UEA provides State School Board with input on the Utah ESSA Consolidated State Plan
As part of Every Student Succeeds Act (ESSA) requirements, Utah must submit a plan to the U.S. Department of Education describing how federal programs will be implemented in the state to support specific student populations. The plan must be submitted by September 18, 2017.
The Utah Consolidated State Plan was released on June 7, 2017, and is open through July 7, 2017, for a mandatory 30-day public comment period. The public (including educators!) can review the plan and provide feedback through a State Board of Education survey.
Each school district will also be required to submit a district-level accountability plan that aligns with the state ESSA plan. More information on that process and timeline will be available soon.
The UEA has submitted detailed comments on the state plan to the State Board of Education (see letter from UEA President Heidi Matthews). The UEA has also compiled an analysis and talking points about the Utah plan, including strengths, concerns and opportunities.
The Every Student Succeeds Act (ESSA), passed by Congress in 2015, ends the era of No Child Left Behind (NCLB). Where NCLB focused on accountability, testing and compliance, ESSA provides an opportunity to focus on equitable student access, opportunities and outcomes beyond a test score.
ESSA removes many federal mandates and returns decision-making to states to determine how to implement assessment and accountability programs as well as address opportunity gaps. ESSA directs each state to create a plan to identify how they will improve equity and supports for economically disadvantaged students, English language learners, at-risk students and other student populations through federal programs. Districts must also create a local plan that aligns with the state plan.
UEA Analysis and Talking Points About the Utah Consolidated State ESSA Plan
The Every Student Succeeds Act (ESSA) ends the No Child Left Behind era of accountability, testing and compliance. ESSA eliminates many federal mandates and returns decision-making to states to determine how to implement assessment and accountability programs as well as address opportunity gaps. ESSA directs each state to create a plan to identify how it will improve equity and supports for economically disadvantaged students, English language learners, at-risk students and other student populations through federal programs.
With ESSA, we can focus on serving our most vulnerable students and have the financial support to do so. With ESSA, there is opportunity to identify components of school quality that are meaningful to students, parents and educators beyond a statewide, standardized test on a given day. With ESSA, we can focus not only on equitable outcomes but also equitable access and equitable opportunities for every student. And, with ESSA, stakeholder engagement is central – and required.
The strengths and concerns highlighted below are viewed through the lens that ESSA creates real opportunities for student equity and that Utah must not fall short in creating a plan to help every student succeed.
Title I, Part A: Improving Basic Programs Operated by Local Education Agencies (LEAs)
School Quality or Student Success Indicator (Page 32)
This section describes the new “equity” indicator required by ESSA to be included in a state accountability system. This indicator will be measured by the growth of the lowest performing 25 percent of students in a school based on a statewide, standardized test.
- High school accountability will be measured using some indicators not based on a test (graduation rate, coursework completion).
- Elementary and middle school accountability will not include a single measure that is not based on a test.
- This section fails to reference the opportunity for each school to self-report two school quality indicators. These indicators are not part of the accountability calculation, but can provide greater context about a school and, over time, should replace the reliance on solely test-based indicators. More meaningful indicators of school quality could include: whether a school has sufficient counselors, nurses, social workers or a full-time librarian/media specialist; school climate; student attendance rates; parent and community engagement; teacher mentoring programs or student access to a broad and rich curriculum.
Exit Criteria for Comprehensive Support and Improvement Schools (Page 44)
This section describes changes to how a school identified for improvement under the state Turnaround law or identified for comprehensive support under ESSA will exit that status.
- Recent legislation allows the State Board of Education to develop a new process for exiting Turnaround or improvement status which will individualize exit goals for each school rather than base sufficient improvement solely on improving the letter grade received under the School Grading system.
More Rigorous Interventions (Page 45)
This section describes the significant overlap between schools identified for improvement under the state Turnaround law and those identified for comprehensive support under ESSA.
- States that the “USBE will align exit criteria and implications for not meeting exit criteria for both programs.” Interventions for Turnaround schools are defined in state code and include converting the school to a charter school, state takeover of the school or contract management. These are severe consequences that are already a concern for Turnaround schools and should not be expanded to non-Turnaround schools.
- The emphasis on interventions should be to support improvement in schools, not simply to impose consequences.
Technical Assistance (Page 46)
This section describes the support the state will provide for districts with a significant number of schools identified for improvement. The State Board of Education will conduct a comprehensive needs assessment which will include “identification and removal of potential LEA-level policies or procedures that create barriers to school improvement including priority for teacher recruitment and retention, hiring and staffing.”
- The “identification and removal” of LEA employment policies appears to give the State Board influence over local employment issues, which is not the purview of the Board.
- It is not clear the “removal” of barriers will result in improved teacher recruitment and retention. Instead, USBE should define and invest in a statewide strategy and system of supports to help the recruitment and retention of effective teachers.
- This section fails to address the Academic Pathway to Teaching (APT) license created by the State Board and how it may impact the distribution of effective teachers, recruitment or retention since an APT candidate receives a Level I license with no requirement for any classroom experience, classroom management, pedagogical or instructional skills.
Disproportionate Rates of Access to Educators (Page 47-48)
This section describes whether Title I schools have a disproportionate rate of ineffective, out-of-field or inexperienced teachers.
- There is no mention of the possible impact of the Academic Pathway to Teaching (APT) license created by the State Board in 2016.
- An APT candidate receives a Level I license with no requirements for classroom management, pedagogical or other critical expertise. It is not clear why the Board would consider an APT license “qualified” and “effective” as compared to education preparation program graduates.
- This is an important distinction in comparing charter schools to district schools since the rates of “qualified” teachers are already lower in charter schools.
Title II, Part A: Supporting Effective Instruction
- In this section, there is no focus on the need for strong induction and ongoing mentoring programs to improve instruction and retention. In an era of teacher shortage, the state should seek to expand programs like Peer Assistance and Review that have demonstrated results in improving retention and instructional effectiveness.
Teacher Leaders (Page 66)
This section describes the creation of a pilot grant program for districts to develop teacher leader programs.
- The requirements of the grant program do not include the essential role of teachers in the development of those projects. The grant requirements should be revised to emphasize the use of current teacher leaders to create a teacher-designed and teacher-directed program to build the leadership capacity of other teachers.
Improve Equitable Access to Teachers (Page 66-67)
The section describes student access to effective teachers, defined as 1) years of experience and 2) whether a teacher is qualified (fully licensed).
- There is no discussion of how the new Academic Pathway to Teaching (APT) relates to being a “qualified” or “effective” teacher. This creates significant concerns about equitable access to effective instruction for all students since the APT program allows a candidate to receive a Level I license without having any classroom experience, pedagogical training, classroom management training or other critical instructional skills.
System of Certification and Licensing (Page 68-69)
This section describes the current educator licensure process. It also describes the ongoing work of the State Board Licensing Task Force which is looking to change licensure to help “educators meet state requirements by demonstrating competency.”
- The goal of “demonstrating competency” is too vague to provide any understanding of the Board’s intent. Demonstrating competency through more rigorous student teaching experiences for education preparation program graduates could be beneficial. Demonstrating competency by requiring a vendor-based pedagogical exam could be detrimental.
Data and Consultation (Page 72-73)
This section describes how the state will use consultation to improve Title II activities. The plan states that there is a need to “be flexible when consulting with stakeholders, especially educators, by holding meetings or conferences outside the hours of the school day…”
- This is an extremely important recognition. This change would be a real improvement and allow classroom educators to participate in-person in stakeholder discussions.
Teacher Preparation (Page 73-74)
This section describes several goals for improving educator preparation programs. Goals include “requir[ing] multiple performance-based measures of knowledge and demonstrated skill for initial licensure” and “prepar[ing] initial certification candidates to effectively teach all students, with particular attention to special needs and English language learner”.
- A full description of the status of teacher preparation must acknowledge and differentiate that the stated goals for teacher readiness apply only to those graduating from education preparation programs and the Academic Pathway to Teaching (APT) license created by the State Board does not have the same expectations or requirements.
- The APT process for receiving a Level I license does not require any classroom experience, pedagogical skill or classroom management training prior to initial licensure and does not meet the goals stated above.