Background on proposed regulatory amendments


The Every Student Succeeds Act passed by Congress in 2015 ended the federal government’s ability to mandate the use of student test scores in local educator evaluation systems. The MTA and AFT Massachusetts have been working since then to eliminate the unworkable, invalid and time-consuming requirement that districts create a “student impact rating” for all educators based on District-Determined Measures and, where available, “growth” scores on standardized tests.

The unions were joined by the superintendents’ association in making the case against the current impact rating requirements. Education Commissioner Mitchell Chester responded to concerns by proposing a new system that is acceptable to the superintendents, but not to the unions. In fact, the MTA believes the new system is worse than the current regulations since it retains the requirement that districts use common assessments and growth scores to judge teachers, and moves that requirement to the high-stakes summative rating part of the evaluation system.

Details of Commissioner Chester’s proposal

DDMs graphic
  • The proposed regulations would eliminate the Student Impact Rating of low, moderate and high based on two to three years of data on District-Determined Measures and, where available, on Student Growth Percentiles.
  • The Student Impact Rating would be replaced by a “Student Learning Indicator” added to the evaluation rubric within Standard 2. The indicator would be based on whether an educator met or exceeded anticipated student learning gains.
  • Teachers involved in “direct instruction” must use “common assessments” (similar to District-Determined Measures) and/or Student Growth Percentiles, where available.
  • No individual ratings on an educator’s “impact on student learning” will be reported to the DESE.

Critique of proposed regulations

MTA and AFT MA continue to believe that the proposed regulations do not address the problems with the Student Impact Rating that have been identified by educators over the past five years. In most instances, the flawed elements of the current regulations have been replicated in the proposed regulations — just with different names.

Further, the proposal would allow invalid and unreliable student learning measures to count even more than they do now. While the current Student Impact Rating is separate from the summative rating, the new Student Learning Indicator is placed directly in Standard 2, where it can have a disproportionate impact on the educator’s summative evaluation.

A rating below Proficient on Standard 2 prevents an educator from receiving an overall Proficient rating. Using student test scores as the basis for such high-stakes ratings is methodologically unsound and educationally harmful.

If the BESE approves the regulations without significant modifications, MTA members will continue efforts at the state and local levels to oppose unworkable mandates that take time away from teaching and learning.

Letter from MTA and AFT Massachusetts on proposed regulations

MTA President Barbara Madeloni and AFT MA President Tom Gosnell sent a letter to the members of the BESE specifying objections to the proposed regulatory changes.

The main points of that letter are:

  • The problematic components of the current regulations are simply carried over to the proposed revisions — with new names.
  • The proposal creates even higher stakes around student learning outcomes by allowing invalid and unreliable student learning measures to count even more than they do now.
  • The proposal does not explain how the Student Learning Indicator relates to the existing Student Learning Goal, an ambiguity that will lead to confusion and implementation headaches.

Click here to read the letter.