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PEBC’s response to proposed ESSA Regulations

The United States Department of Education (USDOE) recently proposed regulations on accountability, consolidated state plans, and data reporting under the Every Student Succeeds Act (ESSA). The proposed regulations were published in the Federal Register on Tuesday, May 31. These proposed rules are subject to a 60-day public comment period, with comments due by August 1, 2016. Comments submitted during this period are read and influence change.

Sue Sava, PEBC’s Director of Policy, submitted the comment below on behalf of PEBC.

I applaud ED for including the “non-cognitive indicator” and a more holistic emphasis on measures of student achievement in ESSA. The emphasis on the importance of recruitment, educator preparation and continuing high-quality professional learning experiences for all educators is critical as well.

It seems a contradiction to eliminate HQT (Highly Qualified Teachers) designation and yet require states to publish numbers of inexperienced, out of field and emergency cert teachers on report cards. What kind of system are we creating that eliminates requirements for encouraging a professional workforce and yet expects LEAs (Local Education Agency) and states to find and hire these teachers? And publicly report it when they can’t? HQT was a safeguard for the education profession that ensured, at the very least, that most candidates who sought licensure and development were serious about embarking on a professional career path. In the face of our teacher shortage, the education profession places itself further at risk by eliminating HQT. We hope that you will consider the unintended consequences of this move. Our students need and deserve highly trained and supported educators and we can predict which groups will suffer the most from this change. Thank you for engaging with us around this aspect of the proposed regulations.

I hope that states will act judiciously when re-designing “grades/ratings” for schools. Using an asset-based approach, why don’t we begin our analysis by reflecting on what is working in a school? Wouldn’t we rally more people to the cause if we drew attention to the strengths of our children and their teachers? Wouldn’t parents be excited to participate in an endeavor that is about capacity-building instead of demoralization? Wouldn’t teachers be excited to be a part of such a positive and hopeful movement?

I’d like to assume that as states begin to design their plans, they will reflect carefully on the “lowest 5% of schools.” We have an opportunity in this country, at this moment, to reframe this conversation. Instead of implementing tools left behind by NCLB, let’s re-envision an “all hands on deck” approach for our lowest-performing schools. Let’s respond to this problem with a solution that all educators have been trained to enact: observe carefully, diagnose, intervene, support, assess, plan, tweak and try again.

Let’s add an ingredient to this recipe: let’s engage our communities and invite other sectors including mental health, transportation, nutrition, and other business entities to assist in the “intervention” part of the equation. When our children attend our lowest-performing schools, it is because we have all failed them. It is our collective responsibility to uplift them. Let’s hope that ESSA delivers on the opportunities to collaborate that are implied through block grants. It is time to focus on the child and what she needs in order to grow and to move away from labeling her “an Unsat.” What has been “unsatisfactory” is how we have labeled children, dedicated teachers, and their struggling schools. Let’s ensure that all children have access to the types of educational experiences that each of us would want for our very own children. ESSA may help us to collectively create these opportunities, if states embrace the flexibility inherent to the law and encourage diverse stakeholders to the table to assist in solving the problem.

To see PEBC’s comment or add your comment, go here.

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