The Missouri DESE recently released an updated draft of their ESEA waiver application. You can read it on their ESEA Flexibility Waiver Web page. As we have mentioned in past posts (Read MSTA Director Kent King’s post here and the previous objections here), MSTA opposes NCLB and is strongly against this waiver. We have several specific concerns:
Most importantly, DESE still has not completed a financial impact study to determine the associated cost to Missouri taxpayers. Additionally, the department has not released details of when or if they intend to conduct this study.
Just like previous drafts, this application is vague. The department developed it under a short timeline, with little input from Missouri educators.
The waiver essentially puts control of Missouri’s accountability system in the hands of the federal government instead of local school districts, compromising what’s long been recognized as an outstanding model of school accountability.
In terms of specific concerns page 18 proposes achievement targets increase 25 percent by 2020. How is this different than our current system of Adequate Yearly Progress (AYP) under the current NCLB? How is this feasible given new assessments, new standards and a model curriculum will be implemented during this timeline? We already know the new standards are expected to be more rigorous and the rigor will be measured in the form of new assessments. Not only will the new assessments have to be re-benchmarked, leaving DESE with no idea how students will achieve these benchmarks, but research on assessment administration indicates that new tests typically yield lower results in the first one to three years. Combine the research with more rigorous assessments, and 25 percent improvement doesn’t appear to be a realistic expectation.
There are vast differences between MSIP 5 and DESE’s waiver plan, which make it impossible to create a single system of accountability. The Feb. 21 application deadline does not allow DESE sufficient time to conduct data analysis and simulations or to evaluate the impact the new system will have on Missouri public school districts and students. Specifically, there are new standards for which there is no or little data for analysis, the methodology used to develop the scoring guide is entirely new and applying any scoring guide at the building level will be extremely complicated and will require extensive analysis and evaluation.
The evaluation system, as described, will require districts to develop new assessments, implement new data collection and reporting systems, implement new tracking and monitoring system sand provide extensive training. The administrative and financial requirements will have huge financial implications for school districts.
Our state assessment system was not designed to measure “teach affect” as prescribed in the evaluation component of the waiver application. Summative assessment results culminate a combination of factors, including the student’s prior knowledge, the curriculum and instruction. Teachers have little control over their curriculum and as page 10 of DESE’s waiver application indicates, lack of state resources have impacted the quality and availability of written curriculum.
The requirements for teacher evaluations and state sacrifice our state’s system of accountability and will taint what has long been a widely well-recognized system. Instead of “gaining” NCLB flexibility, we will be “LOSING” state flexibility. This “solution” to having multiple systems of accountability will not solve the flaws within NCLB, but will, instead, flaw MSIP and create one very large flawed system that will have negative consequences for our schools, teachers and students.
Again, it isn’t financially responsible to exhaust state and local school district resources in pursuit of a federal initiative that is likely a temporary provision, with requirements and guidelines that will be replaced with new reauthorization requirements and guidelines after less than one year. There are NO real consequences for states that do not meet NCLB requirements by 2014. It would be more cost effective and efficient to continue to live with the current requirements and guidelines than to exhaust resources on a short-term solution that will have long-term, costly negative consequences for public school districts.
Missouri’s application cites five major Collaborative Partnerships (intended to be K-12/Higher Ed partnerships). Of the five, only one school district was represented on each of three initiatives and no school districts were represented on two, while other members included multiple representatives from DESE, DHE and higher education institutions (very much like the development of Top 10 by 20). Who’s driving the bus? Who has the most to gain from some of the following DESE initiatives:
- Higher standards for teachers= more college remediation and additional required courses ($)
- College for all students=increased college enrollment ($)
Send DESE your concerns by Feb. 21 to esea@dese.mo.gov.
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