ACSA has submitted comments to U.S. Secretary of Education Margaret Spellings concerning proposed Title 1 regulations under No Child Left Behind.
ACSA’s comments center on 20 proposed changes to NCLB that could have an impact on California as early as the beginning of the 2008-09 school year. Chief among ACSA’s concerns is the perception this is a “shadow reauthorization” that does not require Congressional input before the Bush administration leaves office. ACSA recommends time would be better spent on true reauthorization of the Elementary and Secondary Education Act.
Some of the other issues include a new graduation rate, disaggregation of graduation rates by subgroups, mandated advocacy by LEAs to highlight the benefits of private tutors, shorter timelines to alert parents to school choice and supplemental educational services and possible changes to subgroup size, among many other topics. Following are highlights of ACSA’s comments:
Definition of graduation rates
The proposed regulation requires states no later than 2013-14 to use a uniform method of calculating graduation rates that is consistent with the definition agreed to by the National Governors Association. ACSA supports a uniform graduation rate. However, ACSA does believe all students should be counted in the graduation rate, including those who take longer than four years. We do not support switching for the short-term to a four-year freshman model that does not account for transfers or dropouts. There are multiple and complex reasons that some students will take longer than four years. ACSA does not support having those exceptions narrowly defined at the federal level, as federal officials are too far removed from the classroom and school site to understand the needs of individual students.
Students with disabilities in California have up to the age of 22 to graduate. Students who are in juvenile detention settings may be significantly below grade level and need more time. Students in alternative education will also need more time.
A recent court case settlement (Valenzuela v. O’Connell) requires schools to serve students who fail one or more parts of the CAHSEE for an additional two years after 12th grade in order to ensure they pass CAHSEE as a condition of high school graduation. Under the proposed temporary formula, these students would not be counted.
By 2011-12 California will have a sufficient longitudinal data system to calculate a graduation rate consistent with the NGA. In the meantime, ACSA opposes using the averaged freshman rate because California would end up with three separate definitions of graduation rates in the span of four years (current formula, freshman temporary formula, NGA formula). States should continue to retain their process so long as they are moving toward a longitudinal data system that can track students.
Disaggregation of grad rates
ACSA supports the disaggregation of graduation rates once the formula can be calculated to incorporate all graduates (including beyond four years) and California’s longitudinal data system is fully in place. In addition, the NGA formula must be fully implemented for at least two years to ensure comparable data is available. ACSA only supports use of disaggregation for the purposes of targeted intervention and instruction, not for punishment.
SES notice to highlight benefits
This proposed regulation would require schools and districts to highlight the benefits of socio-economic status in the eligibility notice to parents and make it clearly distinguishable from other communications with parents.
This is an excessive level of micromanagement in ACSA’s view, and requires public schools to become advocates for private tutoring companies. ACSA is concerned that because no research has created a direct link between private tutors and an increase in individual student academic achievement, this begins to cross over into advocacy for private tutoring.
While it is important to provide clear, concise information and ensure parents have choice, this regulation is unnecessary, as schools already notify parents of their choices.
Parent notification
Proposed regulations would require school districts to notify parents of eligible children regarding public school choice and SES, and provide their options no later than 14 days before the start of the academic year. Current federal law requires parents to be notified of school choice and SES no later than the first day of school. For California, this will unfairly penalize local school and district administrators who cannot control the release of data provided by the state concerning the status of schools and school districts as it relates to Program Improvement. Currently, California school districts receive this information Aug. 31 of each year. School calendars vary in the state from early to mid-August to early September for a traditional school calendar or as early as June or July for a year-round calendar. It is impossible to meet an arbitrary standard of two weeks, when the testing cycles and the testing contractor must have time to accurately report testing data.
The state must have the time to accurately calculate AYP with all the complexities given states by the U.S. DOE. An alternative would be to require those schools who will not exit PI to notify 14 days in advance; but for those schools or districts receiving their first PI notice, retain the first day of school requirement.