Forum on Educational Accountability

www.edaccountability.org

 

Re: Race to the Top Fund – Notice of Proposed Priorities, Requirements, Definitions and Selection Criteria – Docket ID ED–2009–OESE–0006

 

Draft Guidelines for ‘Race to the Top’ Has Some Good Ideas, But Priorities Need Changing

 

Re Regulatory Alternatives Considered, pp. 48-49

The Forum on Educational Accountability (FEA) appreciates the opportunity to respond to Education Secretary Duncan’s “Draft Guidelines” for the “Race to the Top Fund.”  Fundamentally, FEA concludes that a number of the priorities in the Draft Guidelines must be considerably revised.

 

FEA’s comments are rooted in its two statements, the “Joint Organizational Statement on No Child Left Behind (NCLB) Act” (2004) and “Empowering Schools and Improving Learning: A Joint Organizational Statement on the Federal Role in Public Schooling” (2009); and its two reports, “Redefining Accountability: Improving Student Learning by Building Capacity” (2007) and “Assessment and Accountability for Improving Schools and Learning: Principles and Recommendations for Federal Law and State and Local Systems” (2007). The first two documents are appended to the end of these comments. All published FEA materials are on the web at http://www.edaccountability.org.

 

FEA is an alliance of national education, civil rights, religious, disability, parent, union, and civic organizations supporting comprehensive public school reform. For the Race to the Top (RTTT) Guidelines to advance that goal (I. Proposed Priority 1, pp. 10-11), the federal government should encourage states’ applications to answer a central question: Which systemic changes would significantly improve schools’ capacity to successfully teach a challenging curriculum in the classroom and parents’ capacity to support high level learning at home?  Building those capacities is the heart of successful public school reform.

 

In evaluating state applications, the Department should give the most weight to the factors most critical to strengthening teaching and learning (III. Selection Criteria, 1^st paragraph, p. 23):

 

·        improving the quality of assessments;

·        providing for effective professional development of teachers, principals and other educational staff;

·        ensuring equity and opportunity to learn for all children;

·        enhancing family support for student learning and family involvement with schools; and

·        building state capacity to assist systemic improvements in public schools.

 

Assessments:

 

III(A)(2), (A)(3), and (B)(3)(i), Proposed Selection Criteria, pp. 26-28 and Definitions, “Formative Assessment,” p. 40, “High-quality assessment,” p. 41, “Student achievement,” p. 43 and “Student growth,” pp. 43-44.

 

The Guidelines’ emphasis needs to be on states overhauling their assessment systems in line with FEA’s published recommendations, including as follows. (FEA takes no position on “common standards.”)

 

·        The Guidelines must emphasize that state assessments – or any national assessments or common assessments created by consortia of states based on new common standards -  need to go beyond using predominantly multiple-choice tests to incorporating performance assessments.  In the words of President Obama, these can show student ability to “use technology, conduct research, engage in scientific investigation, solve problems, present and defend their ideas.”  New assessment systems also should include the use of locally-based evidence of student learning, in addition to state level exams.  Further, state evaluations of “student achievement” need to incorporate additional data, such as high school graduation rates.

 

·        New systems also need to help teachers develop and use classroom-based “formative assessments.” These provide teachers with prompt feedback on what their students do and do not understand, and they enhance teachers’ skills in adjusting instruction accordingly to meet the needs of individual students.

 

Data Collection/Opportunity to Learn:

 

III(B)(1)(2)(3), Proposed Selection Criteria, pp. 27-29, III(C)(3), pp. 30-31 and Definitions, “High-quality assessment,” p. 41, “Student achievement,” p. 43 and “Student growth,” pp. 43-44.

 

FEA supports the Guidelines’ having states expand their collection of “statewide longitudinal data systems” to include out-of-school factors such as students’ health and postsecondary experience.  The Guidelines should also call on states to collect and publish data on resource inequities (disparities in the opportunity to learn), such as the extent to which not only qualified staff, but also buildings, libraries and other material resources necessary for a high quality education, are being provided in some public schools in the state and not in others.  Then, the states need to be required to develop strategies to overcome the inadequacies and inequities. In line with our Assessment recommendations, data on student learning must use standardized test scores as only one modest component, relying more on other information about student learning and progress.

 

Teacher and Principal Quality:

 

III(C)(2), Proposed Selection Criteria, pp. 29-30 and Definition, “High-quality assessment,” p. 41.

 

·        It is important to strengthen the evaluation of educators, and evaluations may include "teacher and principal effectiveness based on performance." But it should be made clear that if systems use student “achievement” data in evaluating teachers and principals, then “achievement” must include evidence of student learning in which student scores on state exams are at most only a small portion.

·        The Draft is correct that assessments should be appropriate for a full range of students, including students with disabilities, English language learners and other student populations that are the prime focus of federal improvement efforts.

 

III(C)(5), Proposed Selection Criteria, pp. 31-32 and Definitions, “Instructional improvement systems,” pp. 41-42 and “Persistently lowest-performing schools,” pp. 42-43.

 

·        The Draft’s section on “[p]roviding effective support to teachers and principals” needs to be greatly expanded.  “Professional development” and “time for common planning and collaboration” are not merely necessary to help teachers and principals use quickly available (“rapid-time”) formative assessments to “inform current … instruction,” but are critical to improving teacher and principal knowledge and skills generally.  Likewise, mentoring is essential to meet educators’ individual pedagogical and leadership needs. Career ladders must be established for mentor teachers and other specialists to support ongoing teacher and principal improvement.  The Guidelines should require states to focus these improvement efforts on the highest poverty/lowest achieving schools among the “persistently lowest-performing schools,” including how they will address the unique and challenging education needs of various specific student populations attending public schools, such as Native Americans and recent immigrants.  In its NCLB reform proposal, FEA has emphasized that it is important for the Government to support such efforts by  allocating substantial sums for those purposes (e.g., an amount equal to 20% of Title I funds).

 

School Turnaround:

 

III(D)(3), Proposed Selection Criteria, pp. 33-35.

 

The Draft’s priorities proposed for turning around struggling schools need to be reversed.  Replacing school governance, converting schools to charters or private management, or closing them down should be de-emphasized.  At a minimum, the five options allowed under NCLB should not be narrowed, as the Draft does. Primarily, emphasis must be on transforming schools by improving leadership and instruction through intensive professional development, peer collaboration, mentoring, career ladders and other educational supports for staff.

 

Family Engagement:

 

III(D)(3), Proposed Selection Criteria, pp. 33-35.

 

Similarly, providing “mechanisms for family and community engagement” must be given a higher priority and should no longer be relegated to the last initiative in the Draft’s lowest ranking turn-around option.  Specifically, States need to provide programs of adult literacy and parenting skills for parents of very low-performing students to increase parental support for student learning at home, as well as adult mentors for students without parents available.  And states and school districts need to provide programs to engage families to be directly involved with the schools.  This is essential so that staff and parents, or other responsible adults at home, will be working together to transform the children’s learning.  In its NCLB reform proposal, FEA has emphasized that it is important for the Government to support such efforts by allocating substantial sums for those purposes (e.g., an amount equal to 5% of Title I funds).

 

Improving State Capacity

 

III(E)(5), Proposed Selection Criteria, pp. 37-38.

 

While the Draft soundly recognizes the value of building the capacity of state departments of education to support school improvement generally, the chief focus needs to shift.  States qualifying for RTTT funds should be required to greatly expand their staffs’ knowledge and skills in how to assist, and, where necessary, lead transformations of low-performing schools.  In its NCLB reform proposal, FEA has emphasized that it is important for the Government to support such efforts by allocating substantial sums (e.g., an amount equal to 2% of Title I funds) to building states’ capacities to assist districts and schools implement systemic change.

 

FEA recognizes that RTTT operates within the structure of NCLB.  But, while NCLB has some strengths, it also causes serious harmful consequences (such as those identified in the attached Joint Statement), is ineffective in dramatically improving student learning and needs to be fundamentally overhauled.  In its RTTT Guidelines, the Department should do all that it legally can to ameliorate the negative impacts of NCLB in the short term.  Beyond that, the Department should work with Congress to write a new Elementary and Secondary Education Act that will put FEA recommendations for comprehensive, systemic school improvement at the center.  FEA would be pleased to assist the Department in that process.

 

Monty Neill, Ed.D., Chair

FairTest, 15 Court Square, Suite 820, Boston, MA 02108; 857-350-8207 x 101; monty@fairtest.org

 

Gary Ratner, Esq., Chair, Committee on Capacity-building

Citizens for Effective Schools, 8209 Hamilton Spring Ct., Bethesda, MD 20817; 301-469-8000; gratner@rcn.com

 

Note: The Forum on Educational Accountability includes some of the organizations that have signed the Joint Organizational Statement on No Child Left Behind. Signers agree to the goals of the Joint Statement and seek to implement its recommendations. Additional statements made by FEA reflect this commitment, but may not reflect all individual positions taken by signatories.

         

Appendix 1: Joint Organizational Statement on NCLB, with list of signing organizations.

 

Appendix 2: Empowering Schools and Improving Learning, with list of signing organizations.

Joint Organizational Statement on No Child Left Behind (NCLB) Act

With list of 151 signers

 

The undersigned education, civil rights, religious, children’s, disability, civic and labor organizations are committed to the No Child Left Behind Act’s objectives of strong academic achievement for all children and closing the achievement gap. We believe that the federal government has a critical role to play in attaining these goals. We endorse the use of an accountability system that helps ensure all children, including children of color, from low-income families, with disabilities, and of limited English proficiency, are prepared to be successful, participating members of our democracy.

 

While we all have different positions on various aspects of the law, based on concerns raised

during the implementation of NCLB, we believe the following significant, constructive

corrections are among those necessary to make the Act fair and effective. Among these concerns are: over-emphasizing standardized testing, narrowing curriculum and instruction to focus on test preparation rather than richer academic learning; over-identifying schools in need of improvement; using sanctions that do not help improve schools; inappropriately excluding low-scoring children in order to boost test results; and inadequate funding. Overall, the law’s emphasis needs to shift from applying sanctions for failing to raise test scores to holding states and localities accountable for making the systemic changes that improve student achievement.

 

Recommended Changes in NCLB

 

Progress Measurement

 

1.      Replace the law's arbitrary proficiency targets with ambitious achievement targets based on rates of success actually achieved by the most effective public schools.

 

2.      Allow states to measure progress by using students’ growth in achievement as well as their performance in relation to pre-determined levels of academic proficiency.

 

3.      Ensure that states and school districts regularly report to the government and the public their progress in implementing systemic changes to enhance educator, family, and community capacity to improve student learning.

 

4.      Provide a comprehensive picture of students' and schools' performance by moving from an overwhelming reliance on standardized tests to using multiple indicators of student achievement in addition to these tests.

 

5.      Fund research and development of more effective accountability systems that better meet the goal of high academic achievement for all children.

 

Assessments

 

6.      Help states develop assessment systems that include district and school-based measures in order to provide better, more timely information about student learning.

7.      Strengthen enforcement of NCLB provisions requiring that assessments must:

·        Be aligned with state content and achievement standards;

·        Be used for purposes for which they are valid and reliable;

·        Be consistent with nationally recognized professional and technical standards;

·        Be of adequate technical quality for each purpose required under the Act;

·        Provide multiple, up-to-date measures of student performance including measures that assess higher order thinking skills and understanding; and

·        Provide useful diagnostic information to improve teaching and learning.

 

8.      Decrease the testing burden on states, schools and districts by allowing states to assess students annually in selected grades in elementary, middle schools, and high schools.

 

Building Capacity

 

 9.     Ensure changes in teacher and administrator preparation and continuing professional development that research evidence and experience indicate improve educational quality and student achievement.

 

10.    Enhance state and local capacity to effectively implement the comprehensive changes required to increase the knowledge and skills of administrators, teachers, families, and communities to support high student achievement.

 

Sanctions

 

11.    Ensure that improvement plans are allowed sufficient time to take hold before applying sanctions; sanctions should not be applied if they undermine existing effective reform efforts.

 

12.    Replace sanctions that do not have a consistent record of success with interventions that enable schools to make changes that result in improved student achievement.

 

Funding

 

13.    Raise authorized levels of NCLB funding to cover a substantial percentage of the costs that states and districts will incur to carry out these recommendations, and fully fund the law at those levels without reducing expenditures for other education programs.

 

14.    Fully fund Title I to ensure that 100 percent of eligible children are served.

 

We, the undersigned, will work for the adoption of these recommendations as central structural changes needed to NCLB at the same time that we advance our individual organization’s proposals.

 

Advancement Project

American Association of Colleges for Teacher Education
American Association of School Administrators
American Association of School Librarians (AASL), a division of the American Library Association (ALA)

American Association of School Personnel Administrators (AASPA)
American Association of University Women

American Baptist Women's Ministries

American Civil Liberties Union
American Counseling Association
American Dance Therapy Association

American Federation of Labor – Congress of Industrial Organizations (AFL-CIO)
American Federation of School Administrators (AFSA)
American Federation of State, County and Municipal Employees (AFSCME)

American Federation of Teachers (AFT)

American Friends Service Committee (AFSC)

American Humanist Association

American Music Therapy Association

American Occupational Therapy Association
American Speech-Language-Hearing Association

American School Counselor Association

Americans for the Arts
Annenberg Institute for School Reform
Asian American Legal Defense and Education Fund (AALDEF)

Asian Pacific American Labor Alliance
ASPIRA
Association for Supervision and Curriculum Development
Association of Community Organizations for Reform Now (ACORN)

Association of Education Publishers
Association of School Business Officials International (ASBO)

Association of Teacher Educators

Big Picture Company

Business and Professional Women/USA
Center for Community Change
Center for Expansion of Language and Thinking

Center for Parent Leadership

Center for Policy Alternatives

Change to Win

Children's Aid Society
Children's Defense Fund

Christians for Justice Action--UCC 

Church Women United

Citizens for Effective Schools

Coalition for Community Schools

Coalition of Essential Schools
Commission on Social Action of Reform Judaism

Communities for Quality Education

Consortium for School Networking
Council for Children with Behavioral Disorders
Council for Exceptional Children

Council for Hispanic Ministries of the United Church of Christ
Council for Learning Disabilities

Council of Administrators of Special Education, Inc.
Cross City Campaign for Urban School Reform

Disciples Center for Public Witness
Disciples Home Missions of the Christian Church (Disciples of Christ)

Disciples Justice Action Network (Disciples of Christ)
Division for Learning Disabilities of the Council for Exceptional Children (DLD/CEC)

Education Action!

Education Law Center

Educate Not Incarcerate

Episcopal Church

Equal Partners in Faith

Evangelical Lutheran Church in America

Every Child Matters
FairTest: The National Center for Fair & Open Testing

Forum for Education and Democracy

Gay, Lesbian, Straight Education Network (GLSEN)

Gender Public Advocacy Coalition
Hmong National Development

Holmes Partnership

Indigenous Women's Network

Institute for Language and Education Policy
International Reading Association

International Society for Technology in Education (ISTE)
International Technology Education Association

Japanese American Citizens League

Jobs with Justice
Learning Disabilities Association of America
League of United Latin American Citizens (LULAC)

Mental Health America
Ministers for Racial, Social and Economic justice of the United Church of Christ
National Association for the Advancement of Colored People (NAACP)
NAACP Legal Defense and Education Fund (LDF)

National Alliance of Black School Educators
National Association for Asian and Pacific American Education (NAAPAE)
National Association for Bilingual Education (NABE)
National Association for the Education and Advancement of Cambodian, Laotian and Vietnamese Americans (NAFEA)

National Association for the Education of African American Children with Learning Disabilities (NAEAACLD)

National Association of Federally Impacted Schools (NAFIS)
National Association of Pupil Service Administrators

National Association of School Nurses
National Association of School Psychologists

National Association of Secondary School Principals (NASSP)
National Association of Social Workers

National Baptist Convention, USA (NBCUSA)

National Coalition of ESEA Title I Parents

National Coalition for Asian Pacific American Community Development

National Coalition for Parent Involvement in Education (NCPIE)

National Conference of Black Mayors

National Council for Community and Education Partnerships (NCCEP)
National Council for the Social Studies
National Council of Churches
National Council of Jewish Women
National Council of Teachers of English
National Education Association

National Education Taskforce

National Federation of Filipino American Associations

National Forum on Information Literacy
National Indian Education Association
National Indian School Board Association
National Korean American Service & Education Consortium (NAKASEC)
National Ministries, American Baptist Churches USA

National Pacific Islander Educator Network

National Parent Teacher Association (PTA)

National People's Action
National Reading Conference
National Rural Education Association
National School Boards Association

National School Supply and Equipment Association

National Science Teachers Association

National Superintendents Roundtable

National Training & Information Center
National Urban League
Native Hawaiian Education Association

Network of Spiritual Progressives

Organization of Chinese Americans
People for the American Way

PFLAG National (Parents, Families and Friends of Lesbians and Gays)
Presbyterian Church (USA)

Progressive National Baptist Convention

Promise the Children

Protestants for the Common Good

Protestant Justice Action

Public Education Network

Rethinking Schools
Rural School and Community Trust
Service Employees International Union
School Social Work Association of America
Social Action Committee of the Congress of Secular Jewish Organizations

Sikh American Legal Defense and Education Fund
Southeast Asia Resource Action Center (SEARAC)
Stand for Children
Teachers of English to Speakers of Other Languages, Inc. (TESOL)
United Black Christians of the United Church of Christ

United Church of Christ Coalition for Lesbian, Gay, Bisexual & Transgender Concerns
United Church of Christ Justice and Witness Ministries

United Methodist Church, General Board of Church and Society

USAction
Women's Division of the General Board of Global Ministries, The United Methodist Church
Women of Reform Judaism

Young Men's Empowerment Network

Empowering Schools and Improving Learning:

A Joint Organizational Statement on the Federal Role in Public Schooling

 

Vision of Public Education

 

All children deserve the opportunity to succeed in high quality public schools. High quality public schools are schools where students and adults form active communities of learners, evidenced by a culture that is both supportive and challenging. They attend to the whole child and meet the individual needs and support the strengths of each child, including English language learners, students with disabilities, and students of diverse racial, cultural and socioeconomic backgrounds. They are well-resourced and well-staffed by qualified professionals, provide classes of a size that ensures individualized instruction and attention to each child's learning needs, and are safe, healthy and modern. Students attending these schools demonstrate ongoing progress toward important learning outcomes as indicated by a variety of sources and kinds of evidence, including classroom work, different types of assessments of progress and mastery, and grade promotion and graduation rates.

 

Important learning outcomes must include basic and higher order content knowledge and thinking skills in and across subject areas. Schools must have programs to provide all students with a coherent and intellectually challenging curriculum that includes 21^st century critical thinking, problem solving, and high-level communication skills, and that ensures deep understanding of content. To achieve these outcomes, schools must be culturally sensitive and address different learning styles and interests through curriculum and instruction that fosters student engagement, promotes creativity, and addresses diverse experiences and needs. Schools also will collaborate with families and communities to meet the needs of the whole child -- cognitive/intellectual, social, civic, emotional, psychological, ethical, and physical -- while preparing them for successful citizenship in a multi-cultural world.

 

The federal government has a limited but important role to play in realizing this vision of high quality schooling for all. It should help provide the tools and resources to empower schools where students are underserved by partnering with schools, districts, states, communities, and organizations to ensure all schools are of higher quality. To ensure successful learning outcomes, the federal government also must take a strong role in addressing issues complementary to education, including health care, housing, employment, income, and community fragmentation.

 

Key Components of the Federal Role

 

To effectively assist in empowering schools and improving learning, the federal government must overhaul the Elementary and Secondary Education Act (ESEA, currently authorized as the No Child Left Behind Act, NCLB), especially Title I. The new law should be consistent with the Joint Organizational Statement on No Child Left Behind and this document. In particular, rather than making accountability the central component of ESEA, the law must make capacity-building central, with accountability as one component that serves the improvement process. In making this change, the federal government must provide assistance and develop guidelines, but not manage the details of implementation, as it does under NCLB.

 

Major changes in the federal role in public education are needed in three areas: empowering schools so they can better ensure strong learning outcomes for all students; providing more adequate and equitable resources for all students; and developing an accountability system that focuses evaluation on students' opportunities to learn, processes of systemic school improvement, and student learning outcomes based on multiple forms of evidence. Adopting these changes will reshape federal, state and local relationships. The following are key components of the federal role in ensuring high-quality learning outcomes for all students.

 

Empowerment for Improvement

 

1. Improvement plans and actions: Every ESEA Title I school and district shall engage in a planning process with the participation of school personnel, parents, and the community the school serves. Planning will result in strategies to provide equitable, high quality education, including implementation of the systemic changes in school practices detailed below. Plans shall address cultural diversity and the specific needs of any special populations, such as English language learners, students with disabilities, and students with gifts and talents. Schools and districts will implement the plans, and districts will monitor plan implementation, provide support as needed, and intervene should implementation falter. States, in turn, will monitor school districts.

 

2. Collaboration: Funds for Titles I and II shall be used to enable school-based educators, with support from districts and the state, to work collaboratively to improve curriculum, instructional practices, and assessments; better meet the needs of individuals and groups of students and address barriers to learning; and ensure the continuing professional development of all education personnel.

 

3. Professional learning: As an integral component of educational improvement and ongoing school practice, professional development funds shall be used to meet local educational needs through professional collaboration, mentoring, career ladders, and appropriate professional activities and strategies to work with families and communities. Schools may use a portion of these funds to engage outside expertise and other agencies to assist their staff. To adequately support professional learning, a funding stream in an amount equal to 20% of Title I funds shall be used for this purpose, with states providing a matching amount. State and local education agencies shall jointly identify appropriate sources of funding and work with schools to determine the best uses for those funds.

 

4. Parental and family engagement and support: Because parental and family engagement in schools and parental and family support of student learning at home are vitally important to school quality and student success, a funding stream in an amount equal to five percent of Title I funds shall be provided for these purposes. These funds, determined jointly by state and local education agencies in consultation with schools, shall be used to strengthen parent involvement in schools, including translation services and transportation and child care, so that parents can meaningfully participate in school improvement activities. Equally, these funds must be used to build parents' capacity to assist their children's learning through adult literacy, English as a second language, and culturally sensitive parenting skills programs. These funds also shall be used to mentor students whose parents are unable to provide adequate support.

 

5. Assessment: ESEA shall provide funds to enable schools, districts, and states to develop high quality formative and summative assessments in the various subjects, as well as other indicators to provide evidence of improved student learning and school quality. These assessments must be based on state standards and the local curriculum, assess higher order thinking and other 21^st century skills, and provide multiple approaches for students to demonstrate their learning. The primary use of these assessments is to improve instruction and enable teachers to better address each student's strengths and needs. These funds may be used jointly with the funds authorized for collaborative activities and professional development in the school and school district, provided those activities include developing assessments and indicators and improving educators' skills in using them. Since the federal government has previously provided substantial funds for the improvement of statewide standardized tests, Congress should continue modest funding for those activities, which also may include the development of tasks and projects (performance tasks) that states, districts, and schools can use. In addition, Congress shall provide funds for the use of universal design principles to create large-scale and classroom-based assessments that are appropriate for all students, including English language learners and students with disabilities. 

 

6. Research and dissemination: ESEA shall increase support for research and dissemination. Such support shall include gathering information about successful approaches to ensuring high quality learning outcomes and evaluating the conditions under which such programs are likely to succeed. Information also shall be gathered about high-quality curriculum and assessments that can be utilized locally, on a voluntary basis, and made available on electronic networks or in print. ESEA shall create a new national sample within the National Assessment of Educational Progress (NAEP) or another appropriate process that will employ extended performance tasks (including electronic variations) based on up-to-date evidence of how individuals learn. These tasks shall be designed to indicate students' ability to understand and apply knowledge and higher order thinking in and across subject areas. Knowledge gained through this program shall support development of performance tasks that may be incorporated into state, district, and classroom assessments.

 

Improved Funding to Enhance Equity and Adequacy

 

7. Equity and adequacy: The goal of the federal government shall be to ensure that all children have equitable access to a high-quality education and achieve high-quality learning outcomes. The federal government shall substantially increase education funding and ensure fair distribution of federal funds across the states; enforce the requirement that states use Title I funds to supplement, not supplant, state and local funding; ensure collection of data that can identify, within schools and communities, any key inequities that affect learning outcomes; and, work with states to help them move quickly toward greater equity and adequacy of resources. Federal, state, and local governments together must contribute to meeting this goal. While each step poses complex issues to resolve, rapid progress toward the goal must be achieved. It is a state responsibility to ensure that resources adequate to produce high-quality learning outcomes for all students are available to each school and are used appropriately. The federal government shall conduct studies to determine the costs of providing a high-quality education to all students.  

 

8. Federal funding: Through the ESEA and the appropriations process, Congress shall continue to provide assistance by supplementing the local and state funds available to schools and districts with concentrations of low-income and diverse students. Congress shall fully fund ESEA Title I and the Individuals with Disabilities Education Act (IDEA) Part B, in accord with current formulas, and shall make both ESEA Title I and IDEA Part B mandatory federal budget items. The increased mandatory allocations would more than double the amounts now provided by these laws. The federal government shall fund a significant portion of the cost of implementing the systemic school improvement changes described in this document and in the Joint Organizational Statement on NCLB.  Congress also shall appropriate substantially increased sums to better meet the needs of students served under the other Titles and Parts of ESEA and IDEA. In addition, funding shall be provided for school modernization programs.

 

9. Comprehensive indicator systems: ESEA shall provide for the development of comprehensive statewide indicator systems to provide evidence on such school factors as the equitable and sufficient distribution of qualified staff, including but not limited to teachers and supervisory staff; class size; buildings, libraries, technology, and other material resources; school climate; parental engagement; and family and community support for learning. Such indicator systems will also provide evidence about learning outcomes, such as high school graduation; college readiness, enrollment, and progress; employment; and civic participation. In addition, the system shall collect information on out-of-school factors including comprehensive health care, housing, employment and income, and community safety. Collection of these indicators will be a collaborative activity involving relevant state and federal departments and agencies. This evidence will help improve opportunities to learn and support school improvement efforts.

 

10. Opportunity to learn: Each state shall develop strategies for providing resources to overcome inequities and inadequacies identified by the indicators. The goal is to provide resources sufficient to ensure every child can participate in high quality learning experiences. Each state shall report biannually on the indicators, strategies, and progress to the public. The federal government shall provide a biannual report to the public as to status and progress on these indicators across the states.

 

Accountability for Improvement and Learning Outcomes

 

11. Information systems: To improve schools and student learning outcomes, states shall construct information systems that incorporate the indicators and assessments described in this document. States may use a federally designed model or their own. These systems will enable schools, districts, and states to utilize information and evidence for improvement activities. Such information also can be used for monitoring and publicly reporting on schools.

 

12. Accountability for school improvement and learning outcomes: With the primary focus on empowering schools and improving learning, ESEA shall establish several forms of accountability with identified consequences. Evidence on the learning progress of all students,   using multiple sources and types of evidence in the various subjects, including district and school-based information, must be gathered and reported on a disaggregated basis. Equally important, data on implementation of systemic school improvement changes (as described in preceding paragraphs), obstacles encountered and steps taken to overcome them, outcomes, and proposed steps for further improvement must be gathered and publicly reported. Each school will provide an opportunity for its teachers and other staff, parents, and the community to review, discuss, and provide advice on the reports.

 

13. Rate of improvement: Evidence of a school's learning outcomes shall be evaluated in light of expected statewide rates of improvement. The expected rates of improvement, to be specified by a formula in ESEA, must be rooted in actual levels and rates of improvement that are attained by the more successful Title I schools and for which evidence indicates that these rates can be sustained over time. Aspects of improvement can be combined into a comprehensive indicator system with a composite expected rate of improvement.

 

14. Assistance and intervention: ESEA shall not mandate an explicit set of school or district "governance" changes, nor shall it overturn contract provisions for local personnel. ESEA will provide a funding stream to states in an amount equal to two percent of Title I funds to assist districts in systemic change. However, districts and states are responsible for providing assistance where evidence of school quality--including the level of learning outcomes, rate of improvement in outcomes, or success in implementing systemic changes--demonstrate that a school needs assistance and interventions. The nature and extent of assistance should respond to clearly identified needs. In determining the nature and extent of assistance, funding and resources, including teachers and administrators as well as the instructional program, must be addressed. Should a school be deemed chronically inadequate and unable to improve, the district and then the state are obligated to provide additional intensive interventions.

 

Conclusion

 

Incremental changes will not fix NCLB's serious flaws and will not enable all students to succeed. To ensure high-quality learning outcomes, Congress must overhaul ESEA, particularly Title I, to empower schools to improve, focus on improved assistance, help ensure funding equity and adequacy, redefine accountability, and reshape the federal relationship with states and districts.

 

The federal government must provide strong leadership through supportive policies and sufficient funding. The systemic school improvement and accountability changes outlined in this document are interrelated changes that reinforce each other and must be implemented together. They are not a menu from which to pick and choose. Experience and research show that these are among the most critical changes that states and localities can make to improve learning. The federal government therefore must provide strong financial support to these efforts and more broadly work to ensure all schools have adequate resources to educate all their students well.

 

We therefore call on Congress and the President to follow the guidance found in the Joint Organizational Statement on NCLB and the initiatives described above.

 

Signers of Empowering Schools and Improving Learning

(84)

 

Advancement Project

American Association of Colleges for Teacher Education (AACTE)

American Association of School Librarians

American Association of University Women (AAUW)

American Counseling Association

American Dance Therapy Association

American Federation of School Administrators (AFSA)

American Music Therapy Association

American Occupational Therapy Association

American School Counselor Association

American Speech-Language-Hearing Association

Americans for the Arts

Annenberg Institute for School Reform

Asian American Legal Defense and Education Fund (AALDEF)

Asian Pacific American Labor Alliance (APALA)

Association of Community Organizations for Reform Now (ACORN)

ASPIRA

Big Picture Company

Center for Expansion of Language and Thinking

Center for Parent Leadership

Children's Aid Society

Christians for Justice Action, United Church of Christ

Citizens for Effective Schools

Coalition of Essential Schools National

Coalition for Community Schools

Communities for Quality Education

Council for Children with Behavioral Disorders

Council for Exceptional Children

Council for Learning Disabilities

Council of Administrators of Special Education, Inc (CASE)

Disciples Center for Public Witness

Disciples Home Missions of the Christian Church (Disciples of Christ)

Disciples Justice Action Network (Disciples of Christ)

Division for Learning Disabilities of the Council for Exceptional Children

Education Action!

Education Law Center

Equal Partners in Faith

FairTest (National Center for Fair & Open Testing)

Holmes Partnership

Institute for Language and Education Policy

International Technology Education Association (ITEA)

League of United Latin American Citizens (LULAC)

Learning Disabilities Association of America (LDA)

Mental Health America

National Alliance of Black School Educators (NABSE)

National Association for Asian and Pacific American Education (NAAPAE)

National Association for the Education of African American Children with Learning Disabilities

National Association of Federally Impacted Schools

National Association of Pupil Services Administrators (NAPSA)

National Association of School Nurses

National Association of School Psychologists (NASP)

National Association of Social Workers

National Coalition for Parent Involvement in Education (NCPIE)

National Coalition of ESEA Title I Parents

National Council for Community and Education Partnerships (NCCEP)

National Council for the Social Studies

National Council of Churches USA

National Council of Teachers of English

National Education Association (NEA)

National Education Task Force

National Federation of Filipino American Associations

National Forum on Information Literacy

National Indian Education Association

National Indian School Board Association

National Ministries, American Baptist Churches USA

National Pacific Islander Educator Network

National People's Action

National Science Teachers Association

National Superintendents Roundtable 

National Training & Information Center

Progressive National Baptist Convention

Protestants for the Common Good

Protestant Justice Action

Public Education Network

Rethinking Schools

Rural School and Community Trust

School Social Work Association of America

Sikh American Legal Defense and Education Fund (SALDEF)

Southeast Asia Resource Action Center (SEARAC)

United Black Christians of the United Church of Christ

United Church of Christ Coalition for Lesbian, Gay, Bisexual & Transgender Concerns

United Church of Christ Justice and Witness Ministries

United Methodist Church, General Board of Church and Society

U.S. Action

 

Published by the Forum on Educational Accountability, www.edaccountability.org.