Editor's Note: Kent, King, the Missouri State Teachers Association just sent this letter to the Missouri Department of Elementary and Secondary Education and those mentioned below. You have until tomorrow to send DESE your concerns via email to esea@dese.mo.gov.
To: Commissioner Nicastro and State Board of Education Members
Re: Missouri’s NCLB Waiver application
Date: February 20, 2012
As the application for ESEA waivers are being debated and considered by the State Board Of Education, I would like to go on record as stating that the Missouri State Teachers Association opposes the waiver application to the Federal Department of Education for a variety of reasons. First, we feel that NCLB is dead and another year of meaningless AYP on an area due for reauthorization is not needed. Allowing “waiver rules and regulations” promulgated by DESE and accepted by the Federal Department of Education, to re-yoke students, teachers, districts and our entire K-12 system to a new version of NCLB without Congressional reauthorization and keeps our members and those in public education who have toiled under the unrealistic and artificially mandated standards of the past decade to continue with a new “lite waiver version.”
Many of the associations who have participated in and with the MSIP Steering Committee still have many unanswered questions and concerns regarding the details and implications of Missouri’s waiver application. While we all agree that Missouri school districts and schools would prefer not to be labeled failing under NCLB standards, NCLB is at the end of its life cycle and really has been fairly meaningless along the way. Many have more concerns regarding the actual “relief” that will be provided to public schools under the NCLB waiver compared with the additional provisions that will be required. There are many points included in the one-page side-by-side comparison DESE provided at the last Steering Committee meeting that do not clearly explain which sanctions are waived and which provisions still remain in place. For example, the only HQT provision that’s waived is the sanction that requires an HQT plan to be developed when HQT targets are not met for three consecutive years. Teachers who are not highly qualified still have to be identified and reported, and their salaries cannot be paid using federal funds.
Another area of concern is the lack of details on the scoring guide. While DESE proposes a system that accounts for growth, progress, and status to increase the percent proficient by 25 percent by 2019, the details are still unavailable. The scoring guide details are critical because building- and district-level APR’s (to be used in MSIP 5) will be impacted by what’s approved for federal accountability purposes. While all agree, no one wants to be labeled failing under NCLB, it’s much easier to refute the misidentification under the flawed system of NCLB than to refute “failing” under MSIP. The sanctions associated with loss of accreditation under MSIP are much greater than those associated with NCLB.
This uneasiness around the scoring guide gets magnified with the increased rigor in state standards and associated assessments. DESE’s staff has indicated that the CCSS should increase what a student needs to know by up to two grade levels. If the new tests assess the more rigorous standards, can we really expect to see an increase in the percent of students scoring proficient over the next several years? If the new tests do not assess the CCSS, why are we exhausting our financial resources to develop and administer new assessments?
What are the financial implications associated with implementing the requirements of the waiver application? While the sanctions of the current NCLB system include school choice and supplemental educational services, funds received under Title I can be used to cover the costs of those sanctions. What hasn’t been discussed is that the majority of costs associated with developing and implementing assurances required by the waiver, including the Common Core State Standards, college- and career-readiness standards, Smarter Balanced Assessment Consortium tests, and principal and teacher evaluation systems must be paid for with state and local dollars in order to avoid supplanting. No cost analyses have been conducted to determine how these changes will impact local school districts.
The purpose of this message is not to criticize DESE’s efforts to provide school district relief from certain provisions of NCLB, but instead to consider the implications of the current waiver application and explore alternatives that meet the needs of Missouri public schools. At this site, you can view additional information provided by USED which allows states “more time to develop a comprehensive, high quality request.” This letter provides the opportunity for states to apply for a one-year AMO waiver, which essentially means that no additional Missouri public school districts or schools would be identified as failing under NCLB. This temporary waiver could allow adequate time for DESE to meaningfully engage stakeholders across Missouri to develop a comprehensive plan (to be submitted in September) that addresses the scoring guide details, financial concerns, and infrastructure necessary to support an accountability system that leads to improved student achievement.
There are multiple other issues I could highlight including concerns around the limitations of state assessments in determining "teacher affect," the lack of standards that really support "career readiness," the lack of infrastructure to support the implementation of the waiver plan, all of which lend themselves to making sure we move without undue haste to secure something that really doesn’t meet the needs of Missouri children or the school districts in which they reside. The price tag for all these waivers will simply fall on local districts to absorb as best they can. Not something that endears our state leadership to the day-to-day practitioners of K-12 education.
In closing, it should be noted that DESE's unfinished plan leaves practitioners with questions and concerns for the future of Missouri education. How can stakeholders be meaningfully engaged if they don't have a completed plan on which to react? Specifically, the current plan doesn't address any of Section 2E (Focus Schools) and none of the required documentation to accompany the request has been made available to stakeholders. There comes a point where “trust us” simply doesn’t play.
I hope you take due diligence in the decisions that the rest of the profession has to live with. Thank you for listening.
Sincerely,
If you want to download a copy of the letter, you can click here.
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