Send your comments to NYSED today – don’t punish schools for high opt out rates! Deadline for comments on the new ESSA regs Aug. 17. 

Mine is below, borrow what you’d like:

August 13th

To the Commissioner:

It is the job of schools to administer the test to all students, not sell parents on the value of tests at a time when the state’s true commitment to the education of their children is questionable. If you want “opt out rates” to decrease, and let’s be honest, “opt out” is weak, it is a refusal rate in New York, then you need to convince parents of your loyalty and commitment to better outcomes first-not to your own reputation and coerced and enforced testing requirements. That being said, the suggestion that Title I funding might be impacted by refusals is the wrong way to go at this time. It’s doubling down on a rushed and misguided course and an anti-public education mindset.
Instead, examine closely and expand on some of the promise there actually seems to be in the ESSA draft:
School Accountability Methodologies and Measurements
(Under “what will be different”):
-Inclusion of new indicators: college, career and civic readiness (detail what, other than  standardized test scores, these are)
-Data dashboards for transparent reporting of results and indicators not part of accountability/support system (use for collection of the “indicators” in an ongoing student portfolio, not for dissemination of private student data)
-Advisory group to examine different indicators of quality for accountability (Stakeholders on the ground who can guide content/scope/intent/use of the portfolio)

Supports and Improvement for Schools:
-Examination and addressing of resource inequities in low-performing schools
-Incentives for districts to promote diversity and reduce socioeconomic and racial isolation
-Parent voice in some budget decisions in low-performing schools
-Improving access to all programs for students who are homeless, in neglected facilities…migratory

Accountability seems to be the current priority, and I would agree that there needs to be more accountability for student outcomes, but be honest about testing as it exists: the quality of the tests has not been established following years of verifiable examples and concerns (content, level, vendor…) and during what may end up being state-wide shift to computer-administered tests. To draw a sword and threaten the schools of parents expecting more consistency and a demonstration of the state’s will to commit to creating better outcomes (not just demand and measure them) will not inspire parent participation. Instead, require tests as before, but push for more of a shared accountability for things described already in the ESSA:

IN THE NYS’s APPROACH TO ESSA PLANNING SECTION
-More equitable distribution of resources and student access to programs and “effective teachers”
-Build an accountability and support system that is based on multiple measures of college, career and civic readiness (use that “dashboard” to build a digital, developing citizen portfolio that belongs to and travels with the student)
-Recognize the effect of school environment on student academic performance and support efforts to improve climates of all schools