Home ::
To Whom It May Concern:
The Texas Classroom Teachers Association, representing 50,000 classroom teachers and instructional personnel in Texas, appreciates this opportunity to comment on Chairman Miller’s discussion draft of the NCLB Act reauthorization. Our comments include a blend of our recommendations as well as examples from the draft language. We look forward to the continuation of the discussion about the reauthorization of this very important piece of federal legislation.
First, overall, we appreciate many of the changes in the draft that serve to interject a strong dose of reality into the law by recognizing that schools do not operate in a vacuum in terms of influencing student achievement. For example, the draft contains a provision ‘‘(12) FACTORS AFFECTING STUDENT ACHIEVEMENT) calling for the state to “assess the non-academic factors influencing student achievement, and a description of the State educational agency’s strategy to coordinate and collaborate, to the extent feasible, with agencies providing services to children, youth, and families, with respect to local educational agencies within the State that are identified under section 1116 to help provide needed services to address major nonacademic factors that have significantly affected the academic achievement of students in the local educational agency or schools served by such agency.”
Additionally, the draft allows states to use multiple indicators in addition to testing, in another show of recognition that there are many valid ways to measure educational success besides tests alone. Although some will complain that the introduction of multiple measures "waters down" accountability and unnecessarily complicates the accountability system, our experience in Texas has shown otherwise. The Texas accountability system involves some 36 indicators, including testing, high school completion rates, and annual dropout rates for each student group. Yet the system is transparent and understandable. In addition, the inclusion of these other indicators, rather than “watering down” accountability, has in fact served to give the public a richer and more accurate understanding of how well schools are doing. The success of the Texas system has been, in large part, due to striking a balance so that the set goals are a stretch, but not so unattainable that people give up. We believe that the draft's inclusion of more factors than just testing helps to strike this balance. Additionally, the draft includes sufficient checks on the use of multiple measures (such as allowing them to count only for “extra credit” in certain situations), to ensure that these additional measures will not be used to dilute or obfuscate accountability.
In fact, we have concerns about the provision in the draft that states using multiple indicators must set a universal goal for achievement on each indicator that is equal to the average achievement of the highest performing group of students in the highest performing 10 percent of school districts in the state. This strikes us as a circumstance in which the bar is set too high to be attainable and we would encourage reconsideration of this standard.
Teacher qualifications:
The draft contains only minor changes to these provisions, but TCTA understands that Chairman Miller plans to release more changes addressing teacher quality at a later date. We note that the draft includes new language requiring states to show that teachers are receiving high quality professional development to enable teachers to meet the highly qualified requirements, and we appreciate the addition of this provision. However, we remain concerned about recent discussions at the federal level about changing the focus of highly qualified teachers to highly effective teachers, based on student performance. We note that the draft includes language that the state plan for highly qualified may include such measures as the State educational agency determines to be appropriate to increase teacher qualifications and classroom effectiveness, and we wonder what measures the drafters have in mind.
Our concern about interjecting the notion of teacher effectiveness based on student performance centers around the fact that the current state of research regarding the use of statistical models to evaluate teacher effectiveness is insufficient to support the use of these models for high-stakes decisions. In the most extensive evaluation of value-added models to date, by RAND Education, the conclusion was that “the research base is currently insufficient to support the use of value-added models for high-stakes decisions”. (“Evaluating Value-Added Models for Teacher Accountability”, RAND, 2004). At most, these models show “promise for lower-stakes diagnostic purposes” such as initially identifying possibly low- or high-performing teachers who can then be further evaluated to confirm results.
In fact, much of the research in this area seems to be based on the Tennessee model, which is based on a set of privately developed and not fully disclosed algorithms. In a research publication entitled “Value-Added Assessment of Teachers: the Empirical Evidence” by Haggai Kupermintz of the University of Colorado at Boulder, it is noted that there has been little external, peer-reviewed validation of the system in use in Tennessee. Further, the author states “The contention that merely by including in the analysis the student’s previous test scores, the system is able to control adequately for all exogenous influences – without actually measuring them – is a radical departure from the conclusions reached by other researchers, as well as from basic intuitions about schooling. It is counter-intuitive for most educators to assume that student, family, or community resources will have only negligible impact on a student’s rate of progress, even after prior achievement has been accounted for. Such a radical assertion requires reliable and strong empirical evidence if it is to be trusted to serve as a working assumption for school or teacher evaluations. The only evidence that has been offered to date to support this contention, however, comes from an unpublished report circulated by the University of Tennessee Value-Added Research and Assessment Center.”
In another recent report, Using Student Progress to Evaluate Teachers: A Primer on Value-Added Models by the Educational Testing Service, Sept. 2005, the author examined value-added models and concluded with advice for policymakers who are seeking to understand both the potential and the limitations inherent in using such models to evaluate teachers. "Despite the enthusiasm these models have generated among many policymakers, several technical reviews of VAMs have revealed a number of serious concerns. Indeed, the implementation of such models and the proposed uses of the results raise a host of practical, technical, and even philosophical issues. First and foremost, treating the output of a value-added analysis as an accurate indicator of a teacher’s relative contribution to student learning is equivalent to making a causal interpretation of a statistical estimate. Such interpretations are most credible when students are randomly sorted into classes, and teachers are randomly assigned to those classes. In the absence of randomization, causal interpretations can be misleading. In reality, the classroom placement of students and teachers is far from random. In most districts, parents often influence where their children go to school and even to which class and teacher they are assigned. Similarly, teachers may select the school and classroom where they are placed." He also found that treating estimated teacher effects as accurate indicators of teacher effectiveness is problematic. "Much more needs to be known about these kinds of data and the properties of the models in different, commonly occurring situations before there can be agreement on whether it is generally possible to isolate teachers’ contributions to student learning, and have the confidence to carry out actions on that basis." The author concluded: "Policymakers should not ignore the technical aspects of VAMs. The concerns that have been raised are central to the proposed use of VAM results in teacher evaluation.”
Other researchers have identified impediments to accurately gauging teacher effectiveness based on student performance, including that current methods of testing students do not measure gains in student achievement very accurately, that some portion of student gains may be more attributable to factors other than the effectiveness of the teacher, and that there is not the technical capacity to compare the gains of students of widely disparate abilities.
It seems that one of the chief concerns about the issue of teacher quality is the inequity in the assignment of good teachers, such that high-need schools often receive the least experienced or under-certified teachers. Given the lack of substantial research supporting the use of value-added models to determine teacher effectiveness, the fact that many states don’t have data systems in place to tie students to specific teachers, and that an inordinate amount of time and money would have to be spent in order to engage in the process of determining the value to student performance added by specific teachers, we encourage the focus of this legislation to be more on doing things to ensure that certified and experienced teachers teach at high-need schools and stay there. The draft does seem to recognized the value of having properly certified and experienced teachers teaching at high-need schools in that it requires schools missing AYP to ensure that no student in the school is taught for two consecutive years by novice or out-of-field teachers (or, if school capacity does not allow this, to publicly report on the inequities to parents, the school district, and the local community). We would recommend also incorporating this concept into the School Improvement and Assistance provisions of the draft by requiring schools missing AYP to focus on strategies for reducing teacher attrition and turnover, reducing out-of-field assignments, and increasing teacher retention. These strategies should be included among the required interventions for both Priority and High Priority schools.
Additionally, we join with many others in advocating that inequities in teacher quality be addressed by focusing on policies aimed at reducing turnover and helping teachers get better where they are, including bonuses for teaching in a low-performing school, smaller class sizes, intensive professional development, and paying educators more for teaching in shortage subjects such as math, science, and special education.
Regarding the draft’s provisions related to growth models, the principles by which growth models must operate include:
• Continuing the expectation that all students in each subgroup will be proficient by 2013-2014 or be on a trajectory for proficiency within 3 years;
• Establishing annual measurable objectives that are based upon the state’s proficient levels and not upon individual student background characteristics;
• Establishing separate, measurable growth targets for mathematics and reading/ language arts;
• Ensuring all students who take the state’s assessment are included in the state’s accountability system;
• Including comparable results from grade-to-grade and year-to-year within the definition of AYP; and
• Including rates of student participation in assessments and academic achievement as separate indicators in determining AYP.
Given that the results of these growth models will be used for accountability purposes, and that there are so many factors influencing student growth that are outside the teacher’s and school’s control, we strongly advocate adding a provision that would require that the growth methodology selected by the state include advanced statistical methods that fairly and accurately adjust for factors beyond the control of an educational institution or educator, including student demographics and community characteristics. Additionally, in the same way that the draft requires states using different measures of student achievement to ensure that such measures are valid, reliable, and consistent with the Standards for Educational and Psychological Testing (see Requirements for Academic Assessments), we ask that any growth model used must be valid, reliable and consistent with the principles of sound statistical analysis. The criteria for validity and reliability of these models should be that they are based on research that has been independently peer reviewed and based on empirical evidence which adheres to the basic principles of sound statistical analysis. These are the same criteria used by many respected research institutions in deciding whether any given research is valid and reliable (see Using Research and Reason in Education, What is Scientifically Based Research, A Guide For Teachers).
If these growth measures are used in any way to evaluate teachers, then consistent with the same principles established in the draft for different measures of student achievement, (that such assessments shall only be used for purposes for which they are valid and reliable, and consistent with the Standards for Educational and Psychological Testing) we ask that the same principles be applied to using growth measures to evaluate teachers. Further, any assessment instrument used as a basis for educator evaluation must be certified by the entity that develops the instrument as being validated and reliable for that purpose and independently verified by an impartial psychometrician as being valid for that purpose.
Longitudinal data systems:
The draft requires states to develop, within four years, longitudinal data systems that compare the same group of students each year. The requirements for these data systems include prohibiting “the disclosure of personally identifiable information except as permitted under section 444 of the General Education Provisions Act (FERPA) and any additional limitations set forth in State law.”
The draft also contains language in subsection (1)(B) of (e) REQUIREMENTS that requires states to ensure limited use of information in the longitudinal data system by institutions of higher education and State or local educational agencies or institutions to the activities set forth in paragraph (1) or State law regarding education, consistent with the purposes of this subtitle.
These provisions should be clarified to ensure that personally identifiable teacher data, including any linkages to student performance, is not public and is limited to specified educational uses by the described entities.
We appreciate language in the draft that that the state form a committee to design the data system and that the committee include public elementary and secondary school teachers and members of organizations representing teachers, including unions, operating unions that represent teachers, principals and administrators of programs under this Act, representatives of small and large business operating or representing businesses, representatives of civil rights organizations; and experts in educational research, statistical analysis and data privacy from institutions of higher education or other research organizations.
Testing of Special Education and English Language Learner students:
We note that the draft appears to codify many of the current USDE regulations regarding testing of English Language Learners and Students with Disabilities, including the caps on the percentage of students with disabilities who can be tested on an off-grade level test or a modified on-grade level test. We have always felt that these caps were not only arbitrary, but in fundamental conflict with the Individuals with Disabilities Education Act. IDEA requires teams (IEP teams) of parents and educators familiar with the student to design for each eligible disabled student an individual education plan, including the assessments that the student will take, based on the student’s unique situation and abilities. Subsequently, NCLB was passed and the USDE implemented rules regarding testing of special education students and imposing the caps. The result is not only that federal law/regulations undermine the intent of IDEA by effectively taking the decision-making about which test a special education student will take away from the IEP Team, but that many special education students are being tested over content that hasn’t been taught, because their IEPs don’t match the NCLB-imposed testing requirements. A competing law like the NCLB that penalizes schools for exceeding an arbitrary cap on the number of special education students tested on an alternative or modified test puts a significant amount of pressure on schools and parents to focus less on designing an education plan to meet each child’s individual needs, as required by IDEA, and focus more on giving these children tests that they aren’t prepared to take and pass. This is a disastrous situation and should not be continued in the reauthorization. If the goal is to make sure that special education students are appropriately included in the accountability system, the regulations already accomplish that by requiring stringent measures for states to follow in developing alternative or modified tests for special education students. For example, the draft provides that a State may, through a documented and validated standards setting process, define alternate academic achievement standards for students with the most significant cognitive disabilities, provided those standards—
‘‘(i) are aligned with the State’s academic content standards;
‘‘(ii) promote access to the general curriculum; and
‘‘(iii) reflect professional judgment of the highest achievement standards attainable by those students."
We appreciate the fact that the draft requires the Secretary to review key studies on this issue and re-regulate the issue based on the results of such studies after 3 years. However, in the interim, we advocate eliminating the caps, or at least, allowing states and districts to exceed the cap (with no limit) if circumstances justifying exceeding the cap exist.
We are appreciative that the draft adds language that focuses on the state providing support for teachers in order to test these students properly. For example, the draft requires that the state ensure that teachers and school administrators are adequately prepared and trained to determine when accommodations on assessments delivered to these students are necessary and how to incorporate these accommodations into their instruction to these students. This provision addresses a common complaint we hear from our members, that they receive little training or support in how to deliver instruction and services to students with special needs.
We are appreciative that this focus on support for teachers is not just limited to testing situations. The portion of the draft regarding school improvement and assistance requires schools to conduct a needs assessment to look at current professional development activities for teachers and principals. In doing so the draft requires schools to determine how changes to professional development practices or instructional practices, such as common lesson-planning, instructional coaching, and evidence-based interventions, could address causes for the school not making adequate yearly progress. It also requires schools to offer ongoing, high-quality professional development for the school’s principal and teachers. Additionally schools are required to offer mentoring and induction for all new teachers, and the draft suggests that schools provide regular opportunities for teachers of core academic subjects to collaborate with both subject area and inter-disciplinary groups to review student achievement data and plan instruction; and to implement a school-wide literacy or mathematics plan that includes hiring literacy coaches or mathematics coaches. The draft also requires schools to report numbers of out-of-field teachers, an issue which continues to plague Texas, which suffers from a high out-of-field assignment rate.
In our review of the provisions related to school improvement and assistance, we found much to like. For example, the draft requires that in order to help low-achieving children meet challenging achievement academic standards, each school district shall have a plan that includes:
* a description of how the local educational agency will use the results of the assessments to provide research-based instruction and interventions;
* a description of how the local educational agency will create an early childhood education team of staff within such agency with responsibility for curricula, assessment, professional development, and after-school programs, special education, English language learners, and other pupil services for children below grade four, in order to create ongoing channels of communication on shared expectations of learning and knowledge of developmentally, age, culturally, and linguistically appropriate practices;
* a description of the actions the school district will pursue to ensure that high quality, highly qualified teachers take positions in, and remain in, schools served under this part; and
* assurances that the local educational agency will provide that the instructional materials are aligned with current State academic content standards and prepare students to meet current State academic achievement standards.
Additionally, the draft requires that certain schools not making AYP develop a comprehensive school improvement and assistance plan in consultation with, among others, principals, teachers and other school staff, including those with expertise in working with students with diverse learning needs, including English language learners and students with disabilities. The plan shall include a review and analysis of the systemic causes for the school not making adequate yearly progress, including review of students not meeting proficiency targets and the specific subjects and student groups that account for the school not making adequate yearly progress and achievement data for students not meeting proficiency, including—
* an analysis of teacher assignment by grade, subject and group of students;
* an analysis of practices concerning the school’s core academic instructional program that have caused the achievement differences.
The plan shall include a review and analysis of current and prospective strategies, policies, and practices that will directly address the systemic causes for the school not making adequate yearly progress, including—
* current teacher assignments that include a review of out-of-field teaching and data from the local educational agency’s needs assessment to determine whether students who are not proficient are assigned to teachers who are highly-qualified and who are best equipped to help them attain proficiency and how changes to teacher assignments could address causes for the school not making adequate yearly progress;
* current professional development activities for teachers and principals to determine how changes to professional development practices or instructional practices, such as common lesson-planning, instructional coaching, and evidence-based interventions, could address causes for the school not making adequate yearly progress;
* the current amount of instructional time (including learning time before school, after school, during the summer, and during any extension of the school year and through tutoring options) to determine how changes to the amount of instructional time could address causes for the school not making adequate yearly progress.
Finally the draft requires schools missing AYP to ensure that students who need the most help are assigned to the teachers best equipped to help them by ensuring that no student in the school is taught for two consecutive years by novice or out-of-field teachers (or, if school capacity does not allow this, publicly reporting on the inequities to parents, the school district, and the local community.)
These are all good provisions based on sound educational practice.
However, we do have a concern about some of the wording used in these provisions. Specifically, in (b) SCHOOL IMPROVEMENT AND ASSISTANCE PLAN, (3) CONTENT OF PLAN, there is a provision that states that the plan must include an analysis of teacher assignment and teacher expertise by grade, subject and group of students. We are unclear as to what the term “teacher expertise” encompasses. The term needs to be defined, and we would object to the definition including an evaluation of teachers based on student performance, given our earlier statements regarding the whole concept of basing decisions about teachers on student performance. Additionally, that same section requires an analysis of reforms that have the greatest likelihood of improving teacher performance. Again, we have concerns about this terminology, given the push for performance pay for teachers and the lack of evidence upon which to base such a policy.
Additionally, we ask that small class sizes be included as a required intervention for Priority and High Priority schools. We note that High Priority elementary schools are required to adopt at least the first three proven interventions listed; High Priority secondary schools are required to adopt at least the first four interventions and Priority Schools can choose at least any two of the interventions, targeting them to the subgroup(s) that are struggling:
o Proven Instructional Programs—schools can revise their instructional programs in order to better align them with the state’s standards. In the case of high schools, this can include improving rigor by ensuring that a full college and work-ready curriculum is available consistent with the Academic Competitiveness Initiative, including increases in AP and similar courses, dual enrollment or early college secondary school opportunities; creating contextual learning opportunities aligned with work-readiness such as high-quality career and technical education; or implementing integrated curriculum.
o Formative Assessments and Data-Based Decision-Making—schools can adopt use of formative assessments that provide teachers with real-time diagnostic information on their students’ progress and can inform their instruction;
o Parental Options—schools can adopt use of free after-school tutoring for low-income students and public school choice as consistent with state law;
o Personalized Learning Environments—schools can provide activities that increase student engagement and attendance, including dropout recovery and credit completion programs, smaller schools, and 9th grade transition programs;
o Extended Learning Time—schools can increase students’ access to after school, summer school and other learning opportunities that go beyond the current typical school day, which may include extra instruction in reading and math;
o Supervised Intervention Models—schools can use supervised intervention models for low-performing schools (such as Response to Intervention approaches, tiered instructional interventions); and,
o Specialized Support and Parent and Community Involvement—schools can offer extra help for students with diverse learning needs, such as English Language Learners and students with disabilities – and additional counselors, social workers, and other supports including activities that link families with support services that help meet students’ non-academic needs. In the case of high schools, this can include career academies and other student engagement activities.
We strongly believe that a required intervention for any school identified as Priority or High Priority should be small class sizes. There is significant evidence supporting lower class sizes as an effective intervention strategy for struggling learners. The intervention entitled “personalized learning environments” is the closest we can find to getting at this issue, but it needs to be a requirement for all of these schools. Texas has successfully required small class sizes as an intervention in the form of accelerated instruction for students at risk of failing, or failing the state assessment (see Texas Education Code section 28.0211(c) ), and we believe that this is a proven model that should be required for all schools identified as Priority or High Priority.
As we mentioned earlier, another required intervention for both Priority and High Priority schools should be requiring schools missing AYP to focus on strategies for reducing teacher attrition and turnover, reducing out-of-field assignments, and increasing teacher retention. These strategies should be included among the required interventions for both Priority and High Priority schools.
We also note that teachers are barely noted in passing as one of the stakeholders to be consulted in the development of a school improvement and assistance plan. We ask that thought be given to requiring evidence of involvement in and support for the plan by teachers, given that it is the teachers who will be charged with implementing most of any school improvement plan, and such “buy-in” is critical to success.
Finally, with regard to the options provided for in the draft for High Priority Redesign Schools, we object to the inclusion of the options to close the school and reopen as a charter school, given the underwhelming track record that charters have shown as a whole. In Texas, charter schools as a group have significantly underperformed their traditional school counterparts, even when compared to traditional schools with comparable student populations and circumstances.
College readiness standards: According to the committee’s outline of the draft, the draft contains provisions providing incentives for states that have not already done so to review their standards in light of national and international benchmarks and collaborate with the business and higher education community in the state to develop standards that are aligned to the skills and knowledge necessary for success in college and the workforce. States that choose to revise their standards would, as part of this process, fully align their state assessments to the new standards within 2 years, ensure that assessments measure critical skills such as prblem-solving and application of knowledge and meet high technical quality standards.
However, in addition to these provisions, we note that the draft also requires states wishing to receive Title I funds to submit a state plan that demonstrates that the state has adopted challenging academic content standards. The draft also adds new language that the content standards are aligned from grade to grade and with the knowledge and skills necessary for success in postsecondary education and the workforce.
Cite: (‘‘SEC. 1111. STATE PLANS.
‘‘(b) ACADEMIC STANDARDS, ACADEMIC ASSESS MENTS, AND ACCOUNTABILITY.—
‘‘(1) CHALLENGING ACADEMIC STANDARDS.—
‘‘(D) CHALLENGING ACADEMIC STANDARDS.—Standards under this paragraph shall
include—
‘‘(i) challenging academic content standards in academic subjects that—
(IV) are aligned from grade to grade and with the knowledge and skills necessary for success in postsecondary education and the workforce)
We also note that the draft contains language requiring state accountability systems to be of sufficient rigor as to ensure that students graduate from secondary school with the problem solving skills and critical thinking capacities necessary to succeed in postsecondary education and the workplace
Cite: (‘‘(2) ACCOUNTABILITY.—
‘‘(A) IN GENERAL.—
Each State accountability system shall—
‘‘(i) be based on the academic standards and academic assessments adopted under paragraphs (1) and (3), progress toward graduating all students as described in section 1124
‘‘(iii) be of sufficient rigor as to ensure that students graduate from secondary school with the problem solving skills and critical thinking capacities necessary to succeed in postsecondary education and the workplace as defined in section 1111A ‘‘
We ask that the draft clarify whether the development of college readiness standards is voluntary or mandatory and consider a more realistic timeframe other than the two years the draft provides for aligning all assessments with college readiness standards.
Test score results:
We appreciate the language contained in the draft that the state will ensure that the results of the state assessments will be promptly provided to teachers not later than 30 days before the beginning of the next school year. ( ‘‘(13) USE OF ACADEMIC ASSESSMENT RESULTS TO IMPROVE STUDENT ACADEMIC ACHIEVEMENT.—
Each State plan shall describe how the State educational agency will ensure that the results of the State assessments described in paragraph (3)—
‘‘(A) will be promptly provided to local educational agencies, schools, and teachers in a manner that is clear and easy to understand, but not later than 30 days before the beginning of the next school year)
Reporting:
The draft contains language requiring states to include in their State Report Cards information, disaggregated by the highest and lowest achieving deciles of public schools (based on statewide standardized assessments), on, among other things, the average class size and range of classes. (see :‘‘(C) REQUIRED INFORMATION.—The State shall include in its annual State report card—
‘‘(x) information, disaggregated by the highest and lowest achieving deciles of public schools (based on statewide standardized assessments), on—
‘(I) the proportion of teachers in core academic subjects who are highly qualified;
‘‘(II) the proportion of school principals (and other school level administrators) certified under an applicable State or national program;
‘‘(III) the proportion of secondary school students enrolled in a college preparatory curriculum;
‘‘(IV) the average class size and range of class sizes;
‘‘(V) the ratio of students to computers; and
‘‘(VI) the average starting teacher salary.)
We note that the current NCLB, while not requiring reports of average class size, does make reporting average class size per grade an option. We believe that average class size per grade is much more meaningful than a statewide average, especially since states like Texas put class size limits on certain grades. Accordingly we ask that the draft include a reporting requirement of average class size per grade.
With regard to “average starting teacher salary”, we believe that limiting reporting to just starting salaries would provide a significantly skewed picture of reality, since most schools in the country pay relatively high starting salaries, but salary schedules quickly flatline after the first couple of years. Therefore, we would recommend expanding this reporting requirement to include average salaries for teachers at particular intervals of experience throughout the teaching career. Additionally, in light of the pressing problem of teacher attrition, we recommend requiring information about the average years of teaching experience the states’ teachers have.
Expanded Learning Time Demonstration Program:
We appreciate language in the draft articulating the stated purpose of the grant program, which is to develop expanded learning time schools and encourage the participation of teachers and teacher union representatives in school redesign efforts associated with expanded learning time in order to create the most effective redesign efforts, as well as to provide educators in participating schools with increased opportunities to work collaboratively and to participate in professional planning to improve instruction and student achievement.
We also appreciate language in the draft which requires that a qualifying expanded learning time and school redesign implementation plan contain, among other things:
* an increase in instructional time on core academics and enrichment, and more time for teacher planning and professional planning;
* a comprehensive restructuring of the entire school day and/or year to maximize the use of the additional learning time and improve student achievement;
* an assurance that core academic subjects shall be taught by qualified, certified teachers while other academic and enrichment programs may be taught by certified teachers, or other qualified personnel;
* evidence of an agreement between the governing body of a participating local education agency and employees, including teachers, at participating schools or their legal representatives to work the expanded schedule.
However, we note that one of the requirements for the plan is that each participating school must add no less than the equivalent of two hours per day to the school schedule that is standard for the participating local education agency. We believe this is not only overly prescriptive, but limits options for schools which might be able to greatly expand learning time by engaging one of the other requirements, a comprehensive restructuring of the entire school day or year to maximize the use of additional learning time. Additionally, it is likely not appropriate to require this amount of additional time for younger students. Therefore, we believe the two hours per day requirement should be eliminated.
Thank you for this opportunity for input.
Holly Eaton
Director of Professional Development and Advocacy
Texas Classroom Teachers Association
Austin, Texas
Web posted: 09/06/07
Note: Slightly reformatted for web publication
