Kentucky has the chance to improve our school accountability system in dramatic ways, but it may require challenging federal regulations that place cumbersome limits on what states are allowed to do under the new Every Student Succeeds Act (ESSA).
ESSA, a reauthorization of the federal No Child Left Behind (NCLB) Act, passed Congress and was signed by the President late last year, and promised to give states far more flexibility in measuring school performance and holding educators accountable for outcomes. But the U.S. Department of Education recently released proposed regulations that would limit state flexibility in key ways. Those regulations are now up for public review and comment through the end of July.
As a new member of the Kentucky Board of Education, I'll have a duty in helping approve Kentucky's new accountability system. The Board and the Kentucky Department of Education will be authoring a collective response to the ESSA regulations, and I believe we'll push back hard against key provisions. As an individual citizen, I have concerns about two areas of the regulations in particular that would hamper our options. I urge readers to become familiar with these regulations and make your own voices heard. My concerns have to do with 1) requiring schools to receive a single, summative score that factors in all accountability measures, and 2) requiring "proficiency" as the only measure of academic achievement.
Problem 1: A single summative score
First let me say that I believe strongly in school accountability. As I wrote recently, the best thing to come out of the otherwise-flawed NCLB regime was the exposure of unacceptable, historic achievement gaps and a collective commitment to addressing those educational disparities. Testing has its place, and should still figure prominently in how we measure school success (as it does under the ESSA law itself, which still requires reading and math tests in grades 3 through 8 and two assessments of science).
But no single measure of achievement can convey meaningful information about what a school does well and what it does not. As it should, Kentucky's current accountability system uses multiple measures, including student proficiency rates on test scores, a measure of the school's progress toward closing achievement gaps, a measure of how much student learning grew over the year, and other metrics.
No matter how you create the formula, though, when you try to mash all those measures into a single number, all the important information is lost. That is especially true when you rank order schools based on that single number and then label them based on their achievement compared to other schools. As a result, we get schools that are labeled as "proficient" or even "distinguished" but have glaring and unacceptable achievement gaps. Schools' real strengths - and weaknesses - are masked.
In contrast, Kentucky Education Commissioner Stephen Pruitt has talked about creating a "dashboard" of achievement measures, so that parents or the public can see at a glance how a given school is doing relative to various metrics. I like this idea, but such an approach would be greatly hampered if we are required to boil all of those various measures down to a single number, especially if the system includes already-problematic measures we are required to use by Kentucky law, like the program review process for non-tested subject areas (the Commissioner also has a task force working on this problem).
Problem 2: Proficiency rates
A second concern about the new ESSA regulations, which is far more technical in nature, is the stipulation that student achievement can only be based on "proficiency" rates. Proficiency is determined based on whether a student achieves a certain score or higher on a test, and is usually reported as the percentage of students who achieve that score. That all sounds good, and it is to an extent, but there may be far better ways to judge whether a school is being successful.
Under a proficiency-based system, schools are incentivized to place all of their energy into "bubble kids" who are on the cusp of proficiency, and may neglect students who could make great progress, but still not quite reach the magic cut score. The school that is growing students more, whether they be traditionally high-performing or traditionally low-performing students, is arguably better than a school that just has a bunch of kids who test at the magic proficiency number every year.
So we should be looking at accountability systems that are based primarily on student growth or a formula that reflects how all students improve relative to scale scores rather than simple proficiency. For a look at how these systems work, and other creative ideas about school accountability, see the recent accountability design competition sponsored by the Fordham Institute. Such approaches are not exactly simple (Fordham authors Michael Petrilli and Brandon Wright call this approach the Scholar's Paradise), but they may be infinitely more fair and accurate, and states should be able to consider such options.
But under the proposed regulations, states will be unable to use growth and scale measures, and that's at least as problematic, if not more so, than the insistence that schools receive a summative performance score.
I look forward to working with the Commissioner and other state Board members to push back against these proposed regulations (the Commissioner has already done an excellent job challenging the U.S. Department of Education's insistence that we use an intellectually dishonest measure of student science achievement under the current accountability rules). In the meantime, please submit your own comments and feedback to the U.S. Department of Education regarding these new regulations. Go here to review the regulations and select "Comment Now!" to submit your comments.
If you share my specific concerns, you might note that you are "opposed to rules that would require states to use a summative score for school performance" and that you are "opposed to the rule that student achievement must be a measure of proficiency." If you feel confident to do so, describe the possibilities for Kentucky's accountability system under ESSA and how those improvements would be hindered by the rules as they are currently written.
I also recommend that you contact members of Kentucky's U.S. Congressional delegation with concerns.
I'll post more on this topic as it unfolds.
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