BOE approves changes to accountability system
The MTA submitted public comment against the changes approved October 24. In addition, MTA is part of a coalition called MassPartners for Public Schools, composed of associations representing teachers, administrators, school committee members and parents. MassPartners also submitted testimony against the changes.
Comments on Proposed Amendments to Regulations 603 CMR 2.00 -- Underperforming Schools and School Districts
Submitted by Anne Wass, President, Massachusetts Teachers Association
September 15, 2006
The Massachusetts Teachers Association wishes to reaffirm and reiterate the objections separately submitted by MassPartners for Public Schools to the Proposed Amendments to Regulations 603 CMR 2.00. We offer the comments below to highlight the issues that are of particular concern to our 100,000 members.
The proposed regulations were developed in a process that did not allow professional debate and discussion. It is vitally necessary that opportunities for collaboration and consensus-building be employed to solve the challenges faced by our students and our schools. Not surprisingly, the regulations do not provide for any meaningful participation by educators and do not support the collaboration essential for effective school improvement.
MTA believes that the proposed regulations are in direct conflict with existing state law in at least three critical respects: (1) The authority to "intervene" in struggling schools by closing them down or giving their buildings and assets away to another school district or to a private entity has not been conferred by the Education Reform Act. (2) The Act provides schools a period of time to engage in improvement efforts. The proposed regulations violate that law by denying schools the time guaranteed by statute to implement improvement strategies. (3) The proposed regulations list "corrective actions" that schools must include in their improvement plans. Some of these are subjects of collective bargaining -- for example, extending the school day or school year. Such actions that encroach on statutory collective bargaining rights are unlawful.
The proposed regulations adopt the discredited federal method for labeling and sanctioning schools based on test scores. In addition, they authorize the imposition of federal sanctions on schools that do not receive federal money. Massachusetts public schools have a long history of high performance, but, each year, more schools are being labeled as underperforming under the federal system. Just this fall, 617 schools -- 37% of all schools in Massachusetts -- were negatively labeled under the federal system. Based on these federal determinations, we estimate that over 140 schools will be subject to the sanctions contained in the proposed regulations on the day they go into effect with more to come every year. Over time, analysts predict that the vast majority of schools in Massachusetts will be labeled as inadequate, including many that are recognized for providing an high quality education.
Perhaps most importantly, the proposed regulations abandon the State's responsibility to provide schools with the assistance that they need. Their essential components impose sanctions more quickly and on more schools than under current practice. The proposal relies on coercion -- using threats of closure, transfer of governance to another school district or conversion to a charter school to effect improvement in student learning. The Board and Department of Education have made it clear that there are no new programs of assistance and there will be no additional resources available to assist schools. This is clearly not a formula designed to help schools improve.
Finally, MTA has already requested that the Department not use the term, "Priority School" to label schools as underperforming. The National Education Association created the "Priority Schools Initiative" in 2001. MTA currently is engaged with a number of low-performing schools in Priority Schools work. "Priority Schools" has come to mean a collaborative, data-driven, school improvement and professional development program. Using the same name to label schools as underperforming will undermine our work. Consequently, we urge the Board of Education to stop using the term "Priority Schools."
Struggling schools do not need more regulation; nor do they need more threats. They do need more effective help. The current school and district accountability system is fragmented, bureaucratic, non-collaborative and authoritarian. Educators have been forced to develop improvement plans that they do not believe have merit. Not surprisingly, this system has been largely ineffective. Despite state intervention and "assistance," very few schools have managed to emerge from their underperforming status in the past six years. Some schools have been waiting almost a year to have their school improvement plans approved. Almost all of the 45 schools that were removed this year from the federal list of schools in need of improvement reached their targets without the "assistance" of the state accountability system. The three districts currently receiving the most attention from DOE regulators had between one-third and 100% of their schools negatively labeled in the most recent federal list.
The proposed system offers only more of the same. The Board of Education should therefore not approve the regulations. The MTA calls upon the Board to develop a sound, constructive approach to providing assistance to at-risk schools. Rather than developing regulations that will further alienate professional educators, we urge the Board to work with educators. We have the experience, expertise and will to improve struggling schools. The Board must not continue with a regulatory program that excludes educators from contributing to the improvement of our public schools.