Archive for Federal Policy

Federal policy is the floor not the ceiling

We often talk about states complying with federal requirements, yet it is important to remember that federal policies and procedures represent the floor and not the ceiling. ESSA requires states to do a number of things related to how schools are identified for support, what their accountability metrics must include, how states communicate progress on those accountability measures, and how funds are used (amongst other things). But, states can go above and beyond those requirements. I highlighted this concept last week at CCSSO’s Implementing Systems for Continuous Improvement meeting in Tampa, Florida. Schools and districts identified for CSI supports must complete needs assessments, but schools and districts identified for TSI supports don’t have to complete needs assessments. Some State Education Agencies have realized the importance of needs assessments are are also requiring schools identified for TSI supports to also complete a needs assessment to ensure that their plan for improvement aligns with their actual needs.

A recent rollback of federal lunch standards is another example of this concept. Just because the federal government is allowing more flexibility to districts to slow down their decreased sodium content or relax the whole grain requirements, it does not mean districts must do so. Districts were already working under the previous guidelines, so why should we backtrack to less healthy food again? Schools and districts have the ability to go above and beyond the federal guidelines to ensure school meals are as healthy as possible for their students. (And yes, healthy food can taste good, and kids can learn to like veggies, whole grains, and salads!)

States, districts, and schools have the responsibility to make decisions that are in the best interest of the students they serve. Sometimes the federal government’s standards ensure that happens, but other times the adults at the local level must step in and set their own floors, which may be higher than the feds.

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The Illusive 5th or “Other” Indicator

Under ESSA, states are required to have a 5th school quality or student success indicator. While many rejoiced in this requirement initially, it quickly became a challenge to figure out what type of indicators meet the proposed federal regulations, what type of indicator actually demonstrates school quality or success, and what data states already collect that could be used. One of the most challenging requirements is that the indicator must be able to be disaggregated by subgroups of students – so while teacher effectiveness might be a useful indicator, it would be difficult to disaggregate a teacher’s effectiveness by subgroup for middle or high schools – since students attend many different classrooms with different teachers each day. Such an indicator could be used for elementary school grades, since students often stay with one teacher for most of the day. The proposed regulations do allow different indicators to be selected for different grade levels – as long as it’s consistent across the state. The other major issue that states are running into is what data do they already have? And, is that data reliable and indicative of school quality or student success? Many districts collect additional data, but the same data may not be collected in the same way across the state.

This recent EdWeek article explains some of these issues, while also providing some initial thinking from a few states as they think through the implications of this 5th or “other” indicator. An important note is that states must use at least one “other” indicator, but they may use more than one as well. From what I’ve heard from states, many are leaning towards including chronic absenteeism, college or career readiness, and other school climate indicators as their “other” indicators. While states think through this new data source, it’s also uncertain if the Department of Education will make any modifications to the proposed rules/regulations. The final rules should be released in late August or September.

This 5th or “other” provides states an amazing opportunity to redefine what a successful school is, but the implementation requirements may make it difficult to actually implement the intention in the timeframe states have to do so.

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Too early to determine success or failure

USED recently released some data on year 1 SIG school performance. The release has re-initiated the turnaround firestorm. While some of the discussion is useful, many bloggers/ed leaders are jumping to conclusions far too quickly. To see some of the blogs/comments: see here, here or here.

Many of us who work in the school turnaround environment could have predicted the year 1 results USED released, some schools improved, some got worse. Unfortunately, that is to be expected in the first year of a turnaround effort. When modifying an existing system (with either tinkering or dramatic change), one still must fight against the status quo. There is no perfect model for a school turnaround and course corrections must be made along the way. As a result, the first programs and practices implemented might not have been the most effective and will be removed or adapted throughout the three-year implementation period.

Honestly, I’m surprised that so many schools were able to achieve double-digit gains in year 1. Year 1 schools often focus on culture and climate. While some academic improvements are likely, the real academic growth won’t come until instruction is the focus, in years 2 and 3. Just looking at year 1’s assessment data should not imply success or failure of a turnaround. We must also look at culture and climate indicators (i.e. student, teacher and parent satisfaction surveys, student AND teacher attendance, in/out of school suspensions, etc), in addition to student academic performance. If we’re evaluating turnaround efforts on assessment data for year 1, we are setting those schools up for continued failure. The schools (teachers and leaders) must know that they have the public’s support to implement a multi-year plan to make real and lasting changes. To say that a turnaround has failed so quickly implies that all of the improvements that were made were not effective, and in most cases this is simply not true, they just have a long way to go.

The other major piece that’s missing in much of this discussion (i.e. all the blogs and the early research) is what changes are actually taking place in these schools? How does the achievement (and behavioral) data compare when you look at turnarounds vs transformation vs restarts? How does the political will of leaders (school boards, superintendents, principals) impact the turnaround effort? If teachers were replaced, was there a sufficient (and highly effective) pool of teachers to rehire from? Were community partnerships formed to address all of the social needs turnaround schools often have? How hands-on or hands-off was the state education agency in helping schools and districts make real and lasting changes? What systems, conditions, and practices were embedded into the larger district to ensure sustainability and continued growth (post-SIG funds).

Until we look at 1) a more robust (and diverse) collection of data to get a real picture of what’s happening in a school over multiple years, and 2) the structures, supports, and implementation processes of turnarounds, it is far too early to draw definitive conclusions in support of or against the revised federal SIG program, and why it is or is not working. Until then, we must support the incredibly hard work that is being done in these schools, continue to work towards equitable educational opportunities for all students, and wait for additional research.

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Analysis of GAO’s SIG report (part 3)

… and finally part 3. Click here for parts 1 and 2.

One of the most important recommendations in the GAO report (at least in my opinion) is that states should do a better job evaluating the partners, or at least requiring districts to evaluate the partners, that are helping implement the turnaround and transformation SIG models. To date, ED does not do this, and GAO found that the quality of partners varied greatly. In response to GAO’s recommendations, ED stated it does not agree with the recommendations for several reasons, including:

The Department has required that LEAs hold external partners under the restart model accountable for meeting the SIG requirements because they are engaged in whole-school reform and have considerable flexibility with respect to the school improvement activities they will undertake. External providers supporting the implementation of a turnaround or transformation model may require less provider-specific monitoring, as they generally work on specific, discrete activities to improve student academic achievement (GAO-23-383, pg 36).

While I respect and support many of ED’s SIG policies, such an answer allows partners (who are earning millions of dollars per school over the course of three years) to work without accountability for their actions (or inactions).

While it is true that restart partners do take on a significantly greater role in a restart, external partners working under the turnaround and transformation models also play a significant implementation role and their quality impacts student performance. External partners that take on a defined and specific role (i.e. data analysis or principal leadership) should not be monitored or evaluated to the same extent as a Lead Turnaround Partner that assists with multiple parts of improvement.

But, all partners, irrelevant of the size of their contract or scope of work, should be monitored and their performance should be evaluated. Too many mediocre partners have been able to continually receive contracts because they always have.

If we’re (finally) cracking down on teacher and leader performance, we must do the same with every person or entity working in a school building. Some states ensure the monitoring and evaluation of all partners, especially those acting in a Lead Turnaround Partner role, but a statement from ED requiring, or at least encouraging, such steps would be useful and would benefit the school improvement field as a whole.

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Analysis of GAO’s SIG report (part 2)

To continue the analysis of a recent GAO report…. See Part 1 here.

Dance of the lemons

Schools implementing the federal turnaround model must replace 50% of teachers, and the transformation model requires replacement of the principal (with a few exceptions), yet how those staff members are removed and replaced is not always done in the best interest of students.

While some teachers or principals in a low-performing school may simply need a new environment, many need significant professional development to improve their instructional and leadership abilities, and a few may need to change careers. The GAO report cites how these requirements are implemented all too frequently, “However, the district officials said they relocated the released teachers to the other SIG schools in their district because those schools had almost all of the vacancies. Similarly, in two states we visited, district officials moved a school’s previous principal into another leadership position on site so that the person could continue to work in the school even after a new principal was assigned.” (Pages 9-10)

Some of these moved teachers may succeed in simply a new environment, but reassigning low-performing teachers, who’ve been teaching in a chronically low-performing school, to another chronically low-performing school will not likely produce the desired student achievement results. Similarly, keeping a low-performing principal in a leadership position undermines the authority of a new principal coming into the building who is trying to make changes.

Districts must put their best teachers and best leaders in their (traditionally) “worst” schools. District leaders must develop the political will and the commitment to put student needs ahead of adults (i.e. acting as an employment agency) and school boards and state education agencies must back up these decisions.

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Conflict of interest vs. quality

The U.S. Department of Education, as well as many State Education Agencies, utilize the peer review process to identify winning applicants to most (if not all) competitive grant funds. In theory, peer reviewers and experts from the field evaluating proposals and grading them against rubrics makes complete sense. In practice, sometimes we’re so concerned about avoiding conflicts of interest that the quality of the reviews suffers.

For example, an upcoming peer review process will include at least a dozen separate competitions, all likely receiving numerous applications from organizations, universities, and partnerships across the country. ED recently contacted me to see if I would like to apply as a peer reviewer for the upcoming review process. I disclosed that while I am interested, I am likely assisting an organization with their application to one of the competitions. In effect, it is likely that I am no longer eligible to act as a peer reviewer for any of the competitions.

I completely understand and agree that a peer reviewer should not be able to review applications in any competition that they have a clear interest in (i.e. I wouldn’t be able to judge any of the applications for same competition I helped write a response for), but what about the other competitions? Based on the scale of this upcoming process, I don’t understand how ED will find enough peer reviewers, with 1) appropriate knowledge in the topic areas, and 2) who have no conflicts of interests to any of the organizations submitting applications to the dozen or so separate competitions.

While eliminating patronage and corruption is critical, ensuring that peer reviewers understand the topic area of the competition, and that applications are judged based on QUALITY, and not how well they can write a response to an RFP, is equally important. There has to be a middle ground.

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Don’t reset the clock

Despite all of the controversy and disdain surrounding No Child Left Behind, that version of the Elementary and Secondary Education Act (ESEA) made some very important and positive changes to public policy. First, we actually started to look at how our students perform – and where disparities exist (i.e. the disaggregation of data). Second, we formally committed to the idea that every child should attend a semi-decent school. How either of these important features translated into action varied by state. Some states took the data and made significant changes to their state education systems to decrease the achievement gaps and the number of low-performing schools. In contrast, other states kept doing more of the same and ignored the federal mandates, found a way to work around making any substantial changes, or did just enough to meet the minimum requirements. (For more “Getting Nostalgic About The Law Formally Known as NCLB, see DFER’s blog.)

It is clear that many aspects of NCLB need (and have needed for some time) significant changes and refinement, but as discussion of the NCLB waivers and ESEA reauthorization permeates eduwonk discourse, I fear that the accountability clock is going to be reset. Schools which have failed to educate their students for years (based on any and all types of data analysis, including AYP, safe harbor, dropout rates, etc) are finally hitting the end of the current accountability system and are being forced to make substantial reforms.

I fear that if we completely overhaul the accountability system (formulas for calculating improvement, AMOs, AYP, etc) that schools who have failed their students for 10 years (or more) will start back at year 1 and will argue that they need the chance to improve on their own, without increasing levels of state or federal support (aka interference).

The revised ESEA and any approved NCLB waivers must include a conversion strategy for schools currently identified as in improvement, corrective action, or restructuring and where they fall on any new state or federally-defined accountability system. Without such measures, we will reset the accountability clock and additional generations of students will continue to attend schools which don’t educate them.

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