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By Holly Eaton, Director of Professional Development and Advocacy

May 7, 2009

We appreciate the enormous undertaking by the author and staff in drafting this bill.  We are well aware of the massive amount of input they’ve received on a bill that so broadly affects almost every aspect of education, and we appreciate being part of that process.  There are some very good position changes in this bill that seek to address concerns consistently expressed in public testimony to the Select Committee on Public School Accountability regarding an accountability system that relies too heavily on one-time, snapshot student test results.  Some of these changes are the ability to base the accreditation status of districts/campuses in part on 3-year rolling averages of student performance and on student growth.

However, we are concerned that in the bill, accreditation status is still heavily reliant on student performance on high-stakes tests.   As you’re aware, the accreditation status for campuses is based on student performance on state assessments and dropout and high school graduation rates, which is the same criteria upon which campus accountability ratings are based under our current system, with the exception that, under the bill, student performance on assessments can be based on a 3-year rolling average, and student growth on assessments is also included.  We have consistently advocated for lessening the emphasis on student performance on state assessments by expanding this measure to capture a broader and more complete picture of student learning.  For example, we have suggested that accreditation status indicators include a learning environment indicator, which would be structured as an index of data already collected through PEIMS, including out of field teaching assignments, teacher turnover rates, class size waivers, organizational health surveys, and discipline support.  Research supports the use of this data in accountability systems, as many of them serve an important role as “leading indicators” of school and student success.

We are concerned about the bill’s inclusion of a higher, and as yet, undefined accountability  performance standard of college readiness.  We would suggest that language be included in the bill that requires the studies conducted by TEA to substantiate the correlation between a certain level of performance on Algebra II and English Language Arts III and college readiness, to be peer-reviewed, scientifically validated research studies based on empirical evidence.  Given the need to have adequate time to ensure the validity of these indicators, we appreciate provisions contained in the bill that delay using these indicators in the accountability system until 2013-2014.

We are extremely supportive of the bill’s elimination of the requirement that students pass the Reading/Math state assessment in grades 3, 5, and 8, and the return to promotion decisions based largely on course grades and teacher recommendations.  However, we continue to suggest that the bill apply the 10-student class size limit for accelerated instruction classes to these classes in all grade levels, instead of just in grades 3, 5, and 8. 

We continue to be concerned about provisions allowing for-profit alternative management entities.  Although we appreciate the allowance of a repurposing option in lieu of alternative management or closure, we suggest allowing for more flexibility regarding which teachers can be retained at a repurposed campus than is currently provided for in the bill.

Although we are supportive of the use of the student measure of improvement in determining accreditation status, we believe that the bill should specifically preclude the use of this measure for purposes of evaluating individual teachers, since there is currently no scientifically validated method to accurately and fairly isolate teacher effects on student performance.

We believe that a better approach to rewarding high-performing campuses than excellence exemptions is to allow accredited campuses to maintain that rating for a 3-year period.  This is a more reasoned response to the quest for excellence rather than to reward high-performing campuses by exempting them from the very laws that they operated successfully under as high-performing campuses.   Require more frequent rating only for campuses rated unaccredited (annually, which would also allow them to recover accredited status more quickly) or those which fail to make AYP for two consecutive years. 

We are greatly supportive of the bill’s new pass/fail system of accountability, with opportunities for distinction.

We are deeply concerned about provisions in the bill which make it questionable whether open-enrollment charter schools are subject to satisfactory performance on state assessments. Charter schools are public schools and should be held accountable under the same standards as all public schools.

We appreciate the inclusion of language in the bill clarifying that the Teacher Report Card will be provided to teachers at the beginning of the school year for incoming students, as this clarifies that the reports will be able to be used as a useful guide for instruction for teachers.

Finally, we appreciate the inclusion of provisions prohibiting school districts from requiring teachers to assign certain minimum grades to students regardless of the quality of the students’ work.

Again, we thank you for all your hard work and openness to suggestions on this extremely important bill, and we look forward to continuing to work with you to improve it.

Created: 05/08/09