Implementing the requirement that districts create Student Impact Ratings for educators ground to a halt on Feb. 28, 2017, as state officials amended the regulations governing those policies. The MTA is opposed to the new regulations, which were proposed by Commissioner of Education Mitchell Chester and approved by the Board of Elementary and Secondary Education.
In 2010, Massachusetts adopted regulations 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 arose 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.
BESE Approves Revised Regulations
The changes to educator evaluation regulations approved by the BESE eliminate the separate Student Impact Rating and replace it with a new Student Learning Indicator in Standard 2 for teachers (Standard 1 for administrators).
In other words, instead of simply repealing the Student Impact Rating requirement, the new regulations create a similar requirement on the summative rating side of the educator evaluation system.
The MTA will be providing additional information about the significance of the regulatory changes and their implications for collective bargaining.
Memo from Mitchell Chester concerning the new amendment to the regulations on Educator Evaluation: On the Desktop – March 10, 2017
Why the DESE-Developed Alternative Is Worse
Under the 2010 regulations, teachers and administrators received two separate ratings, a summative rating and a Student Impact Rating. The regulations established a timeline of staggered implementation, with districts adopting a process for determining a summative rating first and then adopting the process for determining the Student Impact Rating.
The amended regulations eliminate the separate Student Impact Rating. However, this approach will retain evidence of student learning based on multiple measures, including “common assessments” and statewide student growth measures, as an important component of the summative performance rating. In addition, the amendments also include technical changes unrelated to the Student Impact Rating, such as removing provisions that describe timelines that have expired. Full text of the regulations with the amendments red-lined are here.
New names, same problems. Instead of District-Determined Measures, the new regulations call 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,” the new regulations rate their “expected impact” as meeting or exceeding anticipated student learning gains on multiple measures of student learning, growth, and achievement. The bottom line is that the new regulations still use test scores in a way that is invalid, unreliable and unhelpful.
Continued focus on test results. The new system continues 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.
DDM Mandate Repeal Effort
The MTA worked with other educators to repeal the Student Impact Rating and DDM requirements. Among other concerns, we 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.
The MTA and many members submitted public comments against the new regulations in January 2017. Read more about the MTA's opposition:
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.
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
The 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.