August 25, 2017

The Honorable Pedro A. Rivera
Secretary of Education
Pennsylvania Department of Education
333 Market Street
Harrisburg, PA 17126

Dear Secretary Rivera,

The Pennsylvania School Boards Association, which represents the 4,500 elected officials who govern the commonwealth’s school districts, appreciates this opportunity to provide comments regarding the Consolidated State Plan proposed by the Department of Education (PDE) to comply with the federal Every Student Succeeds Act (ESSA).

PSBA commends the department’s process, as required by ESSA, in convening stakeholder workgroups to identify recommendations for the development of the plan. The work of school leaders and other stakeholders underscores the importance of local governance and community ownership in public education. Similarly recognizing the benefit of stakeholder input, in March, 2016, PSBA convened a diverse group of more than 80 school directors, school administrators and subject experts to develop a report with recommendations for the State Plan that was presented to PDE and the General Assembly for consideration.

The proposed State Plan provides the transition for Pennsylvania’s compliance with the federal law as it moves away from a system that was prescriptive and punitive to one that provides for measurable accountability with positive support in raising school and student performance. The plan correctly notes: “Pennsylvania is a local control state, and PDE’s Consolidated State Plan recognizes that the federal law provides greater autonomy and flexibility at both the state and local levels. As such, PDE prioritized strategies that promote flexibility for LEAs and ensure that decisions about how to use federal funds are driven first and foremost by students’ needs, determined within a local context as appropriate.” With implementation of the plan beginning in this new school year and full rollout scheduled for 2018-19, PSBA believes this new framework will strengthen the ability of local school boards to act in the best interests of students and to advance excellence in public education.

With this in mind, PSBA offers these comments to selected issues contained in the proposed State Plan.

Academic Assessments – Testing mandates for federal accountability purposes continue to exist under ESSA; however, the law provides flexibility for states to determine the type, form and method of assessments that will most benefit their students. While Pennsylvania’s system of standardized assessments will not change and the PSSAs and Keystone Exams will continue to be used, PDE will reduce testing time for the PSSAs beginning in 2018. PSBA supports this change that could eliminate up to two full testing days for some schools. PSBA also supports the department’s intention to shorten the testing window and move it toward the end of the school year, beginning in 2019. As PDE continues to examine issues related to standardized testing, PSBA urges the department to consider whether changes related to the length and testing windows are feasible for the Keystone Exams.

On a related note, PSBA understands PDE’s rationale for its decision not to pursue an exception from the double-testing experienced by many 8th grade students who take the PSSA and Algebra I Keystone Exam. However, the association urges the department to continue to consider this issue that has been identified by stakeholders as important to pursue and resolve. Perhaps some flexibility may be allowed in the future for all middle school students with no additional high school level math assessment mandated.

Accountability, Support and Improvement for Schools – Overall, ESSA allows less emphasis on measuring achievement based on standardized test scores, and permits states to further define valid measures of progress. PSBA supports this effort that reduces the reliance on test scores and uses multiple indicators to determine growth and success. Those include the indicators required by ESSA (academic achievement, academic progress, graduation rate, progress in achieving English language proficiency) as well as new Pennsylvania-specific indicators (chronic absenteeism and college/career readiness).

PSBA supports the concepts contained in the new Future Ready PA Index to be used beginning in the fall of 2018 as an improved system that provides a more holistic evaluation of school and student performance. As a replacement for the current School Performance Profiles that uses a single numeric rating, the dashboards will provide a comprehensive report using a wider range of criteria to highlight successes as well as areas in need of improvement on various measures. The association looks forward to the continued discussion and progress towards the finalization of these new school report cards.

Under ESSA, states must continue to identify and address low-performing schools, but the law provides flexibility to states to design accountability systems and interventions. PSBA generally supports the provisions under the State Plan to identify schools for Comprehensive Support and Improvement (CSI) and Targeted School Improvement (TSI) and provide assistance. This approach provides in some instances an important balance between state oversight and accountability with local flexibility. The association makes further comment on the following specific components of the Plan:

  • School-level participation rates: The plan requires schools with rates below 95% to develop and implement state-approved improvement plans, and such schools may be required to complete a school- or LEA-level assessment audit. However, the State Plan does not provide any additional detail regarding the new requirements. What must be included in an improvement plan, what are the timeframes for development of the plan, and what is the approval process that will be used by PDE?  What criteria will be used to determine if an assessment audit is necessary? Will PDE consider different options for schools with varying rates; for example, will a school with a participation rate in the 90-94% range be subject the same consequences as a school with a rate in the 80% range, or 70% range?  Will considerations be given with the acknowledgement that Pennsylvania does permit parents to have their children exempted from participation?
  • Exit criteria for CSI schools: PSBA suggests that some clarification would be helpful regarding exit criteria. What is “measurable progress” on at least one accountability indicator? Must the improvement plan be approved by PDE?
  • More rigorous interventions for schools that fail to meet exit criteria: The State Plan includes a list of interventions that PDE may impose on schools that fail to meet exit criteria. The language here is vague and raises questions. For example, the second item on the list calls for additional PDE approvals of local expenditures associated with ESSA. What will be defined as a qualifying expenditure? Does this apply only to expenditures using federal funds or does it include expenditures using state and local funds? Would PDE will be able to deny local expenditures? Will there be an appeals process for schools? PSBA is concerned that these provisions could be used in a restrictive manner by PDE and effectively erode local control over school districts’ use of state and local funds.
  • Locally-developed intervention plans: The State Plan includes less restrictive language that permits districts to propose a locally-developed plan for interventions in returning CSI schools. PSBA supports this provision as it recognizes that local school leaders best understand the needs of their students and communities, and what interventions may work best to achieve progress so that they may exit the CSI status.

Supporting Excellent Educators – PSBA supports the efforts of the department regarding educator recruitment, development, retention and advancement. The many current initiatives along with the proposed new initiatives address on a wide scale the issues facing the state regarding its supply of quality teachers and school leaders. The association acknowledges that the implementation of these initiatives is dependent on state funding as well as federal Title II, Part A money. With funding challenges on both the state and federal levels, PSBA expresses its support and hope that these initiatives can be fully implemented and continued as long as possible.


Educator Evaluations – Not part of the State Plan, but a critical issue discussed by PDE’s stakeholder groups as well as PSBA’s workgroup, is the opportunity that ESSA provides to modify Pennsylvania’s existing process for educator evaluations. Because federal law no longer requires states to specifically address evaluation systems, it is not appropriate to include provisions in the State Plan. PSBA believes that this change sets the stage for the General Assembly to re-visit the current educator evaluation system established under Act 82 of 2012. The association, in partnership with the PA Association of School Administrators and the Principals Association, has developed a series of recommendations for change and stands committed to working with the department and the General Assembly on this issue.

Again, allow me to thank you for the opportunity to comment on the proposed ESSA State Plan. We look forward to continuing our work with you as this process continues and as schools will implement the new plan.

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