PAA comments on ESSA

PAA submitted the following comments to the federal Department of Education on the proposed draft ESSA regulations:

PAA comments on ESSA draft regulations

July 29, 2016

Parents Across America is a grassroots organization that connects parents of all backgrounds across the United States to share ideas and work together to improve our nation’s public schools. PAA is committed to bringing the voice of public school par­ents – and common sense – to local, state, and national education debates. We currently have forty chapters and affiliates in 23 states.


PAA is concerned that the draft regulations:

  • fail to reflect parents’ real interests and needs while using mistaken assumptions about parents to justify ineffective and harmful policies,

  • unacceptably attack parents’ right to protect our children from the misuse and overuse of standardized tests,

  • perpetuate many of NCLB/ESEA’s misguided and harmful policies and practices which failed to improve schools and actually undermined too many over the last decades, and

  • continue to micromanage key aspects of school assessment and accountability in these and other aspects of the draft regulations.

Specifically, we oppose:

  • Requirements throughout that states lower the ranking of schools not testing at least 95% of their students. This proposal unacceptably attacks parents’ right to protect our children from the misuse and overuse of standardized tests by opting them out of specific standardized tests. This requirement should be deleted.

  • Section 200.14, 200.18’s requirements that states set three levels and single accountability labels for schools, and give “much greater weight” to state test scores in this labeling process. Public education is a right, not a competition. There is no need to focus school accountability on “differentiating” among schools or demanding that states establish of three arbitrary levels and simplistic single school labels. Contrary to the draft regulations’ assertions, parents are not asking for this. Public opinion polls consistently show that parents put little stock in single standardized test scores. These requirements should be deleted.

  • Section 200.18’s requirements that certain students be classified as “consistently sub-performing” on state tests, and the justification of this as the way to know if struggling students are receiving the help they need. Standardized tests, which most states will use under pressure from the draft regulations if approved without change, are historically and by their nature biased against low-income children and children of color. The proposed system will only serve to label and sort them disproportionately, which research warns may lead to increased retention and drop out rates. It will also make schools and districts more apt to use test preparation and test drill as “supports.” This language should be deleted and replaced with language that strongly encourages more focus on alternative and teacher-made assessments. For example, the cutting-edge work done by the Consortium on Chicago School Research on students’ “on-track” status focuses on classroom grades, not standardized test scores.

PAA supports the draft regulations’

  • repeated references to the inclusion of parents along with other stakeholders in planning and implementing state report cards and school improvement processes, although the language could be more specific and comprehensive,

  • inclusion of financial and program equity indicators in school report cards,

  • attention to homeless children, children in foster care and the children of members of the Armed Forces, and

  • requirement that charter schools include local demographic and academic information on their annual report cards.

Further, we recommend that the lists of suggested indicators of school progress and school improvement strategies throughout specify the following measures:

  • increasing active parent involvement in the school and in their children’s education through such means as providing additional time for parents and teachers to meet, extra resources for increased home-school communication, and a meaningful parent voice in school governance,

  • implementing more inclusive deliberation and requiring more effective and extensive improvement steps before a school is closed,

  • lowering class size, and

  • increasing comprehensive services to children….

…all of which research shows are far more powerfully related to improved student learning than the strategies that the regulations do specify – turning schools over to charter schools, closing schools, or increasing the use of technology.

Please also incorporate into our submission the PAA position paper, “What is a Quality Education?” found here:

Posted on by Julie Woestehoff Posted in Misc

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