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Deadline in 4 Weeks: A Letter to Educators (Part II)
Last week, I published a piece calling educators to action about a Notice of Proposed Rulemaking (NPRM) working its way through the US Department of Education: Deadline in 5 Weeks: A Letter to Educators. The post received a personal record-breaking 8,635 hits last week – and for that I thank you for sharing! However, out of all those people, only 126 even looked at theregulations.gov site to possibly post a comment – that’s only 1%.
We can do better.
Now, the number of comments on the NPRM have gone up from 71 to 272. Out of 272 comments, 5 are in favor of the proposed changes. That’s almost 3%. The rest, a full 97%, are AGAINST the NPRM. That’s good, but we need so many more than that. We need thousands of comments, not hundreds, to even make a dent.
I urge you to post a comment, and soon.
But if you cannot, and I am sure that with so many of you back in session this week your time is extremely limited, I am planning to write up a comment that will also take the form of a petition so that others can sign on in agreement against the proposed rule changes.
Please post a comment to the US Department of Education HERE; share the information with as many as possible through facebook, newsletters, newspapers, etc (you all have my permission to use last week’s post however you see fit, but please give credit), and pass the word along to as many as you can – and in as many states as you can – about my upcoming comment. We only have 4 weeks to do this.. so let’s do it!
Deadline in 5 weeks: A Letter to Educators
Dear Educators,
In just five weeks time, a deadline concerning teacher preparation programs – on a national scale – will pass… will you have educated yourself on the issue and made your opinion known? Recently,the ED “announced” new guidelines that many were not happy with; I put quotes aroundannounced because it was actually announced years before in the Federal Register, but many educators missed it… years later, just days before the new guidelines are effective, many teachers and parents are left wondering how they could have missed it, if there is there anything that can be done in these final days, and how can they make their opposition known.
Sadly, the boat may have sailed for those rule changes. However, there is a new boat on the horizon that you shouldn’t miss…
Don’t let the implementation dates in 2017-2019 fool you, this is a normal implementation timeline – and you don’t want to be left scratching your head in a couple years wondering where the new legislation came from. If you have an opinion, let it be known now – while there is still time to make alterations.. or scrap the rule changes all together.
I read through most of the 200-page proposal. It gave me a headache. To save you that, I have outlined the changes below – this outline is obviously not exhaustive, but it highlights the main issues others have had after reading such a long-winded draft. And there is opposition – mostly opposition – almost complete opposition. Of the 71 public comments available so far, only one – ONE – was positive.
To give you some warning, this is what some people are saying about this proposed legislation:
“[It] is at best unworkable.”
“[It is] likely to produce dire unintended consequences for public schools”
“This proposal uses flawed tools and will do great damage”
“the proposed new regulations … would be an unmitigated disaster.”
“These regulations are both dangerous and irresponsible.”
“Some of this is benign, some of it is deceptive, and some of it is rank foolishness.”
“I find the proposal … horrendous.”
“[It] is at best unworkable.”
“[It is] likely to produce dire unintended consequences for public schools”
“This proposal uses flawed tools and will do great damage”
“the proposed new regulations … would be an unmitigated disaster.”
“These regulations are both dangerous and irresponsible.”
“Some of this is benign, some of it is deceptive, and some of it is rank foolishness.”
“I find the proposal … horrendous.”
The Notice of Proposed Rulemaking (NPRM) re: Teacher Preparation Issues…
To paraphrase the summary for this rule change, Duncan proposes:
(1) that annual State report cards provide more meaningful data on the performance of each teacher preparation program in the State, and
(2) to amend the regulations governing the TEACH Grant Program to consider teacher preparation program quality when determining a program’s eligibility to participate in the TEACH Grant Program and to update, clarify, and improve the current regulations
To paraphrase the summary for this rule change, Duncan proposes:
(1) that annual State report cards provide more meaningful data on the performance of each teacher preparation program in the State, and
(2) to amend the regulations governing the TEACH Grant Program to consider teacher preparation program quality when determining a program’s eligibility to participate in the TEACH Grant Program and to update, clarify, and improve the current regulations
The reason behind these changes is that the Federal Government feels that “[current] State and IHE reporting requirements have not produced information that is sufficiently helpful to programs, the public, or the Secretary in improving low-performing teacher preparation.” As such, “Rather than focusing on outcome measures of program quality, the title II reporting system currently relies on States to establish their own indicators of program effectiveness”.
The ED states that the goal of this proposed legislation would provide “access to more meaningful indicators of teacher preparation program performance.” By establishing these changes, the ED would be “Creating a feedback loop between school districts and higher education [that] will not only facilitate program improvement, but will also provide information that can be used, for example, by potential employers to guide their hiring decisions and by prospective teachers to guide their application decisions.”
It all kind of sounds like unicorns and rainbows, right? I mean, more access to how a teacher prep program is doing sounds like an excellent idea to students that are deciding where to go to grad school, to employers hiring new graduates, and to the public as a whole for providing a means to make sure their public institutions of higher education (IHEs) are doing a good job preparing teachers to educate their children.
But how does the Federal Government measure program performance? How do they define these “meaningful indicators”? Therein lies the ruse. First, the Federal Government, and not the States, will be supplying these definitions. Second, to provide consistency, these definitions are aligned with Departmental initiatives such as Race to the Top. And third, and possibly the biggest thorn of all, these indicators would link test scores of K-12 students to the institutions that trained the teacher – and allow the use VAM to do it.
The four meaningful indicators:
- Student learning outcomes: would be defined as data on the aggregate learning outcomes of students taught by new teachers trained by each teacher preparation program in the State.
This would be measured by student growth, which would be newly defined as the change
in student achievement in tested grades and subjects, as well as the change in student
achievement in non-tested grades and subjects for an individual student between two or
more points in time. The draft also states that this measurement could be a simple
comparison of achievement between two points in time or a more complex “value-added
model”.
Student achievement would be determined using
(a) a student’s score on the State’s assessments, and,
(b) as appropriate, other measures of student learning described in the definition of
“student achievement in non-tested grades and subjects” that are rigorous and
comparable across schools and consistent with State requirements.
For non-tested grades and subjects, achievement would be determined by measures of
student learning and performance, such as students’ results on pre-tests and end-of-
course-tests, objective performance-based assessments, student learning objectives,
student performance on English language proficiency assessments, and other measures
of student achievement, that are rigorous and comparable across schools and consistent
with State requirements. - Employment outcomes: defined to include the teacher placement rate, the teacher placement rate calculated for high-need schools, the teacher retention rate, and the teacher retention rate calculated for high-need schools.
In addition, a State could, at its discretion, assess traditional and alternative route teacher
preparation programs differently based on whether there are differences in the programs
that affect employment outcomes, provided that varied assessments result in equivalent
levels of accountability and reporting. - Survey outcomes: is defined as qualitative and quantitative data collected through survey instruments, including, but not limited to, a teacher survey and an employer survey, designed to capture perceptions of whether new teachers who are employed as teachers in their first year of teaching in the State where the teacher preparation program is located have the skills needed to succeed in the classroom.
- Accreditation or State Approval To Provide Teacher Candidates With Content and Pedagogical Knowledge and Quality Clinical Preparation and as Having Rigorous Teacher Candidate Entry and Exit Qualifications: this would be a determination of whether:
(a) the teacher preparation program is accredited by a specialized accrediting agency recognized by the Secretary for accreditation of professional teacher education programs or, alternatively,
(b) that the program:
1. Produces teacher candidates with content and pedagogical knowledge;
2. Produces teacher candidates with quality clinical preparation; and
3. Produces teacher candidates who have met rigorous teacher candidate entry and exitqualifications.
Now, if you didn’t quite catch the main drift of this proposal from the language above, don’t worry… they hid all that (and more) in 200 pages of legal gibberish, so even I didn’t catch on at first. But after a few hours of ripping it apart piece by piece, a couple themes became apparent to me: through this proposed legislation, the ED is crafting, and possibly controlling, teacher prep programs to their liking by explicitly defining the methods States must use to assess programs and then specifying the consequences for the “State-determined” label attached to each program (exceptional, effective, at risk, or low-performing); it is also embedding Race to the Top language into law – making it much harder to revise – even though RTTT is not law in itself, but an optional contest laid out in the ARRA of 2009 (which is Federal law); and finally, the ED is solidifying standardized testing as high-stakes for yet another group: IHEs – rating teacher prep programs almost entirely by the grades of a teacher’s students on standardized tests.
I will come out and say that I believe teacher prep programs need to be part of the move to realign our education system, and even that some of the ideas in this proposal aren’t bad at all.. but, as a whole, this is absolutely not the way to do it. The proposal should be majorly revised, or possibly scrapped, if the ED cannot dissect the draft appropriately. If you agree – or, even better, if your group or organization agrees – you can comment on the proposed regulations HERE. Don’t be sorry you never did…
And I will leave you with my favorite comment excerpt yet:
“So here’s my modest proposal: Arne Duncan has been secretary of education for six years, and in that role he is ultimately responsible for the educational progress of all U.S. students. According to the most recent PISA results, U.S. students’ scores haven’t improved on Duncan’s watch. Therefore, by Duncan’s own logic, I propose that we deprive his alma mater — Harvard University — of some federal funding for its current students because Duncan’s failure to improve U.S. PISA scores demonstrates that Harvard (which educated Duncan) is responsible for U.S. students’ flat scores on the PISA exam. If Duncan and Harvard don’t like the logic of my modest proposal, then Duncan should withdraw his proposed scheme for rating teacher preparation programs based on the educational outcomes of their alumni’s students, as my logic simply tracks his own.”
— Sarah Blaine, parentingthecore blog
“So here’s my modest proposal: Arne Duncan has been secretary of education for six years, and in that role he is ultimately responsible for the educational progress of all U.S. students. According to the most recent PISA results, U.S. students’ scores haven’t improved on Duncan’s watch. Therefore, by Duncan’s own logic, I propose that we deprive his alma mater — Harvard University — of some federal funding for its current students because Duncan’s failure to improve U.S. PISA scores demonstrates that Harvard (which educated Duncan) is responsible for U.S. students’ flat scores on the PISA exam. If Duncan and Harvard don’t like the logic of my modest proposal, then Duncan should withdraw his proposed scheme for rating teacher preparation programs based on the educational outcomes of their alumni’s students, as my logic simply tracks his own.”
— Sarah Blaine, parentingthecore blog
Susan Schneider
On The Education Enterprise
http://susanschneiderblog.com/