The U.S. Department of Education wants input to its rules to implement the Every Student Succeed Act. State Education Commissioner Pam Stewart wrote them a letter, a long one. In it she lists her concerns. Her first concern had a familiar ring; under the proposed timeline, it would not be possible to implement the new rules by the beginning of the 2017-18 year. One has to smile, Ms. Stewart is right. She has learned from experience when district superintendents voiced similar complaints about the timeline for implementing the Florida Student Assessment accountability measures two years ago. Stewart’s other concerns are more problematic.
I list them below.
- Number of students tested. Stewart asks that federal penalties for states that fail to test 95% of their students be removed.
- Personally identifiable data. Federal law protects privacy of individuals in data reporting, but there is no way to protect the individual school principals’ privacy.
- Differentiating levels of achievement among groups of students within schools. Federal rules would require that school grades reflect three distinct levels of achievement. Florida has just moved to report achievement by percentages of students achieving proficiency.
- Lowest performing schools. Currently, Florida identifies the lowest performing schools taken as a whole. The federal rule would require identification of the 5% lowest performing schools at the elementary, middle, and high school levels. Stewart balks at requirements to identify and target consistently low performing groups within individual schools rather than allow the state to identify targeted groups and schools.
- Target support and improvement plans. Low performing schools that do not improve within three years may be identified for ‘comprehensive support and improvement.’ Districts would have to report schools with disproportionate numbers of ineffective, out of field, or inexperienced teachers assigned to these schools. (While there are some reports that hiring skilled, experienced teachers can be a problem, it is clear from accountability data that this is of particular concern in charter schools. Stewart also contests a provision that the state conduct a ‘root cause analysis’ of why schools employ these teachers.)
- Comparisons of charter and traditional school performance. Federal rules require state report cards to include these comparisons, but Stewart states the comparison are not valid. Charters, Stewart claims (rightly) enroll a unique set of students. (Florida reported such comparative data in the past, and it was clear that charters do not serve the same population of students as do traditional public schools. This issue is now being framed as a civil rights issue. Additional civil rights reporting requirements are also contested.)
- Per student funding. The new rule would revise FTE calculations to be based on actual student membership. Under current formulas, part time student data are combined together to determine the full time equivalent number of students. The implications are that the new requirement would produce two separate and potentially confusing systems.
The new federal guidelines appear to focus on the need to better identify struggling students within schools who may be relatively invisible simply because the school grade is not low. In other words, schools that enroll fewer children from low socio economic families may appear to be high performing schools because most students do well. Yet, the incentive and/or the resources to provide extra services to at risk students in these schools may be less than at schools with higher concentrations of at risk children. Once again, it all comes down to funding. Pam Stewart argues that Florida’s reporting system is fine the way it is. It comes down to the best way to increase public awareness of children’s needs. How much do we want to know? What a harsh question. No easy answers.