Archives for category: Accountability

This is the NEA commentary on Congressional rewriting (reauthorization) of the Elementary and Secondary Education Act (aka NCLB).

NCLB is the name that President George W. Bush gave to ESEA. The federal law is supposed to be revised every seven years. NCLB was passed by Congress in the fall of 2001 and signed into law by President Bush on January 8, 2002. It is years overdue for reauthorization.

January 12, 2015


WASHINGTON—The National Education Association, the nation’s largest union with 3 million educators, has been a staunch critic of the failed No Child Left Behind system since its implementation more than 12 years ago. The following statement can be attributed to NEA President Lily Eskelsen García:

“We are pleased the Administration is calling for the reauthorization of the Elementary and Secondary Education Act. We all know that 12 years under a broken No Child Left Behind system has failed students and schools by neglecting to close the achievement and opportunity gaps as promised. Our students, especially those most in need, should not have to wait any longer.

“We are looking forward to working with Republicans, Democrats, the civil rights community, educators and other partners in ensuring that all students have equal educational opportunity—the original focus of ESEA. Our focus is on providing equal opportunity to every child so that they may be prepared for college and career. A child’s chances for success should not depend on living in the right zip code.

“In order to do this, we must reduce the emphasis on standardized tests that have corrupted the quality of the education received by children, especially those in high poverty areas. Parents and educators know that the one-size-fits-all annual federal testing structure has not worked. We support grade span testing to free up time and resources for students, diminish ‘teaching to the test,’ expand extracurricular activities, and allow educators to focus on what is most important: instilling a love of learning in their students. We must give states and districts the flexibility to use assessments they feel are best for identifying achievement gaps, rather than forcing them to live with a one-size-fits-all approach that often ignores high needs children.

“And we should move toward a smarter accountability system that looks at more than just a test score, but focuses on the many factors that are indicative of school and student success, and highlight gaps in equity that must be addressed.”



New York State Allies for Public Education wrote a research-based response to a letter written on behalf of Governor Cuomo by his director of state operations Jim Malatras. The letter makes incisive points that are relevant to every state and every district in the nation, so I am posting it in full. Please open the post to see the links to research.



NYS Allies for Public Education
January 5, 2015


Dear Governor Cuomo,


We, the undersigned members of NYS Allies for Public Education (NYSAPE), are writing in response to the December 18th letter to the Commissioner and Chancellor that Mr. Malatras wrote on your behalf. By responding to the questions posed, we want to separate fact from misinformation. We are also very troubled by several questions that were not included in your letter which continues to demonstrate a disconnect between your office and the public.


We strongly believe in the importance and power of public education for all children. While the vast majority of our students are successful, we cannot rest until our struggling students are supported and given the needed resources to be successful.


Unfortunately, you have based your vision of school reform on a misguided agenda. That agenda includes ineffective strategies for school improvement. If current policies are not corrected, more state resources will be wasted and our students’ futures will be put at even more risk.


Let’s start at the beginning of the letter. The New York State Education Department (NYSED) has established capricious and inaccurate measures of proficiency and college readiness. The proficiency rates that are quoted in the letter (34.8% and 31.4%) reflect arbitrary cut scores set by Commissioner King in 2013. In 2012, proficiency rates in ELA and Math were 55% and 65% by the cut scores set by then-Commissioner Steiner, based on a college readiness study that he commissioned in 2010. Prior to 2010, proficiency rates were higher still under Commissioner Mills. In short, proficiency is an arbitrarily defined standard, and there is good evidence to suggest that NYSED has now set the Common Core standards unreasonably high, for political rather than pedagogical reasons.


We understand that you believe that over the past four years “much has been done to improve public education.” We disagree. Our high school graduation rate has barely budged since 2011, and the percentage of students earning a Regents diploma with Advanced Designation has been stagnant for several years and decreased this year. During the past four years, the graduation rate for the state’s English Language learners has dropped by 6 percentage points.


The Common Core proficiency rates were essentially flat between year one and two of the new tests (as were the rates on the final two years of the prior test) and our state’s SAT scores have decreased since 2010. In short, although we have engaged in four years of market-based corporate reforms—expansion of charter schools, evaluating teachers by student scores, imposing the Common Core standards and more time-consuming, and developmentally inappropriate tests–there is no evidence that New York schools are improving, and there is some evidence that results are moving backward instead. We believe that there is sufficient evidence to change course.


Clearly the public agrees. The 2014 Times Union/Siena College poll indicates that 46% of New Yorkers oppose the implementation of the Common Core standards, compared to only 23% who support them, while 46% oppose the current use of standardized testing, compared to 29% who support it. We believe it is time to listen to your constituents, rather than double-down on damaging policies that are hurting our children. It is our intent, by answering the questions that your office posed, to help you advocate for a better and wiser course in the months ahead.


Question 1


How is current teacher evaluation system credible when only one percent of teachers are rated ineffective? The NYC system was negotiated by Commissioner King directly and no one claims it is an accurate reflection of the reality of the state of education in NYC. What should the percentages be between classroom observations (i.e. subjective measures) and state assessments, including state tests (i.e. objective measures)? What percent should be set in law versus collectively bargained? Currently, the scoring ·bands and “curve” are set locally for the 60 percent subjective measures. What should the scoring bands be for the subjective measure and should the state set a standard scoring band? In general, how would you change the law to construct a rigorous state-of-the-art teacher evaluation system?


The first question implies that the teacher evaluation system called Annual Professional Performance Review (APPR), which you insisted be quickly adopted, is deeply flawed. We strongly agree. When it was put in place, over one third of the principals of New York State signed a well-documented letter explaining why APPR would have negative consequences for students and harm the profession of teaching. Since that time, the evidence against evaluating teachers by test scores has only increased.


The New York State School Boards Association recently passed a resolution against the use of student test scores for teacher and principal evaluations, and the National Association of Secondary School Principals has also disavowed their use for this purpose. In April of 2014, the American Statistical Association clearly outlined how unreliable this methodology is. Opposition to the evaluation of teachers by test scores is growing among parents as well, with only 31% approving of the practice in national polls.


Your question implies that test-score based evaluations are good because they are “objective”—that is, generated by an algorithm devised by the New York State Education Department. We strongly suggest that you review the evidence—just because a number can be generated based on other numbers does not make it a valid measure of performance. To revise APPR to give more weight to test scores would be a grave mistake.


You seem troubled that only 1 in 100 teachers were found to be incompetent, according to the APPR evaluation system. Do you have research that indicates that the number should be higher or lower? We strongly suggest that you return the decision on how to evaluate teachers to local education officials and each community’s elected school board. Your recent veto of your own Common Core APPR bill demonstrates that your office does not have a clear understanding of teacher evaluation, and the problems associated with Common Core testing. Albany bureaucrats should not be in the business of designing evaluation systems and arbitrarily determining what acceptable outcomes for each district should be.


Question 2


How would you address the problem of removing poor-performing educators when the current 3020-a process makes it virtually impossible to do so? Likewise, how would you change the system in New York City where poor-performing educators, with disciplinary problems, continue to be paid in the absent teacher reserve pool as opposed to being terminated?


No one wants incompetent teachers in the classroom. Tenure assures due process, not a job for life. You have been misinformed if you believe that the removal of teachers using the 3020a process is impossible.


The 3020a proceeding, which was streamlined in 2012, can lead to the termination of a teacher in 125 days or less. Teachers can be terminated for insubordination, immoral character, conduct unbecoming a teacher, inefficiency, incompetency, physical or mental disability, neglect of duty, or the failure to maintain certification.


Most experts say the real crisis in teacher quality, specifically in our high needs districts, is teacher turnover. According to a study of New York City schools by researchers Ronfeldt, Loeb, and Wycoff, “teacher turnover has a significant and negative impact on student achievement in both math and ELA. Moreover, teacher turnover is particularly harmful to the achievement of students in schools with large populations of low-performing students of color.”


We will not attract and retain the most talented teachers, especially in high-needs schools, by removing their right to due process.


Question 3


What changes would you make to the teacher training and certification process to make it more rigorous to ensure we recruit the best and brightest teachers? Do you agree that there should be a one-time competency test for all teachers currently in the system? What should be done to improve teaching education programs across the state?


We also want “best and the brightest” to be recruited to teaching, which happens by making the profession more attractive to highly talented people who have a desire to commit their lives to guiding and instructing children.


Since 2012 and the onset of “reform”, teacher morale is at a 20 year low. New reports have shown that there has been a dramatic drop in enrollment in teacher preparation programs—with a 22% decline in New York State in just the last two years. This suggests that the overwhelmingly negative rhetoric targeted to teachers and the assignment of blame for any and all problems in the way our schools are run have made the profession far less attractive. If the current trends continue, there will soon be a critical shortage of teachers, especially in STEM, special education and foreign languages –areas in which it is already very difficult to find sufficient candidates.


If you are interested in advancing teacher education programs, practicing educators should be surveyed, especially recent graduates, to ascertain how their preparation could have been improved. The idea that the quality of a teacher education program can be assessed by using the student test scores of its graduates is even more unreliable than evaluating teacher quality by means of student test scores. Likewise, creating a single high-stakes “test” to weed out practicing teachers is a gimmick, not a sound basis for judgment.


Question 4


What financial or other incentives would you provide to high-performing teachers and would you empower administrators to make those decisions?


The idea that teachers should be financially rewarded when their students receive high test scores has been proposed for decades, despite the fact that numerous studies have shown that merit pay does not work, including a recent three year study conducted by the National Center on Performance Incentives at Vanderbilt University.


Merit pay would be a waste of taxpayer dollars that would be far better spent on proven reforms.


Question 5


Do you think the length of a teacher’s probationary period should be extended and should the state create a program whereby teachers have to be recertified every several years, like lawyers and other professions? What other changes would you propose to the probationary period before a teacher is granted tenure?


New York State has a rigorous pathway for teacher certification. In order to earn Initial Certification, a candidate must be awarded a bachelor’s degree, pass no fewer than three certification exams, spend a semester of mentored student teaching with a certified educator, pass a written exam, and complete the performance –based assessment known as the edTPA.


In order to maintain teaching certification and progress to the required Professional Certification, teachers must have 3 years of satisfactory teaching experience, including one year of mentoring. Additionally, they must earn a Master’s Degree. Once teachers have completed all of these requirements and obtained their Professional Certificate, they must accrue 175 hours of additional professional development every five years.


A three-year probationary period during which they are frequently observed and given feedback from principals and other certified observers provides ample opportunity for a school district to assess an educator’s professionalism, growth and ability to incorporate best practices into his or her instruction. It is not unusual for that probationary term to be extended to four or even five years if there are doubts that sufficient progress has not been made. During probation, many struggling teachers leave the profession through the resignation process, so that fewer need to be formally dismissed.


Although teachers are not required to undergo recertification, they are required to engage in ongoing professional development and yearly evaluations, which is comparable or goes beyond the requirements of other, high level professions. Local school districts should be encouraged to continue to develop robust programs and protocols to monitor and support both new and veteran teachers.


Question 6


What steps would you take to dramatically improve priority or struggling schools that condemn generation of kids to poor educations and thus poor life prospects? Specifically, what should we do about the deplorable conditions of the education system in Buffalo?


The current practice of shutting down schools that are deemed failing is not an effective long-term strategy. Replacement schools usually do not serve the students in the so-called failing school. These displaced students then remain in a phase-out school with fewer resources, and drop out, or are displaced to another school, with an even higher concentration of at-risk students, thus continuing the cycle of school failure and closure.


Your question is based on the false assumption that schools are solely responsible for the outcomes of poor and disadvantaged students. Neither high-stakes testing, the Common Core, or the continual closing of schools can fix the systemic problems of our high-needs schools. NY State has one of the most inequitable funding systems in the nation, despite the decision of the state’s highest court in the Campaign for Fiscal Equity lawsuit that the funding system should be reformed. You have refused to address this inequity–schools with the greatest needs continue to receive the least resources and support.


As a result, class sizes in our highest need districts have grown each year. Let’s take Buffalo as an example. In Buffalo, many kindergarten classes have grown to 30 students or more, compared to a statewide average of twenty students per class. In New York City, class sizes have increased sharply since 2007, and last year they were the largest in 15 years in kindergarten through third grades. If you are truly interested in improving outcomes in our highest needs schools, these schools must be provided with the resources to reduce class size, a proven reform that benefits all students, but especially those most at risk.


In addition, providing resources for health services, counseling, after school child care and recreational programs to reduce truancy and improve attendance would likely have a positive impact on student learning.


Question 7


What is your vision for charter schools? As you know, in New York City the current charter cap is close to being reached, so would you increase the charter school cap? To what? What other reforms would you make to improve charter schools’ ability to serve all students?


The charter cap should not be raised. Many researchers including Macke Raymond, head of CREDO, a pro-charter research organization funded by the Walton Family Foundation, now agree that charter expansion and enhanced “competition” do not work to improve public schools. Moreover, charters do not enroll their fair share of high needs students – especially English language learners and special needs students, as acknowledged by the NYC Charter Center and independent researchers. According to the 2010 amendment to the New York charter law, before charters are renewed or allowed to replicate, they must show they enroll and retain equal numbers of at risk students as the districts in which they are located, and yet neither the Board of Regents nor SUNY have ever rejected a charter proposal on these grounds – despite the fact that many charters have sky high student suspension and attrition rates. Neither SUNY nor the Regents have provided adequate financial oversight, and in 95 percent of charter audits, the State Comptroller’s Office has found corruption or mismanagement. Yet when the Deputy Comptroller wrote a letter to the state’s major charter-school regulators asking for stronger oversight, he received no response.


The recent approval by the Regents of a charter school started by a 22 year old who faked his educational background only further reveals the inability of authorizers to carry out their current responsibilities, no less authorize yet more charters that could waste taxpayer funds. Meanwhile, in New York City, where the vast majority of the state’s charter schools are located, about two thirds of these privately-managed schools receive more public funding per pupil than district public schools – a disparity that will grow even worse with the new law requiring that charters receive free space paid for by the city or be provided space within the district’s already overcrowded public schools. This year, NYC charters are siphoning off $1.3 billion in public funds – while leading to the concentration of the most at-risk students in public schools with fewer resources and less space. It is no wonder that more NYC voters believe the number of charters should remain the same or decrease than be raised.


Question 8


Do you support using technology to improve public education, like offering online AP courses by college faculty to high schools students who do not have any such courses now, even though these changes have been resisted by education special interests?


The push towards using more technology in public education is not being “resisted by special interests,” as your letter claims, but instead is promoted by special interests – including software companies eager to get a larger share of the $8 billion education technology market. There is no rigorous research showing that more exposure to online learning improves student learning or outcomes in K12 schools, and many studies suggest that expanding the amount of time students spend in front of computer screens has negative effects.


Question 9


What would you do about mayoral control in NYC and do you support mayoral control in other municipalities? What changes and improvements would you make to NYC Mayoral control?


In general, mayoral control is an unproven experiment that has NOT worked to improve NYC schools compared to other large urban districts across the country, and should not be expanded across the state. In New York City, the mayoral control law should be amended to give more local control to the city’s residents, by giving the City Council the authority to provide checks and balances, since the city lacks an elected school board. Our democratic system of government relies on the separation of powers, and an omnipotent executive inevitably leads to abuse and poor decision-making. At the same time, the new state charter law should be amended, with local control returned to NYC officials, to enable them to determine whether or not privately run charter schools should receive space at city taxpayer expense.


Question 10


There are approximately 700 school districts in New York many of which have declining enrollment. Do you think we should restructure the current system through mergers, consolidations or regionalization? If so, how would you do it?


This question implies that through mergers, consolidations, and regionalization we can improve education while reducing costs. The research, however, contradicts that suggestion. Studies show that consolidations and mergers actually increase costs to districts and there is typically no gain in academic achievement. The following summary is from Penn State College of Education:


“School consolidation continues to be a topic of great concern for many small rural school and districts. While advocates for consolidation commonly cite fiscal imperatives based upon economies of scale, opponents have responded with evidence undermining this argument and pointing out the prominent position of the rural school in the economic and social development of community. Additionally, evidence continues to build demonstrating the advantages of small schools in attaining higher levels of student achievement. Larger schools, in contrast, have been shown to increase transportation costs, raise dropout rates, lower student involvement in extra-curricular activities, and harm rural communities’ sense of place.


The consolidation of services is already underway and should be incentivized when it makes sense and benefits students. It is interesting that while you have proposed consolidation for school districts, you have also supported charter school expansion, each of which are considered a separate local education authority or school district –which appears to be a contradiction.


Question 11


As you know, the appointment and selection process of the Board of Regents is unique in that, unlike other agencies, selections and appointments are made by the Legislature. Would you make changes to the selection and appointment process? If so, what are they?


We believe the Board of Regents must stay independent of the executive branch and the Governor should not interfere in matters of education policy. The authority should remain with the legislature to intervene when necessary.


There is a fair balance of powers in the NYS Constitution Articles V and XI requiring that the Governor and the Senate have the authority to appoint heads of departmental agencies, and the joint legislature to elect members of the Board of Regents, which in turn appoint the Commissioner of Education.


We do believe the nomination of Regent candidates should be a more transparent, inclusive process, and involve stakeholders from each judicial district, including parents, educators, students, and local legislators. For the at-large Regent seats, there should be a state-wide committee consisting of parents, educators, and legislators to nominate candidates after assessing gaps that may exist in the Board of Regents’ expertise, diversity in background and geographical balance.


Question 12


Chancellor, the Board of Regents is about to replace Dr. King; can we design an open and transparent selection process so parents, teachers and legislators have a voice?


We strongly believe there should be a more rigorous, inclusive, and transparent process to appoint the next New York State Commissioner of Education as well. While the appointment process is at the discretion of the Board of Regents as per Article V of the NYS Constitution, the overwhelming dissatisfaction of New Yorkers with the current policies — and the failure of state education officials to listen to parents and teachers – has revealed the need for a new Commissioner who is more responsive to stakeholder needs and concerns.


Questions That Should Be Asked


We were disappointed by the omission of important questions that should have been asked in your letter. During the past year, members of the public, especially parents, expressed serious opposition to the current education policies during forums that were held across the state. Those concerns, however, were excluded from your list. Here are three questions, which are very much on the minds of parents and that we would like to be asked of state officials:


How will the State Education Department review and modify the Common Core standards given the enormous public outcry against the standards and their implementation?


In October of 2014, Governor, you said that you were working to roll the standards back. You recognized that implementation had been rushed and that there were questions regarding whether the Common Core standards were the best standards for the students of New York State. The public has clearly expressed its dissatisfaction. A plurality of New Yorkers believes that the implementation of the Common Core should be halted entirely. Many other states are now engaging in a thorough analysis of the standards as they make revisions, both large and small. New York students deserve the best possible standards. Please join us in urging the State Education Department to provide a date when an open review of the Common Core standards will begin in New York.


How will we reduce the time students spend on state standardized testing?


Polls consistently report that New York parents do not support the grueling and inappropriate Common Core tests. Time spent on state testing has dramatically ballooned since 2012. Last year between 55,000 and 60,000 students “opted out” of the grade 3-8 New York State exams. Make no mistake—this was a deliberate decision on the part of parents to show how displeased they are with the Common Core exams and the way in which these tests have narrowed and diminished the education of their children.


Your support for reducing the effects of test scores on students was but a small step in the right direction. Please join us in asking the State Education Department to provide a plan to radically reduce the time spent on state exams, rolling it back to 2010 levels, as long as yearly testing is mandated. Please also inquire as to when teachers will be allowed to author better assessments, so that the state is no longer spending millions of taxpayer dollars to corporations that have consistently produced shoddy products.


How will personally identifiable student data be protected?


Data privacy of student’s personally identifiable information is still not protected, nor is the privacy legislation that was passed last spring being enforced. While the legislation helped to stop sharing with inBloom, it did not address the concerns of parents of the widespread collection and sharing of their children’s personal data that is occurring without their knowledge or consent.


Moreover, allowing data-mining vendors to access children’s personal data has huge risks, including to student privacy and safety. Yet the State Education Department still has not implemented or enforced the new student privacy law, passed last spring, which requires the appointment of a chief privacy officer who will create a parent bill of rights with public input. As a result, numerous districts and schools throughout the state continue to disclose highly sensitive personal student data to vendors without parental knowledge or consent, and are ignoring several federal privacy laws, including FERPA and COPPA, without enforcement or oversight by the state.


In summary, it is apparent that the punitive education agenda of testing and privatization is not working to improve student achievement and instead is having a deleterious impact on our schools. It is time to change course rather than intensify these policies through requiring more school closings, expanding charters, and putting even more emphasis on unreliable test scores.


What New York badly needs is a new Commissioner with a strong background in public education and a deep understanding of how students learn. He or she should have a healthy respect for local autonomy and the need to work collaboratively with stakeholders. The era of top down, bureaucratic, and monopolistic control of our schools by state officials must end.


We believe that the members of the Board of Regents should be thoughtfully selected with input from the communities that they represent. Most importantly, parents and teachers demand appropriate learning standards that allow teachers to focus on learning, not testing. With equitable funding, thoughtful standards, sufficient teacher autonomy, local control, and community support, we know public education will better accomplish what we all want–a brighter future for all students. We also urge you to hold public forums, so you can hear directly from parents, teachers, and other stakeholders how they want their schools improved –rather than remain in a bubble up in Albany, separated from the constituents whose interests you should be dedicated to serve.


NYS Allies for Public Education

- See more at:

Charter schools continue to be a risky investment. The Albany (NY) Times Union reports that a Wall Street credit rating agency downgraded the bonds of certain Brighter Choice schools, once considered the “holy grail” of the charter school movement.


Wall Street sensed trouble at the Brighter Choice middle schools for boys and girls even before the state notified them last month they may be forced to close their doors after this year.


One of the largest credit rating agencies, Fitch Ratings, in December downgraded the five-year-old schools’ bond ratings, citing improved but still lagging academic performance and the fact that the schools themselves had not sought full five-year renewals of their state charters.


In its Dec. 18 briefing for investors, Fitch noted the schools’ “limited renewal prospects” based in part on “testing results below (state) expectations…..”


The threat of closure looms large not just for the roughly 450 fifth- through eighth-grade students and staff but also for the Brighter Choice Foundation, which helped found the schools and could be on the hook for the $15.1 million in bonds owed on the brand-new building.


According to Fitch, the foundation — the 15-year-old nonprofit that once supported 11 city charter schools — guaranteed the schools’ bond debt. Yet the rating agency expressed doubt that the foundation has the money to make those payments over the long term.


As Governor Andrew Cuomo seeks to expand charter schools across the state, he might pay attention to what is happening in Albany, his backyard.



This is a comment by one of our frequent participants, identified as Teacher Ed:


Virtually every component of corporate “reform” imposed across this country is based on disasters that “reformers” have fabricated and tyrannical racketeering. Clearly, this is being done in order to privatize public education and raid tax dollars, while diverting attention away from the real disasters of poverty, a severe decline in the number of jobs with livable wages, a diminishing middle class and the inequitable distribution of wealth.


Are we supposed to wait until the perpetrators turn the screws and receive their dues for each part of this scheme before lawsuits can be filed? Is that how it works with the mob, too –payoffs have to be made first by victims before anything can be done about all the threats and dire consequences to result from not kowtowing to demands?


Is it possible to file a lawsuit that addresses virtually ALL of the components of the corporate “reform” business plan that is rapidly unravelling the fabric of American education? Maybe the ACLU could manage it, if only someone who cares would help fund it.

In Connecticut, a formal investigation of Families for Excellent Schools and Jumoke Academy concluded that the growing charter chain–a favorite of top state officials–engaged in unchecked nepotism, with little or no supervision by the state. Be it noted that Governor Dan Malloy appointed Andrea Comer, chief operating officer of FUSE to the state Board of Education. Comer resigned from her position at FUSE after the scandals surrounding Michael Sharpe broke, and she also resigned from the State Board of EducAtion.


The Hartford Courant reports:


The Jumoke Academy charter school operation was saddled with “rampant nepotism,” imposed little or no oversight on former CEO Michael Sharpe and made repeated financial missteps that could sink the organization within three years, according to a 99-page investigative report ordered by the state Department of Education.


The report, released Friday afternoon and coming in the midst of an FBI investigation of Jumoke and the closely related Family Urban Schools of Excellence, mirrors reporting by The Courant since June. The state report was especially critical of Sharpe, who hired multiple family members, gave work to the relatives of Jumoke executives, approved the hiring of felons for school jobs and oversaw “expensive and ornate modifications” to a Jumoke-owned apartment that he later rented. Sharpe resigned on June 21.
“There were virtually no checks and balances in place to control Mr. Sharpe’s actions at Jumoke,” the report’s author, Hartford attorney Frederick L. Dorsey, wrote. “Michael Sharpe basically had unfettered control of Jumoke from the time he was appointed CEO in 2003, and even after he had transitioned in July 2012 from CEO of Jumoke to CEO of FUSE.”


Here is the full report:




We’re All Mad Here: The Conference on English Education’s (CEE) Response to the US Department of Education’s Proposed Regulations for Teacher Preparation



On Dec. 3, 2014, the United States’ Department of Education (DOE) released a document proposing new regulations for teacher preparation programs, citing the need for greater accountability for teacher preparation programs, as well as the development and distribution of data focused on the quality of those programs. The public was then invited to comment on the regulations, with the comment period closing on Feb. 2, 2015. Note, however, that the Office of Management & Budget “is required to make a decision regarding the collection of information contained in the proposed regulations between 30 and 60 days after publication of the proposed regulations.”3 For full consideration of the public’s response, therefore, comments should be submitted by Jan. 2, 2015.


The Conference on English Education (CEE) urges its membership, as well as teachers, parents and students, to make use of this public comment period to respond to the proposed regulations – ideally by Jan. 2.


These regulations are disingenuous at best, hypocritical at worst, in their misrepresentation of and approach to quality teacher education. Therefore, we must state clearly and forcefully – to the DOE, as well as to US senators, state representatives, university presidents, state superintendents, school principals, teachers, students, neighbors and the public at large – that the proposed regulations will do more harm than good.


Whether online, through the media or in person, we must speak against the misguided beliefs driving such regulation: that teacher performance can be equated to student performance; that standardized tests provide meaningful evidence of learning; that student learning occurs in a vacuum; that there is one set approach that works with all students. We have been invited to speak, and we must accept the invitation – although it feels a bit like being invited to the Mad Hatter’s tea party, doesn’t it? “But I don’t want to go among mad people,” Alice remarked. “Oh, you can’t help that,” said the Cat: “we’re all mad here. I’m mad. You’re mad.” “How do you know I’m mad?” said Alice. “You must be,” said the Cat, “or you wouldn’t have come here.”


Despite very little evidence to support its efficacy for student learning, standardized testing has claimed our classrooms. “Objective” data drives decision-making rather than the “subjective” issues that affect the children we seek to educate. Teachers are constantly labeled as ineffective, uncaring, unprepared. Patently unqualified corporations, millionaires and for-profit businesses are invited to “solve” educational issues while patently qualified teachers, teacher educators and educational researchers are excluded from the discussion.


The document is found at!documentDetail;D=ED-2014-OPE-0057-0001


To do so, visit!submitComment;D=ED-2014-OPE-0057-0001


For additional information, view Jane West’s webinar: uploads/2014/12/Teacher-Preparation-Regulations-for-CEEDAR.pdf


For an excellent example, see Anne Elrod Whitney’s piece Proposed Regulations Bad for Kids, Teachers, and Schools: teachers-and-schools/ And now, teacher education programs have moved into the line of fire. If the proposed regulations are to be believed, teacher preparation currently functions with little accountability, producing poor quality candidates whose abilities are not properly assessed. The evidence for such claims consists of flawed measures and unreliable research from questionable sources.


Yet, the answer to this (unproven) assumption is to increase assessment and accountability measures, despite no evidence that these measures have been beneficial as implemented in the public schools. Madness. Teacher preparation programs are, indeed, held accountable; they undergo assessment; they use data to inform their decision-making processes.


As the professional organization for English teacher education, CEE created the Standards for Initial Preparation of Teachers of Secondary English Language Arts 7-12; revised in 2012, these standards delineate the required competencies of knowledge, skills and dispositions connected to content, pedagogy, learners and professionalism. The Council for the Accreditation of Educator Preparation (CAEP) uses these standards to assess and recognize the abilities of English teacher education programs to prepare quality secondary English teachers. To meet these standards, programs must gather, analyze and report a wide range of data from both the program and the candidates. This external accountability is in addition to the internal accountability of the programs themselves. In-house, as it were, teacher preparation programs must remain cognizant of and respond to the internal and external pressures driving education in order to prepare teachers for the classroom.


Do some teacher education programs fail in this endeavor? Admittedly, yes. But the way to improve our teacher education programs is not with more assessment and accountability, measures in and of themselves that are already present and valued in higher education. Could these measures be improved? Certainly, as any educator knows. Teacher education programs recognize the need to improve our efforts to gather better data from and about our graduates; we are constantly revising our means of candidate assessment in order to respond to our needs and the requirements of an outside accrediting body.


What we don’t do is expect the test scores of our graduates’ students to provide a worthwhile measure of their teacher’s efficacy. Value added measurement (VAM) has little support among those with the ability to understand the nuances of assessment5, much less those of teaching and learning. Parents certainly do not support the current over-testing of their children; teachers know that reliance on externally developed high-stakes tests offers a distorted view of a child’s abilities; teacher educators recognize that assessment is a nuanced process that requires multiple measures over time. We know that assessing teachers’ worth on the test scores of the complex human beings they teach is a deeply flawed measure of ability, with no recognition of the many factors influencing both teaching and learning. Rather than admit this and seek better ways to determine quality teaching, however, the US Department of Education now proposes to assess the teachers of the teachers’ worth on those same test scores. Madness. Alice laughed. “There’s no use trying,” she said: “one can’t believe impossible things.” “I daresay you haven’t had much practice,” said the Queen. “When I was your age, I always did it for half-an-hour a day. Why, sometimes I’ve believed as many as six impossible things before breakfast.”


For more on those nuances, see the American Statistical Association’s Statement on Using Value-Added Models for Educational Assessment: These regulations promulgate beliefs that those in education know to be false: that there is one right measure of learning, that there is one right method of teaching, that there is one right type of teacher, that there is one right way to prepare teachers. Teaching is a complex, complicated, challenging, often contentious, endeavor because those we seek to teach – and the subjects we seek to teach them – are complex and complicated and challenging and, often, contentious. We understand, though, that teacher education creates the foundation that our students build on for the rest of their teaching career rather than hubristically assuming that we can boil teaching down to a set of “one size fits all” approaches that will serve in any situation.


Teacher education programs educate prospective teachers to understand, examine and respond to issues of content, pedagogy, learners and learning. It isn’t an easy job – hence the diversity of approaches and the ongoing assessment of those approaches in teacher education programs around the country. While the foundational principles of education may remain the same, English education programs in New York City are not – and should not be – the same as those in Cheyenne. What my students in West Lafayette, Indiana need to know in order to teach a largely rural population differs from what my colleague’s students in Tampa, Florida need to know in order to teach a largely urban population.


Yet, every day, we in teacher education embrace this difficult task of preparing young men and woman to respond as experienced professionals to every possible combination of factors they will meet in their future classrooms. These regulations trade on the common complaint that many beginning teachers feel unprepared when they first enter the classroom, pointing back to a lack of preparation from their teacher education programs. Solidifying such unproven cause and effect into ill-suited regulation belies the many factors that shape a teacher’s entry into the classroom: the type of school, the level of support, the number of resources, the diversity of student issues in addition to the teacher’s individual abilities, understandings and personality. Assuming that this one factor – how teachers are prepared – contributes to the high rate of teacher turnover is yet another unproven cause and effect. Teachers don’t leave simply because they aren’t prepared well. They leave because political, social and rhetorical conditions in this country destroy their will to teach. And those conditions are now poised to destroy teacher education.


Has it occurred to no one (except educators) that one reason teachers leave the classroom is because many schools have become unpleasant places to be? This has less to do with their preparation – teacher education programs cannot control the factors their students will meet upon entering the classroom – and everything to do with the current climate in this country surrounding teachers and education. Why would anyone want to enter a profession that is continuously attacked, denigrated and demeaned in every public avenue? And, yet, I have students in my college classrooms wanting to do just that. These bright young women and men are cognizant that their choice of career is held in little regard; they understand that they will work long hours for little external reward; they accept that the public will disregard their intelligence, their ability and their commitment in seeking to become English teachers. They want to teach, however, because they want to do something meaningful with their brains and their bodies.


These young college graduates willingly take on an astounding level of responsibility from their very first day in the classroom because, as one of my students wrote recently, “How are we, as future teachers, supposed to challenge our students if we never challenge ourselves?” “Take some more tea,” the March Hare said to Alice, very earnestly. “I’ve had nothing yet,” Alice replied in an offended tone, “so I can’t take more.” “You mean you can’t take LESS,” said the Hatter: “it’s very easy to take MORE than nothing.”


At this point in our country’s history, teachers and teacher educators are doing their best with more of nothing: no public support for their work, no understanding of their professionalism, no recognition of the contributory factors to student learning. That extends to the teacher education programs that prepare them. We work against the fallacy that teacher education at the college level is of little benefit, that sixweek boot camps can prepare anyone for the classroom, that those with no understanding of or background in education are better suited to do our work. The US DOE regulations of teacher education programs cost more time and more money – millions, in fact – while implementing an assessment system in higher education that has proven seriously flawed in the public schools. They assume a reductive approach to teacher preparation that belies the complex factors teacher education programs must navigate to educate their candidates. They dismiss the solid work happening in teacher education programs every day throughout the country in favor of pushing an agenda that neither conforms to reality nor recognizes expertise.


Like Alice, we need to push away from our seat at this table by clearly speaking against the misguided beliefs propelling these regulations. We need to publicly proclaim this party for the madness it is, opposing those who lead it and shaking those who slumber while it happens. We know better, as teacher educators. Every day, we do better, as teacher educators. It’s time we spoke up, as teacher educators, and established that we are better at assessing our students’ abilities as teachers than the measures proffered by these fundamentally flawed regulations.


Respectfully submitted,


Melanie Shoffner, PhD Chair, Conference on English Education

The speaker of the State Assembly in Wisconsin said the first thing on his agenda when the Legislature reconvenes will be a teacher accountability bill.


Tim Slekar, dean of Edgewood College, has a better idea: Why not start with a “legislator accountability bill”?


The speaker, Robin Vos, now wants reports on professors’ workload. Slekar says, Let’s check out your daily workload first. Let taxpayers know when and where you are actually working for us.



Anyone who criticizes the current regime of test-based accountability is inevitably asked: What would you replace it with? Test-based accountability fails because it is based on a lack of trust in professionals. It fails because it confuses measurement with instruction. No doctor ever said to a sick patient, “Go home, take your temperature hourly, and call me in a month.” Measurement is not a treatment or a cure. It is measurement. It doesn’t close gaps: it measures them.

Here is a sound alternative approach to accountability, written by a group of teachers whose collective experience is 275 years in the classroom. Over 900 teachers contributed ideas to the plan. It is a new vision that holds all actors responsible for the full development and education of children, acknowledging that every child is a unique individual.

Its key features:

1. Shared responsibility, not blame

2. Educate the whole child

3. Full and adequate funding for all schools, with less emphasis on standardized testing

4. Teacher autonomy and professionalism

5. A shift from evaluation to support

6. Recognition that in education one size does not fit all

Peter Greene makes a stab at explaining what Andrew Cuomo doesn’t understand about accountability.

First point is that you keep your promises after the election is over. Cuomo promised to delay high stakes attached to test scores in teacher ratings. After the election, he changed his mind.

The second is that you use tests to learn what’s happening, not to confirm what you believe. Cuomo thinks lots of teachers are failing, and he won’t believe any measurement unless it confirms his prior conclusions.

What Peter doesn’t explain is why presumably intelligent people like Cuomo think that teachers alone are responsible for student test scores. What if the student never does his homework or pay attention in class? What if the student doesn’t speak English? What if her mother has a fatal illness? There are so many variables over which the teacher has no control. Experience has shown that the various teacher evaluation models are fraught with instability and error.

Marian Wang of ProPublica writes that Néw York’s First Deputy Comptroller, Pete Grannis, can’t understand why charter school regulators in the state are uninterested in charter school accountability for public funds.

Grannis has contacted state and city officials about his concerns and received no response.

“Pete Grannis, New York State’s First Deputy Comptroller, contacted ProPublica after reading our story last week about how some charter schools have turned over nearly all their public funds and significant control to private, often for-profit firms that handle their day-to-day operations. The arrangements can limit the ability of auditors and charter-school regulators to follow how public money is spent – especially when the firms refuse to divulge financial details when asked.

“Such setups are a real problem, Grannis said. And the way he sees it, there’s a very simple solution. As a condition for agreeing to approve a new charter school or renew an existing one, charter regulators could require schools and their management companies to agree to provide any and all financial records related to the school.

“Clearly, the need for fiscal oversight of charter schools has intensified,” he wrote in a letter to New York City Mayor Bill de Blasio last week. “Put schools on notice that relevant financial records cannot be shielded from oversight bodies of state and local governmental entities.”

“It’s a plea that Grannis has made before. Last year, he sent a similar letter to the state’s major charter-school regulators – New York City’s Department of Education, the New York State Education Department, and the State University of New York.

“He never heard back from any of them. “No response whatsoever,” Grannis said. Not even, he added, a “‘Thank you for your letter, we’ll look into it.’ That would have been the normal bureaucratic response….”

“To Grannis, though, his efforts aren’t about politics. His office is “agnostic on charters,” as he put it. His office also audits the finances of traditional public-school districts, he pointed out.

“We’re the fiscal monitors. We watch over the use or misuse of public funds,” Grannis said. “This isn’t meant to be anti-charter. Our job is not to be pro or anti.”

His job is to monitor the use of public funds, wherever it goes. Apparently no one else cares.


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