Sunday, January 3, 2016

An Open Letter to Commissioner Elia re: Receivership

Dear Commissioner Elia:

I begin this letter with greetings for a healthy and prosperous New Year.  Traditionally, the New Year is significant in that most of us take the time, during this symbolic period, to reflect on past experiences and contemplate potential opportunities.  In the spirit of the New Year, I am writing this letter to request that as the State’s highest educational official you take the opportunity, in this new year, to address an issue that to this point you have ignored and seemingly dismissed as inconsequential.  Please note that I am not acting in my capacity as a sitting member of the Buffalo Board of Education but per my individual responsibility as a grandparent and educational stakeholder. 
Last month, the Governor’s Common Core Task Force, of which you were a member, released its final report and recommendations for addressing the flawed implementation of the CCSS.  As the Task Force Chair put it, “numerous mistakes were made” in the process related to the roll out of the standards, aligned curriculum and assessments.  Richard Parsons noted that a core element of the Task Force’s work was predicated on the Governor’s charge that this effort “engage parents, teachers, students, and others to hear from them what is, and is not, working.”  Further, the Chair stressed that throughout the work of the Task Force, its goals were to conduct a comprehensive review and analysis of the CCSS; seek input from diverse stakeholders; and implement recommendations “in an open and transparent manner”. Accordingly, the final report details the “exhaustive outreach” and review of “the Common Core Standards, curriculum, and tests to untangle the problems and develop a series of recommendations.”  

It’s also noteworthy that soon after the release of the Report the Board of Regents voted to accept the recommendations. Of course, as SED Commissioner and Task Force member you already have an intimate knowledge of a report you helped shape. So, I’ll get to the heart of the matter and the reason for this letter.  The Task Force report has a number of failings that have been pointed out by others.  However, I am especially interested in the interpretation of and the implementation of the recommendations regarding high stakes tests.

The Task Force’s final report contains 21 recommendations.  A number of these are specific to the standardized tests that have been used to determine student achievement and school and school district accountability.  In all, 12 of these recommendations focus on issues with these assessments, such as the “one size fits all” practice of subjecting all students, regardless of cognitive or English language ability, to the same tests; the lack of transparency and stakeholder involvement in the development of these tests; the problem of teaching to the test leading to an over-emphasis on test-prep; lack of parent and student engagement and feedback re these tests; the inordinate amount of time devoted to standardized testing. 

The final recommendation, Number 21, however speaks most forcefully to the question of the validity of the Common Core aligned tests and the Task Force’s determination that a “moratorium” should be placed on their use.  This recommendation states: “Until the new system is fully phased in, the results from assessments aligned to the current Common Core Standards, as well as the updated standards, shall only be advisory and not be used to evaluate the performance of individual teachers or students.” 

As a result of this Recommendation, as well as the others, many stakeholders have questions about how the Task Force’s conclusions impact the schools that are now in Receivership status.  These schools are predominantly in urban districts attended by disproportionate numbers of students in the groups referenced in the Task Force recommendations.  Beyond test scores, factors that compound the designation of “persistently struggling” and “struggling” schools are inherent in the composition of their student population, e.g. high poverty, students with disabilities and students who are English Language Learners.  Buffalo has 25 schools designated as “persistently struggling” or “struggling”.  The latter were designated as a result of being identified since 2012-13 as Priority Schools.  Coincidentally, this was the first year of the Common Core aligned ELA and Math tests.   

To provide perspective as to why the demographics of the receivership schools are relevant, the following statistics describe the percentage of each population group in Buffalo’s five “persistently struggling” schools, euphemistically dubbed the “high 5” by our Superintendent Receiver.   

% of Students with Disabilities – 11.9%, 20.9%, 17.5%, 25% and .5%
% of English Language Learners - 40.5%, 14%, 31.6%, 7.4% and 7.2%

Compared to District wide demographics for these indicators, in a total enrollment of 34,000 students, 20% are Students with Disabilities and 14% are English Language Learners.  Clearly, the State has data on sub-group performance on the standardized state tests to inform review, analysis and decisions regarding the impact of these tests on student and school accountability in the Receivership schools.  In fact, under Receivership  a number of the required criteria by which “demonstrable improvement” will be identified or confirmed are dependent on various indicators based on the standardized tests; e.g. student achievement on ELA/Math exams for specific sub groups.  How will that work, given the “moratorium”? 

Not unlike the task given to the Common Core Task Force there needs to an open, transparent and inclusive study, review and analysis of the use of high stakes Common Core aligned assessments and Receivership.   And yes, I do understand there is the matter of the Education Transformation Act of 2015.  This law has given you the authority to impose receivership.  However, given the haste with which policy and procedure has been developed  that authority also comes with the opportunity for State Ed to implement another flawed, poorly devised program that hurts rather than helps children.

A December 30th Buffalo News article summarized the concerns outlined in the foregoing in this statement; “those same tests, however, were a major factor in determining which schools were placed in receivership.”  The article also noted, however that the Commissioner has been “dismissive” of this issue.  Commissioner, I am asking that you not dismiss this question as a non-issue. Your retort that the Federal government still requires the state to assess students annually does not answer the question of the use of invalid assessments as the basis of major decisions impacting students currently.  

It is imperative to clarify the “confusing” and contradictory message sent by the Common Core Task force and confirmed by the Board of Regents regarding the impact of high stakes tests results on students (individually and collectively).  At this time it appears that urban students and schools will still be held accountable as a result of these assessments, while other students will be held “harmless”.    This disparate treatment is unacceptable and certainly a concern I think the Department would want to dispel.

I look forward to hearing from you.

Yours truly,

Barbara A. Seals Nevergold

Barbara A. Seals Nevergold, PhD

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