When new legislation passes, PSBA is seen as the leader in analyzing it and helping members make sense of it.

PSBA Executive Director Thomas J. Gentzel presented testimony to the State Board of Education this week, raising concerns and questions regarding the Chapter 4 proposal to change the state’s high school graduation requirements. He urged the State Board to provide additional time to consider the policy and practical implications of the plan and called for more extensive research on this issue. The following is the text of Gentzel’s comments.

The Pennsylvania School Boards Association supports the board’s desire to ensure that our students graduate well prepared for their chosen paths, and we welcome this discussion.

The debate over Pennsylvania’s high school graduation requirements was initiated in 2005 when Gov. Rendell signed Pennsylvania to the American Diploma Project, a national high school reform movement developed by Achieve Inc. Since that time, the administration has been committed to implementing Achieve’s national, rigid policy agenda in this state and has taken steps to move towards that goal.

Moving the agenda forward began in earnest with the report of the Governor’s Commission on College and Career Success, released in December 2006. The purpose of the report was to outline the state’s justification for adopting the ADP agenda. The report called for the repeal of the current provision under Chapter 4 that allows school districts to use a local assessment as a graduation requirement. Instead, all students would have to pass either the 11th-grade PSSA or a series of new high-stakes Graduation Competency Assessments. These requirements will be the same for all students, whether they are taking college prep or vocational courses, enrolled in cooperative education work programs or participating in other individualized work programs.

The commission’s report concluded that this sweeping statewide change is necessary because our students are not properly prepared for post-secondary study or career, particularly in those school districts that use local assessments as part of their graduation requirements. The report also criticized districts for allowing students who did not score proficient on the PSSA to graduate, even if they had successfully met all other requirements.

PSBA disagrees with these reasons as justification for simply adopting the Achieve model. The association asked the board for research that clearly demonstrates the failure of our schools to adequately prepare our students. For example, what process did the Department of Education use to determine if a district’s local assessment was not aligned with the state academic standards and PSSA? What kinds of deficiencies were found? In how many districts were such deficiencies found? What technical support did the Department of Education provide to these districts? What data has been collected that shows that school districts are using local testing strategies that are not rigorous enough? What data has been collected that shows that students who score below proficient on the PSSA, but meet other graduation requirements, do not succeed beyond high school?

Without clear answers to these concerns, we question the speed with which the proposal is proceeding. There has been an overwhelming response of concern to the implementation of this plan voiced at all the board’s roundtable sessions – legitimate questions and concerns by representatives of schools, teachers, students and parents that have not been thoroughly answered. Now, with Chapter 4 language issued just one week ago and followed by today’s hearing, the board intends to vote on this proposal next week. We urge you to postpone a vote until stakeholders have had time to properly review this specific language, and concerns are properly addressed.

PSBA believes that a sweeping plan for GCAs is not necessary to increase the rigor of high school programs and ensure that the academic standards are being met. Authority to more closely monitor and enforce changes in those schools where it may be necessary already exists under Chapter 4. The regulation currently allows the secretary of education to investigate allegations of deficiencies. The Department of Education has the authority to provide schools with technical assistance in the development of academic standards and assessments that are sufficient to ensure that students are making progress toward attainment of standards required for high school graduation. The system already in place requires that districts provide an assurance that local graduation tests are meeting the standards, and Chapter 4 easily could be modified to “put more teeth” into these provisions.

While PSBA appreciates the efforts of the State Board to revise its plan to allow a local assessment option, the language, from a practical standpoint, effectively provides so many disincentives that it becomes no option at all. The process of developing and validating a series of local assessments every five years will be expensive and out of reach to most districts. Even if done properly, the resulting sets of local tests would be nothing more than alternate versions of the Graduation Competency Assessments offered by the commonwealth.

Furthermore, this option takes away the ability to use various assessment strategies available to local entities under the current Section 4.52(d) and mandates the creation of a series of written, standards-based assessments similar to the GCAs in determining a student’s eligibility to graduate. The current Chapter 4, Section 4.12(f) states that “school districts (including charter schools) and AVTSs shall assess the attainment of academic standards… for purposes of high school graduation and strategies for assisting students to attain them.” Section 4.12(f) also addresses the development of these local assessment strategies, stating that schools “will take into account that academic standards… may be attained by students in various ways and shall be assessed in various ways.” This is the recognition of flexibility in teaching and learning that must be preserved for a diverse population of students. It is puzzling to PSBA that the board would reverse its own existing policy and insist that a standardized test can be the sole measure of attainment of the standards.

The option of using an Advanced Placement or International Baccalaureate exams that are comparable to GCAs, while appreciated, will not be an option for districts that do not offer these programs within their curricula. How many students will benefit from this option? What about the many other students who do not take AP or IB courses? Why not recognize other types of tests taken by students, such as occupational competency tests taken by students in career and technical centers?

PSBA also questions the costs of developing 10 new GCA examinations. We believe that a cost analysis of this proposal must be done before any vote is taken. Certainly the costs of the plan will be a critical factor for state and local budgets for many years to come as this system would be created and continually updated. The State Board has no control over state budget matters, yet this plan will require a commitment of millions of dollars.

Given the amount of state and local money that will be needed to put this proposal into place, including the expense of using options other than the GCAs, PSBA cannot help but comment on the irony of the release of this proposal in such close proximity to the release of the costing-out study authorized by this board that reveals that the state’s public schools are being underfunded to the tune of $4.4 billion.

PSBA also is concerned about the effect the proposed testing scheme will have on the ability of professional educators to deliver a rich and varied curriculum to its students. With year-round testing seasons and greater stakes put on those tests, more time will be spent in test preparation, drilling and pre-testing to ensure success on either the PSSA or the GCAs. Also, the need for remediation and other strategies to ensure passage of the test has been expanded to include those who fail to pass the GCAs and to include science and social studies, in addition to reading and math.

We ask the board to also consider both the advantages and disadvantages of establishing a statewide model curriculum. While a voluntary model curriculum could serve as a helpful tool to districts, it also could indirectly become a mandatory guide if schools are forced to focus planned instruction solely on the PSSAs and GCAs as a condition for students to graduate. All students effectively will be required to take the same courses in order to pass these state tests. This is unacceptable to PSBA and would further strip local school entities of any control over the delivery of instruction to its students.

In conclusion, PSBA believes that these policy issues and questions must be addressed before the State Board votes on the Chapter 4 draft. Practical questions about the costs of the plan to both the state and local school districts must be weighed. PSBA would like to see this board closely examine all of the research on the impact of high-stakes testing on diverse populations of students. Let me be clear – our position of caution is not based on wanting to maintain the status quo or wanting to allow deficiencies to continue. But we believe that the need for large scale change in graduation requirements such as that contained in the Chapter 4 draft first must be unquestionably demonstrated, and we believe that more extensive research must be done. PSBA also suggests that the board consider various ways to achieve its goals and to move away from the one-size-fits-all model offered by Achieve.

All of us here today are in agreement that we want our children to be well prepared for success in college or other post-secondary study and the workplace. Likewise, I believe we can all agree that a high school diploma should mean that a student coming from a public high school in Pennsylvania is well-rounded, can apply his or her knowledge to real-life situations and can solve problems with that knowledge. Simply requiring more tests and using them to determine graduation eligibility is not the answer, and it is not what our students need.