Public Comment on ESSA: We Need a REAL Accountability Overhaul

“Don’t cling to a mistake just because you spent a lot of time making it.”   -Unknown

In December 2015, Congress passed the Every Student Succeeds Act (ESSA), replacing No Child Left Behind, which had been in place since 2002.  The ESSA purports to allow states greater flexibility for the design of their education accountability system, which is great news for us because we have been calling for a complete overhaul of Florida’s accountabaloney system since day 1 of this blog! We hope Florida can rise to the occasion and take full advantage of this opportunity to address our deeply flawed accountability system.

Some states appear to be rising to the challenge. Kentucky Commissioner of Education Stephen Pruitt advises a system that focuses on students:

“If we don’t come out with an accountability system focused on students, then we’ve failed. It can’t be about adults chasing points. The system needs to promote what’s best for students.” -Kentucky Commissioner of Education Stephen Pruitt 4/17/16

If Florida isn’t careful, Kentucky may become the leader in education accountability! They certainly appear to be headed in the right direction (which is away from the adults chasing points to ratify the A-F school grade system). Good for Kentucky!

Floridians are waking up to the realities of the system. Florida’s students are not well served by a high stakes test focused system, as recently explained by the Sun Sentinel Editorial Board:

“A major part of the problem, as we have written before, has been the use of the high-stakes tests for purposes to which they are unsuited. Those include school grades and teacher evaluations. Legislatures and governors with a stick-it-to-public-education attitude have hurt teacher morale, recruitment and retention, exacerbating the situation…

The “reformers” have now become the entrenched special interests. They want more of the same. Floridians should want better.”

These are all wise words and Florida’s Department of Education and legislature should heed them.  On June, 21, 2016, one day after it was promised, the FLDOE opened a website for public comment on changes to the Education Accountability system and ESSA. We invite all Florida citizens to comment on Florida’s current accountabaloney system and demand change. Sadly, if you are going to do so using the new website, you might need a law degree. It is just that convoluted. There are nine individual surveys and each one asks you to comment on specific portions of the ESSA legislation or draft regulations. Even the Florida Association of School Superintendents (FADSS) complained at today’s State Board of Education meeting, asking for a more authentic voice than an online opportunity. (You can watch here around 1:48:00). They demanded that stakeholders have a real voice in the process.

A real voice in the process will be difficult given the convoluted website. Here is what I did: I wrote up a list of my demands, copied it and pasted it into every comment box on each of the one surveys. I asked the FLDOE to determine which part of my demands corresponded to the confusing question they were asking. You might want to try a similar plan (you can copy my list if it suits you), but please let your voice be heard.

What should you ask for?

First, remind the FLDOE of “the original intent of ESEA, which was to facilitate equitable, thriving, and successful public education for all schools via distribution of funding free of strings attached other than need and a comprehensive and viable game plan for success.”

Demand a complete accountability overhaul: eliminate high stakes attached to state testing, minimize state standardized tests to those mandated by ESSA, return classroom assessments to teachers, utilizing primarily locally-based, teacher-controlled assessments, protect student data and make student data privacy a top priority.

• Eliminate high stakes attached to state testing. It is the stakes attached to the tests that have, more than anything else, corrupted the education system.
  • End the mandatory 3rd grade promotion requirement as well as the graduation requirement to pass the Algebra 1 EOC and 10th grade FSA-ELA . These are not required by federal law or regulations. Many states already have eliminated their test dependent graduation requirements.
  • Dramatically reduce or eliminate the weight of the state EOC exams on the students final grade, from 30% to 10% or less.
  • Stop the use of VAM and test scores to evaluate teachers. ESSA eliminated any federal mandate for test-based teacher evaluation.
  • Test scores should make up no more than 51% of the total points in the A-F School Grade formula  (the minimum percentage allowed under ESSA).
  • Ensure that School Grades are used to identify schools in need of assistance (including additional funding) and not to punish schools identified as “low performers.” ESSA does require states to rank all schools and act to improve the lowest performing, but it no longer specifies the types of interventions required.

• There should be no state standardized tests beyond those mandated by ESSA (reading and math in grades 3-8 and once in high school, science once in elementary, middle and high school). 
  • Minimize required state standardized tests to those mandated by ESSA. In Florida the Biology EOC and Algebra 1 EOC, along with the 10th grade FSA ELA could satisfy the high school requirements. The 9th grade FSA-ELA and all other state mandated EOCs could be eliminated.
  • The state should advocate for pilot programs allowing grade span testing or sampling in place of current ESSA mandates.
  • State should forbid standardized local interim, benchmark, predictive, formative, or other such tests, including those embedded in commercial on-line curricula. Eliminate all test data reporting requirements beyond the ESSA mandated assessments.
  • Institute a ban on standardized testing in pre-K through grade 3.
  • End the secrecy around state mandated assessments. Allow educators and parents to view and review state assessments.
• Return classroom assessments to teachers, utilizing primarily locally-based, teacher-controlled assessments, such as projects and portfolios. The New York Performance Standards Consortium has demonstrated better outcomes with fewer standardized test, and should serve as a guide.

• Protect student data and make student data privacy a top priority.
  • Eliminate digital classroom mandates, allowing districts to incorporate technology as a tool rather than a curriculum replacement.
  • Allow parents the option to safeguard their child’s data by allowing families to opt out of digital instruction.
  • The computer based, state mandated Civics exams allows the possibility of collection and sharing of sensitive data of a political nature.  In order to ensure the safety of such sensitive information, this exam, especially, should be paper based.

We encourage everyone to comment on the Commissioner’s site. Send copies of your comments to your state representatives, as well. It is time to overhaul this disaster. It is time to stop clinging to this mistake.

---

P.S. We are under no illusion that Florida will actually use this opportunity to eliminate mandatory 3rd grade retention, test based graduation requirements or the rank and punishment of schools based almost solely on student test scores, restoring teacher autonomy in the classrooms and local control to  our elected school boards. In fact, we are pretty sure the passage of ESSA was designed to open the flood gates towards further privatization of public schools and the profit generating, data sharing Competency Based Education (CBE). CBE is meant to convert public schools into data mining computer centers, where teachers are mere facilitators and massive profits are made for investors.

We agree with Peggy Robertson, that ESSA is not an opportunity to save public schools but rather the law that will hasten its demise.  Here, she points out the irony:

“And the passage of ESSA means that the end of year test eventually could become passé.  ESSA is pushing for online, daily testing – testing that is embedded inside online curriculum.  Children will now be subjected to online modules in which they must master something before moving on to the next online module.  It might be called personalized learning, mastery learning, proficiency-based testing, competency-based education, innovative assessments, and more. ESSA is pushing for these online assessment systems, as is ALEC, and the many foundations and organizations that are hoping to cash in.

As Stephen Krashen states: Competency-based education is not just a testing program.  It is a radical and expensive innovation that replaces regular instruction with computer “modules” that students work through on their own. It is limited to what can be easily taught and tested by computer, and is being pushed by computer and publishing companies that will make substantial profits from it. “

Why do I get the overwhelming sense that Florida’s accountability plan will lead us further down the path of the profiteers and CBE? Because this is Jeb’s mistake and they will cling to it until we vote the reformers out of office.

CBE has already infiltrated our schools. Nearly every one of Florida’s public school children have already used CBE programs (like iReady, iStation and Achieve 3000) and some districts are moving towards complete conversion to CBE within the next 5 years via a recently approved pilot study. Notice how “the Jeb Bush-founded Foundation for Florida’s Future — which lobbied for the program — praised the Legislature for approving” the CBE Pilot Study bill.

What can we do to save our public schools? We must educate other parents, school boards and communities about the inherent dangers in ESSA and CBE (share this video demonstrating the $270 million “pretendathon” happening in Baltimore, don’t let this happen to your district!).  It is time to refuse online curriculum and other online programs that are being used to cash in on our starving public schools and our children. And, by all means, VOTE THE REFORMERS OUT.