NYSAPE & Class Size Matters ESSA Reg Comments to NYSED

August 26, 2016
 
MaryEllen Elia, Commissioner of Education
NYS Education Department
89 Washington Avenue
Albany, New York 12234
 
 
Dear Commissioner Elia,
 
New York State Allies for Public Education is a coalition of more than fifty parent and educator organizations from throughout the state.  Class Size Matters is a parent advocacy group focused on reducing class size, increasing parental engagement and strengthening student privacy.  We are submitting these recommendations as part of the public comment process for the state’s accountability system that NYSED is required by Every Student Succeeds Act (ESSA) to submit to the U.S. Department of Education.  Rather than fill out your survey with extremely constrained choices, we thought it preferable that we explain in more detail how we believe that the process of drafting the state’s plan should improve, and what we hope you will consider including in the accountability plan itself.
 
First of all, we strongly urge you to slow down the drafting of the state’s plan.  Most parents and teachers are not paying attention over the summer, and in order to fully engage their input, hearings and a more inclusive public comment process should occur over the fall and winter months before the State begins to draft its accountability plan.  The deadline for this Accountability proposal is not due until July 2017, therefore it would be best to take advantage of these months to hear from parents, educators and other stakeholder groups before drafting your proposal.  In addition, the final regulations are not expected to be issued by the US Department of Education until sometime in late October.  It is unwise to try to draft even your initial proposal until all concerned have had a chance to read and analyze these regulations.
 
Second, we believe that the state’s apparent intention to draft a system based on a particular notion of “effective schools” is excessively vague and would be impossible to objectively assess.  Factors such as “visionary instructional leaders”, “cultural responsiveness” and “engaging curricula” are all important, no doubt; but are very difficult to measure.  We are also apprehensive that other factors, including “curricula…tied to appropriate formative and summative assessments, which are aligned to State learning standards” may lead to even more testing, detracting from the learning environment.
 
Instead, we suggest you consider adopting a system based on “Opportunity to Learn” index, with evidence-based factors that have been tied to better learning conditions, are discrete and measurable, including but not limited to class size, suspension rates, teacher experience levels and attrition.  Many of these factors are already reported to NYSED for the purpose of completing the state report cards.  We attached a list that we believe should be included in such an index, and that parents in our networks consider essential to providing their children with a quality education.
 
It appears from the survey that NYSED may be contemplating adopting some sort of “Opportunity to Learn” index when they intervene in struggling schools, but it seems preferable instead to encourage schools to provide their students with the conditions for success before they slip into the struggling status.   What gets measured and reported in the state’s accountability should be those that help our children learn and thrive in the years to come.
 
Sincerely yours,
 
 
Lisa Rudley, Executive Director – NYS Allies for Public Education
Leonie Haimson, Executive Director – Class Size Matters
 
 
Cc: Board of Regents
Attachment (see below)
     
 
Opportunity to Learn Index for NYS School Accountability System – update 10/25/16
 The new federal education law called ESSA (Every Student Succeeds Act) allows states to design a new accountability system that include school quality indicators, in addition to strictly academic measures such as student test scores and graduation rates. We are urging the Board of Regents and the Commissioner to incorporate an Opportunity to Learn index in the new NYS accountability system. 

Such a system would include the following essential, measurable and evidence-based factors:
 
 
1. Programs:
 

• Whether the school offers prekindergarten (and report whether full or half-day);

 

• Whether the school offers full-day Kindergarten;

 

• Average class sizes by grade (which in turn affect student achievement, achievement gaps, school safety and discipline, student engagement, teacher attrition rates etc.);

 

• How much arts education is offered and whether this meets the state requirements;

 

• How much physical education is provided and whether this meets the state requirements;

 

• Whether the school uses and documents social-emotional supports, restorative practices or other proven positive behavior interventions;

 

• The number and percentage of students who are not receiving their mandated services, including special education services, ENL/ESL and bilingual classes;

 

• Whether there is scheduled time in the school day for recess.

 
 
 
2. Staffing
 

• The number and percent of teachers in the school who have completed a four-year teacher education program;

 

• Teacher attrition rate and average years of experience;

 

• The ratio of counselors per student and in high schools, the ratio of college advisors per student;

 

• Number of school based team/school psychologist, social worker and/ or designated full-time specialized staff per students with IEP’s;

 

• Number of qualified nurses per student;

 

• No. of full time librarians and whether there is a library;

 

• The experience level of administrators (principals, APs, and department chairs) as administrators and also as teachers;

 

• Number of teachers (special education and non-special education) and administrators who have received a full complement of training in evidence-based interventions (such as Orton-Gillingham and others) for children identified with serious reading, writing and math disabilities.

 
3. Parent involvement
 

• Whether the school has an active PTA and a School Leadership Team or School-based Management committee that includes parents, with regular trainings and meetings; as verified by the district; 

 

• Whether the school gives annual surveys to students, parents, and teachers, and considers the results for school improvement. (The survey results themselves should not be factored into the accountability system, but to inform administrators and the school-based management committee of how to improve the school environment.)

 
4. Other critical factors:
 

• Data regarding use of police in schools (if applicable);

 

• Whether the school tracks the types and number of interventions provided to students identified as at risk of dropping out;

 

• The attendance rate of students and percent of students who are chronically absent.

 

•  Student attrition, discharge, suspension and expulsion rates.