Be Heard! Comment on proposed DDMs/Impact Rating Regs

How to Submit Public Comment

Take action

SUBJECT LINE: The subject line should say something like: Comments against Proposed Amendments to 603 CMR 35.00. (Or: Comments against proposed changes to ed eval regs)

BE CLEAR: At the outset, make it clear that you are opposed to both the current Student Impact Rating system and Commissioner Mitchell Chester’s proposal to replace it with a very similar Student Learning Indicator, which would be embedded in Standard 2 of an educator’s summative evaluation. This change would make a bad problem even worse.

USE YOUR OWN WORDS: Please use your own words and describe your own experiences in explaining reasons for your opposition. This also presents an opportunity for you to say what you think about the evaluation system and describe what changes you would like to see.

ADDITIONAL COMMENTS: Describe what you think should happen instead. Some suggestions include:

  • Eliminate the Student Impact Rating altogether, but keep the rest of the system the same.
  • Do a major overhaul of the entire educator evaluation system. Explain what you think should be changed and why.
  • Eliminate the requirement that districts create DDMs or “common assessments,” but encourage educators and their evaluators to look at and discuss student work with a goal of determining whether there are great practices and lessons that could be shared and/or ideas about changes needed to make sure students are learning and growing.

DEADLINE: Submit your comments before January 27 to

MTA members are urged to submit public comment against proposed changes to the educator evaluation system. The proposal fails to address the most significant problems caused by the invalid Student Impact Rating system and it would continue the misguided practice of judging educators based on student test scores. Even worse, it would increase the negative impact of this rating by moving it to Standard 2, informing the educator’s overall summative rating. In other words, student test scores could prevent an educator from receiving an overall rating of “proficient.”

ACT NOW! It is important that the Department of Elementary and Secondary Education receive a lot of comments from educators against the proposed changes to the Student Impact Rating section of the educator evaluation. Comments written in your own words have much greater impact than boilerplate language.

Please submit your comments before January 27 to

Key points raised by the MTA:

  • New names, same problems. The commissioner’s proposal is extremely similar to what already exists, with new terminology. Instead of “District-Determined Measures,” it calls for “common assessments.” (Both systems also include the use of Student Growth Percentiles.) Instead of rating educators’ impact on student learning as “low, moderate or high,” it would rate their impact as “less than expected” or “at least expected.” Educators are not fooled by this change in terminology. The bottom line is that it still uses 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 Student Learning Indicator is duplicative, confusing and a waste of time.

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