Implementing the requirement that districts create Student Impact Ratings for educators has ground to a halt as state officials weigh amending the regulations governing those policies. Proposed new regulations are expected to be voted on by the Board of Elementary and Secondary Education on Feb. 28, 2017. The MTA is opposed to the current regulations and the proposed ones.
Massachusetts adopted regulations in 2010 requiring districts to use District-Determined Measures and state test score data to create Student Impact Ratings for all licensed educators as part of the educator evaluation system. These state regulations stemmed from federal mandates that evidence of student growth be a “significant” factor in educator evaluations. After strong opposition to this federal mandate across the country, Congress passed a law in 2015 — the Every Student Succeeds Act — repealing the requirement. However, the state regulations linking test scores to evaluations are still on the books.
The MTA has joined with other educators in working to repeal the Student Impact Rating and DDM requirements. Among other concerns, opponents believe that:
- Student test scores are an invalid and unreliable measure of educator quality.
- Developing and administering local tests solely or primarily for the purpose of evaluating educators is a waste of valuable teaching time.
- The mandate exacerbates the ongoing problem of an excessive focus on standardized testing in public education.
- Judging educators based on student test scores will make it more difficult to fill high-need teaching assignments and discourage collaboration.
DESE Develops Even Worse Alternative
New names, same problems. Instead of District-Determined Measures, the proposal calls for “common assessments.” (Both systems also require the use of Student Growth Percentiles.) Instead of rating the impact that educators have on student growth as “low, moderate or high,” it would rate their impact as “less than expected” or “at least expected.” The bottom line is that the proposed new regulations still use test scores in a way that is invalid, unreliable and unhelpful.
Continued focus on test results. The proposed new system would continue the emphasis on sanctions rather than support, and on test results over other measures of teaching and learning.
Duplicative and a waste of time. Student learning is already embedded in other sections of the evaluation system, most notably in the creation of Student Learning Goals. Creating another indicator based on student “outcomes” is duplicative, confusing and a waste of time.
Instead of simply repealing the Student Impact Rating requirement, Commissioner Mitchell Chester’s proposed new regulations create a similar requirement in the summative rating side of the educator evaluation system.
DDM Mandate Repeal Effort
The MTA and many members submitted public comments against the proposed new regulations in January 2017. Read more about the MTA's opposition to the proposed regulations:
More on the MTA's opposition to the proposed regulations:
Why the DDM Mandate Should Go
White paper authored by the MTA and AFT Massachusetts explaining why judging educators based on student test results is invalid and unproductive. The arguments made in this paper against the DDM mandate also apply to the proposed new regulations.
Background on DDMS and Impact Ratings
The requirement for using DDMs and MCAS growth scores in the educator evaluation system was initiated in 2010 in the Department of Elementary and Secondary Education’s application for federal Race to the Top grant funds. The DESE’s commitment to this strategy was reinforced in the state’s 2012 application for a waiver from No Child Left Behind, the federal education law that preceded ESSA.
The educator evaluation regulations containing the DDM requirement were approved in 2013. Under these regulations, at least two measures of educator effectiveness based on student outcomes must be developed for every licensed educator.
For those who teach English language arts and/or math in MCAS-tested grades, one of these DDMs must measure trends and patterns in their students’ Student Growth Percentiles. A trend must consist of at least two years of data.
Under ESSA, the federal government can no longer require states to mandate the use of student test scores in district educator evaluation systems. Thus, the state has a legal right to repeal the DDM/Impact Rating requirements. Until and unless the regulations are amended or repealed, however, the DDM mandate remains on the books.
MTA District-Determined Measures Guidance
MTA’s guidance on the development of District-Determined Measures provides a step-by-step approach that local associations and districts may use in identifying assessments currently in use that could be adapted or adopted as DDMs. This guidance also recommends a process for developing new DDMs. For each educator, there must be least two DDMs and at least two years of outcomes resulting in the educator’s impact on student learning rating as mandated by state regulations.
Educator Evaluation Framework Ratings
As part of the Educator Evaluation Framework, all licensed educators will receive a summative evaluation rating and an impact on student learning rating.
Student Learning Goal vs. Impact on Student Learning
Part of the five-step evaluation cycle, the student learning goal requires educators to complete a self-assessment as part of the educator plan.
Relevant State Statutes, Regulations and DESE documents
State Statutes and Regulations
- Chapter 150E is the state statute governing public-sector collective bargaining, requiring negotiation with respect to wages, hours, standards of productivity and performance, and any other terms and conditions of employment.
- Chapter 71, Section 38 governs school committees’ bargaining performance standards and establishes binding interest arbitration to resolve issues when parties are unable to reach agreement.
- Final Educator Evaluation Regulations adopted by the Board of Elementary and Secondary Education.
Memos Related to District-Determined Measures from the State Education Commissioner
Deeper DiveThe regulations are clear that District-Determined Measures must be grounded in the Massachusetts Curriculum Frameworks, Massachusetts Vocational Technical Education Frameworks or other relevant frameworks. The Massachusetts 2011 English Language Arts and Mathematic Curriculum Frameworks include all of the Common Core State Standards. District and Association leaders may find that the overarching shifts of the Common Core State Standards may provide significant guidance in mapping out how to do this work. Some helpful links include:
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MTA's Center for Education Policy and Practice worked with Holyoke public schools from January 2012 through June 2013 on full district implementation of the Educator Evaluation Frameworks, including the identification of district-determined measures. MTA and the Holyoke Public Schools presented this work at the Department of Elementary and Secondary Education's Spring Convening on Evaluation. Click here for a four-page review of this work.
NEA’s Teacher Evaluation: A Resource Guide for National Education Association leaders and staff.
QUESTIONS? Email us at DDMs@massteacher.org.