US Chamber of Commerce

In submitting a request for a NCLB waiver, a state educational agency (SEA) must “meaningfully engage and solicit input from diverse stakeholders and communities in the development of its request.” The application specifically says that “business organizations” are among these stakeholders. In further guidance to states, the department noted that “ideally, an SEA will solicit input from stakeholders … and will strengthen its request by revising it based on this input.”

A review of the first 11 waiver applications found that overall, while many states did a good job seeking input from many constituencies, they did a relatively poor job of showing true engagement and input from the business community. In most cases where the business community was listed as among the stakeholders asked to provide input, there were limited—if any—details of the input or any indication that such input was considered as part of the revisions to applications.

Moving Forward

For the business communities in the 11 states that have submitted applications, it’s not too late to express these concerns directly to the Department of Education. The department will probably make final decisions on these applications beginning in late January. However, there is also likely to be a rolling approval process over the course of many weeks, or even months, for those states that do not receive initial approval (and there are likely to be many). This too, will be an opportunity for the business community to voice opinions.

There are 28 additional states poised to submit applications by the February 21 deadline. Many of these states have already posted drafts of their applications for review on their state education website and are in the process of seeking input directly from stakeholders. It is important for the business community to take advantage of this outreach and provide comments and, when necessary, actively seek changes to these plans prior to their submission to the Department of Education.

Reviewing Applications

Sifting through hundreds of pages—which many of these applications often entail—can be daunting and confusing. Often, it’s not even clear what questions the business community should be asking. Below are a handful of questions that your state or local business community may want to consider when developing comments. The questions are arranged under the three major sections of the applications: standards and assessments, accountability, and teacher quality.

Standards and Assessments

Since the majority of states have adopted the Common Core State Standards, most applications focus on how the states are rolling out the standards—training teachers, conducting information sessions for the community, and creating tools for districts and schools. While the timelines are interesting, it’s pretty hard to gauge how they will work in reality.

Ask:

How is the state defining college-ready? Is it collecting data from universities on student preparedness for college-level work?

How is the state defining career-ready? Does it plan to collect data on students’ career paths after high school?

Accountability

States describe how they will replace the current NCLB requirements with different annual and long-term goals; how they will include subgroups, the supports and consequences for low-performing schools; and how parents and the community will be able to understand how their schools are performing.

Of particular note under this section is the information that states must provide regarding the new, ambitious goals they will establish in order to replace the current “100 percent proficiency by 2013–2014” requirement. The department suggests two options, while leaving states free to propose other “equally ambitious” goals:

Option A: Set annual goals in equal increments so that the achievement gap between the “all students” group and each subgroup is cut in half within six years (by 2017–2018).

Option B: Set annual goals that increase in equal increments so that all students are “college and career-ready” by 2020.

Ask:

How much growth in annual student achievement (and gap reduction) is required?  Are these state goals sufficiently ambitious? 

Is enough detail provided on how these goals will be implemented and achieved?

Will the state maintain adequate accountability for all subgroups—beyond simply reporting on their outcomes?

How does on-time graduation factor into accountability?

Will parents, the public, and the business community understand school ratings and report cards?

Is student achievement the driving factor for holding schools accountable?

Are there sufficient supports and consequences for low-performing schools?

What options, such as school choice and free tutoring, will continue to be available for students stuck in continuously low-performing schools, including those schools that may not be among the lowest 5% or 10% schools in the state?

What will the state do to ensure that schools not identified as the lowest performing are still making progress and taking appropriate action to improve when necessary?

Teacher Quality:

There is fairly widespread agreement that the teacher quality requirements of No Child Left Behind are outdated. Under the law, teachers are required to have a regular teaching certificate, have a certain number of credits or courses in their area of expertise, and have passed a competency test. However, teachers are not generally evaluated on the basis of student achievement.

In this section of the waiver application, the department has asked states to spell out how they will change teacher and principal evaluations with systems that must “use multiple valid measures in determining performance levels, including as a significant factor, data on student growth for all students…” and “will be used to inform personnel decisions.”

Ask:

What proportion of teacher and principal evaluation will be based on student achievement?

Are all school districts in the state committed to implementing these evaluation systems?  Has the state demonstrated the capacity to do so effectively and timely?

What supports will be given to low-scoring teachers and principals?

To what extent will the evaluation systems be used to inform personnel decisions? What are the consequences for teachers and principals who do not improve, and what is the timeline?

How will these consequences be enforced?

How will the state and districts ensure that high-scoring teachers are distributed across schools?

These questions represent just a few of the many questions the business community must be asking as states move forward with changes which will have a profound impact on education systems for years to come. 

This article appears in ICW's December 2011 newsletter.