To: Member, Pennsylvania Senate

From: Jonathan D. Berger, Director of Government Affairs

Date: June 22, 2017

Re: Senate Bill 756

On behalf of 4,500 locally elected school board members across Pennsylvania, we request your opposition to Senate Bill 756.  As amended in the Senate Education Committee, this legislation provides for significant changes to the use and implementation of standardized assessments, graduation requirements, and the educator evaluation system which have not been vetted by education stakeholders and the details of which provoke considerable concern.

Senate Bill 756 attempts to address the many issues relating to the Keystone Exam graduation requirement as well as Federal accountability requirements in the Every Student Succeeds Act (ESSA).  The legislation specifically looks to completely eliminate the use of Keystone Exams in any capacity, require reduced testing time for all future standardized testing, and provide a new menu of standardized assessment options to be used for Federal accountability compliance.

While PSBA applauds any initiative to remove the State mandated Keystone Exam graduation requirement and reduce testing time, we are concerned that the legislation limits the authority of school districts to set local graduation requirements that may include performance on standardized assessments.  Pennsylvania has a long and proud tradition of local control and this tradition should be upheld in order to satisfy the varying needs and desires of communities across the state.  PSBA also has concerns with language in the bill which expands opt-out policies from the current religious objection to a degree which would allow an individual to opt-out of an assessment for any reason.  Such provisions may result in a surge of opt-outs in school districts across the state which could negatively skew classroom, building, and district results and ultimately affect the use of assessment data for a variety of purposes.  Additionally, the menu of testing options, which includes the PSSA, SAT, PSAT, armed forces qualifications test, PASA, and NOCTI and NIMS exams, raises questions and concerns regarding Pennsylvania compliance with ESSA requirements, such as the need for standardized assessments to be aligned with Pennsylvania academic standards, and the fact that Federal requirements mandate a single statewide assessment to be administered to all students.  Further, it is doubtful that any of the assessments in the menu of testing options could be used by our state to comply with the Federal requirement to assess students in science during high school.  PSBA also has some concern with the rapid timeline in the bill which appears to require the new assessment system to be fully in place in about one year from now, and partial changes to the system to begin as early as the 2017-18 school year.  This timeline does not seem to contemplate the need for Federal approvals or the need for school districts to prepare for such substantial change.

Senate Bill 756 additionally amends state law regarding the educator evaluation system to completely revise the structure and method by which evaluations are administered.  While there is widespread agreement at all levels of the education community that the evaluation system needs to be revised to address a number of issues which have arisen since it was enacted in law in 2012, PSBA is concerned with the changes to the evaluation system in this legislation.

School board members, teachers, and administrators support increasing the observation and practice component of the evaluation system above the current 50%, yet, as amended, this bill would still decrease the weight of this component to 40%.  Further, while the bill was amended to remove new peer review and third-party evaluator provisions, the bill still provides for a new parent and student review factor to comprise a large percentage of evaluations.  Introducing this new factor into the evaluation system is certainly problematic and may unfairly alter evaluation outcomes due to biases, personal conflicts, and deficient knowledge of pedagogy.  In addition, while the PA Department of Education is required to develop the parent survey instrument provided for in the bill, each school district is required to develop the rubric and survey instrument for the student component of the evaluation and approve these at a public meeting of the school board.  This provision would create a new additional burden in terms of cost and administrative time and effort for school districts.  Finally, we see again a rapid timeframe as bill requires the change to this new evaluation system to take place in the space of about one year.

For all the reasons articulated above PSBA opposes Senate Bill 756 in its current form, but looking to the future we would be willing and pleased to work with the Senate and education stakeholders on the important underlying concerns and issues which this bill seeks to address.


I appreciate your time and attention to these matters. If you have any questions or concerns, please feel free to contact me at (717) 506-2450 ext 3716.

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