffing, authorize premature funding cut-offs, fail to
include vital elements of effective turn-arounds, and otherwise need to be
reframed. To facilitate enabling LEAs and SEAs to “make the fundamental
changes needed to turn around [the] lowest-achieving schools,” 74 F.R.
43114, the proposed requirements must be revised to rectify these
deficiencies.
More broadly, the Department should work with
Congress to write a new Elementary and Secondary Act that will put FEA
recommendations for comprehensive, systemic school improvement at the
center. FEA hopes that it will be able to assist the Department in that
process.
Replacement of Staff
I.A.2.a. (i)(ii), I.A.2.d. (i)(A)(2)(3), Proposed
Requirements, “Turnaround Model,” 74 F.R. 43108, “Transformation Model,”
p. 43109.
At the outset of both the “Turnaround” and
“Transformation” models, the proposed regulations mandate,
unconditionally, that the principal must be replaced, as must “at least
50% of the staff” in a “Turnaround” school. These rigid requirements
raise serious questions of fairness and practicability, and would reduce
achievement in at least some schools.
As the Secretary notes, turning around “our Nation’s
most persistently low-achieving schools [is] education’s most intractable
challenge [.]” p. 43102. It “is particularly challenging [.]” p. 43107.
However, the preparation that most principals of these schools received
never equipped them with the knowledge and skills they need to lead the
complex and multi-faceted initiatives and teams, among multiple
stakeholders, required to overcome this “intractable challenge.” If these
principals were given adequate training and support, and their schools’
funding and other unmet needs were met, many of them likely would be able
to do the job satisfactorily. Further, the automatic replacement
requirement is severely overbroad, since it could apply even to principals
who had only been in office for a month or two prior to the new
intervention, as well as to those who had had their staffs seriously cut
due to district-wide budget deficits, or suffered other burdens beyond
their control. In light of these factors, it is unfair and unreasonable
to mandate that all such principals be replaced.
Moreover, it is by no means clear that skilled and
competent transformation leaders could be found to replace principals in
many of the schools to be funded by SIG. Although America has a
relatively small number of educators who have successfully led turnarounds
and may have the necessary knowledge and skills to do so again, their
number is wholly insufficient to meet the need to lead transformations in
all of our very low performing schools, and likely not in the 1,000 –
2,000 schools apparently contemplated by SIG. It would serve no useful
purpose to fire potentially teachable and competent principals where there
is no assurance that a capable replacement can be found. Although it may
be warranted for LEAs to replace certain principals if they find serious
lack of capability and motivation to work hard, other principals may well
have the capacity and should first be given the training, mentoring and
support they would require to have a chance of success. These principals
should be replaced only if this capacity building effort were not
effective.
Similarly, while some current teachers and other
staff may not have the interest and motivation to actively join a
transformation effort, to mandate replacement of “at least 50 percent of
the staff,” as the Turnaround Model does, would be arbitrary, disruptive
and reduce achievement in at least some schools. Likewise, to mandate
schools to “remove” any staff who fail to “improve student achievement
outcomes,” as the Transformation Model does, will predictably lead to
“drill and kill” instruction and manipulation of test scores (as has
repeatedly happened under No Child Left Behind), undermining the very
purpose of the SIG grants. Moreover, it is unfair, since it has no
exception for teachers and other staff who were given little training or
support but who, with professional development and sustained support,
could do their jobs well. And it is overbroad, since it could potentially
be applied to any pupil services professional, paraprofessional or other
staff, from social workers to janitors, who had little or no legitimate
responsibility for increasing student achievement on state exams.
Finally, it is not at all clear that a sufficient number of teachers who
are highly skilled in working with the very needy populations of the most
needy schools would be available to replace staff removed from Turnaround
or Transformation schools.
FEA therefore recommends that this section be
rewritten to call for a careful evaluation of the principal and all staff
in order to ascertain whether any should be replaced. SIG schools should
also be required to develop comprehensive, high-quality staff evaluation
and improvement systems that are linked to the professional development
requirements under SIG, as recommended for modification below.
Assessments
I.A.2.a. (vi), I.A.2.d.(i)(A)(1), (ii)(A)(2),
“Proposed Requirements,” “Turnaround Model,” p. 43108, “Transformation
Model”, p. 43109; II.C. “Renewal for Two
Additional One-Year Periods,” p. 43111.
While “interim” and “summative” assessments may be of
limited use in helping improve teaching and learning, assessment needs to
go beyond using predominantly multiple-choice tests to incorporating
performance tasks. In the words of President Obama, these can show
student ability to “use technology, conduct research, engage in scientific
investigation, solve problems, present and defend their ideas.” New
assessment systems also should include the use of locally-based evidence
of student learning, in addition to state level exams. Further, state
evaluations of “student achievement” need to incorporate additional data,
such as high school graduation rates.
In addition, of greatest use to
teachers in helping students learn are “formative assessments.” These
provide teachers with prompt feedback on what their students do and do not
understand, and they enhance teachers’ skills in adjusting instruction
accordingly to meet the needs of individual students. The regulations
need to list the use of formative assessments not just as an example of
what grantees may do, but as something that they must do as part of a SIG
grant. Teacher capacity to develop and use a full range of assessments
should be included under professional development, as recommended for
amendment below. And use of “growth” models should be required for the
Turnaround Model, as well as in the Transformation Model where it already
is, provided that the growth models include an adequate range of types of
assessment, not only the multiple-choice and short-response items that now
dominate state exams.
Professional Development
I.A.2.a.(v), I.A.2.d.(i)(A)(4), “Proposed
Requirements,”, “Turnaround Model,” p. 43108, “Transformation Model,” p.
43109.
The proposed regulations’ sections on “professional
development” need to be substantially revised. Professional development
must not be provided “to” staff, as in the current Turnaround Model, but
“with” school-wide staff’s active involvement in identifying students’
learning needs. It should be made explicit that professional development
must be used not just to equip senior staff to “facilitate effective
teaching and learning,” but in directly enhancing the knowledge and skills
of teachers and other staff. And it needs to be focused heavily on
helping teachers to teach and assess a challenging curriculum to diverse
students in ways to gain their interest and active participation.
Moreover, it is essential to require in both sections
that schools provide mentoring to meet educators’ individual pedagogical
and leadership needs. And career ladders must be established for mentor
teachers and other specialists to support ongoing teacher and principal
improvement.
Family and Community Support and Involvement
I.A.2.a.(viii), II.A.2.d.(iii)(A)(4), “Proposed
Requirements,” “Turnaround Model,” p. 43108, “Transformation Model,” p.
43109.
The provisions on family and community support and
involvement need to be significantly expanded so that SEAs, in conjunction
with LEAs, are required to arrange, and if necessary, pay for, qualified
public or private organizations to provide programs of adult literacy and
parenting skills for parents in SIG funded schools, as well as adult
mentors for students without parents available. And the LEAs themselves
need to reach out to families to become involved with the schools. These
systemic changes are necessary so that school staff and parents, or other
responsible adults at home, will be working together to transform the
children’s learning.
Curriculum
I.A.2.a., I.A.2.d., “Proposed Requirements,”
“Turnaround Model,” p. 43108, “Transformation Model,” p. 43109.
In addition to addressing assessments and staff
development, it is important that both the Turnaround and Transformation
models require LEA grantees to provide all students a coherent, rich and
intellectually challenging curriculum. This needs to include critical
thinking, problem-solving and high-level communications skills, and to
ensure deep understanding of content. And it must include art, music,
physical education and a varied curriculum, not only because of the
importance of a broad-based education to all today’s children, but to
engage the interest of students who may only be reached that way.
Charter Schools, CMOs and EMOs
I.A.2.b., “Proposed Requirements,” “Restart Model,”
pp. 43108-9.
Use of appropriate assessments and curriculum,
provision of high quality professional development and time for peer
collaboration, and enhancing the support and involvement of families and
communities as described above are essential for all SIG schools. Yet
charter schools, charter management organizations and education management
organizations seem to have been tacitly exempted from these requirements.
They should be held accountable for implementing these systemic reforms
the same as schools implementing the “Turnaround” and “Transformation”
models.
Resources
I.A.2.a., I.A.2.d., “Proposed
Requirements,” “Turnaround Model,” p. 43108, “Transformation Model,” p.
43109.
As explained above, some of the proposed steps in
both the “Turnaround” and “Transformation” models – if those models are
revised – could contribute to building school capacity to improve teaching
and learning and student achievement. However, as the Notice
acknowledges, p. 43105, in most instances the cost of interventions would
substantially exceed the maximum annual school grant statutorily
authorized. In addition, the schools that will receive SIG funds are
often overcrowded and housed in crumbling buildings that do not have:
sufficient light, heat, and air conditioning; working science laboratories
and equipment; accessibility for students with limited mobility; music and
art supplies; sufficient libraries, books and computers; and other
essentials.
The Department of Education should reserve SIG
funding to conduct professional, rigorous studies to determine the costs
of providing a high-quality education to the students attending these
schools, including the increased “instructional time,” “expanding the
school day…week…year,” and other steps necessary to offer students from
poverty backgrounds, those learning English, and those with disabilities a
genuine opportunity to learn. This would be valuable preparation for the
ESEA reauthorization.
In addition, many of the Tier I,
II, and III schools are under-funded and have been for
years because many state -- and the
federal -- education finance systems are inequitable and provide
inadequate funding to schools and districts in low-wealth communities.
Each state should be required to develop strategies for providing
resources to overcome these inequities and inadequacies. The goal is to
provide resources sufficient to ensure every child can participate in high
quality learning experiences.
Flexibility
I.B.1., “Proposed Requirements,” “Providing
Flexibility,” p. 43110.
FEA commends the flexibility of allowing schools that
have already begun interventions that satisfy the proposed requirements to
qualify for SIG funds.
State Technical Assistance Capacity
II.D., “Proposed Requirements,” “State Reservation
for Administration, Evaluation, and Technical Assistance,” p. 43111.
SEAs in general need to dramatically increase their
capacity to assist LEAs in leading turnarounds. States should be required
to spend a substantial part of their five percent, not just for 2009, but
for each year they receive SIG funds, to expand their staff’s knowledge,
skills and manpower to assist, monitor, evaluate and where necessary, lead
transformations of very low-performing schools.
Reporting
III.A., “Proposed Requirements,” “Reporting
Metrics,” pp. 43111-12.
The proposed regulations soundly recognize that
“[l]ocal educators need … data on an ongoing basis to evaluate the extent
to which effective reform strategies are being implemented, to monitor the
impact of changes, to track progress against their own goals, and to
identify areas where, during implementation, assistance or adjustments are
needed.” p. 43107. In effect, this is a recognition that, for schools to
transform themselves, they need to regularly collect and review
information on what steps they are taking to implement the various reform
strategies and what obstacles they are running into for which they need to
make adjustments.
However, the new metrics that the proposal would
require (including which intervention model they’re using, average scores
on state assessments, AP and college enrollment rates, numbers of
instructional minutes, and teacher attendance) will not tell them
virtually any of the information they would need to know as to the status
of specific “reform strategies.” For example, the metrics are silent on
the status of implementation of “professional development,” “formative
assessments,” “time for collaboration” and “mechanisms for family and
community engagement.” The reporting section needs to be substantially
re-crafted to address this issue.
Funding Cut-Offs After One or Two Years
II.C., “Proposed Requirements,” “Renewal for Two
Additional One-Year Periods,” p. 43111.
The proposed regulations state that “research
…suggests that the lowest achieving schools - … (3) Need substantial
funding over three to five years to plan, implement, and solidify rigorous
interventions that change school culture and result in substantial
increases in student achievement.” P. 43104. The experience with NCLB
indicates that it is very difficult for many districts and schools,
including charters and EMOs, to consistently and significantly raise
student achievement for every student subgroup even on often very low
level state assessments. Moreover, the schools that are SIG’s target are
the ones at the very bottom, the ones confronting the most difficult
situations that need the most help to move forward.
Given these considerations, it would be needlessly
rigid, counter-productive and self-defeating to allow LEAs to terminate
funding SIG funds after one or two years. To require meeting the goals
“with respect to all students in the school, as well as each subgroup,” p.
43111, as a condition of being entitled to a three-year grant is
excessive, punitive and unreasonable. If LEAs were wholly failing to
implement the required reform strategies or to act in good faith, SEAs
should be allowed to terminate the grants. Otherwise, SEAs need to
provide technical assistance to help get the LEAs on track. This
provision needs to be greatly restructured.
Monty Neill, Ed.D.
Chair
FairTest, 15 Court Square, Suite 820, Boston, MA
02108; 857-350-8207 x 101;
monty@fairtest.org
Gary Ratner, Esq.
Chair, Committee on Capacity-building
Citizens for Effective Schools, 8209 Hamilton Spring
Ct., Bethesda, MD 20817; 301-469-8000;
gratner@rcn.com
Note: The Forum on Educational Accountability
includes some of the organizations that have signed the Joint
Organizational Statement on No Child Left Behind. Signers agree to
the goals of the Joint Statement and seek to implement its
recommendations. Additional statements by FEA reflect this commitment,
but may not reflect all individual positions taken by signatories.
