NASSP Comments on Race to the Top Guidelines

On August 11, 2009, NASSP submitted the following recommendations, on behalf of its members, to the Department of Education regarding the Notice of Proposed Priorities, Requirements, Definitions, and Selection Criteria for the Race to the Top Fund issued July 29, 2009.

I – Proposed Priorities
NASSP recommends adding a new Proposed Priority 3:

Proposed Priority 3 – Emphasis on Literacy
To meet this priority, the State’s application must describe plans to address the need to (i) offer a literacy program that includes literacy development skills for young children; basic oral language, reading, and writing skills for young students; and higher-order literacy skills, such as the ability to analyze diverse texts and write using critical reasoning, for adolescent students; and (ii) prepare more students, particularly low-income students, English language learners, and students with disabilities for success in school, graduation from high school ready for college and work, and the ability to meet the literacy demands of high-growth, high-wage jobs.

NASSP is a member of the literacy working group that is advocating for a comprehensive literacy bill encompassing early childhood through grade 12, the Literacy Education for All, Results for the Nation Act (not-yet-introduced). Advanced literacy skills are the foundation for many of the priorities expressed in Race to the Top, including improving graduation rates; success in science, technology, engineering, and mathematics (STEM); assuring international competitiveness and meeting internationally-benchmarked standards; and increasing the rate at which students attend and earn credentials at postsecondary institutions.

II, A. – Proposed Eligibility Requirements

NASSP supports the proposed eligibility requirement that a State must not have any legal, statutory, or regulatory barriers to linking student achievement or student growth data to teachers or principals for the purpose of teacher and principal evaluation. However, we urge the Department of Education to ensure that States include multiple academic (e.g., graduation rates, dropout rates, attendance rates, college acceptance rates, and the number of students enrolled in Advanced Placement and International Baccalaureate courses) and nonacademic indicators in their evaluation of principals.

The NASSP Board of Directors approved a position statement on highly effective principals in November 2007. In the position statement, we recommend that school districts examine quantitative and qualitative data pertaining to both academic and nonacademic indicators in their evaluation of principals. The following measurements, in addition to student indicators, are recommended for assessing principal performance: self assessments; supervisor site visits; school documentation of classroom observations and faculty meeting agendas; climate surveys; teacher, other school staff, parent, and student evaluations; teacher retention and transfer rates; and opportunities for student engagement through co-curricular and extracurricular activities and rates of participation. In measuring a principal’s performance based on student indicators, States should use multiple assessments that are aligned with common standards, include performance-based measures, and measure individual student growth from year to year. NASSP suggests the following student indicators: State assessments; portfolios, performance tasks, and other examples of a student’s accomplishments; traditional quizzes and tests; interviews, questionnaires, and conferences; end-of-course exams; comprehensive personal academic or graduation plans; assessments aligned with high school and college entrance requirements; and senior projects.

II, B. – Proposed Application Requirements

Under (a), the State’s application must be signed by the Governor, the State’s chief school officer, and the president of the State board of education. How will the Department of Education ensure that turnover of these positions will not impact the work being done in the state to improve elementary and secondary education?

III, A. – Proposed Selection Criteria

Under (A)(1) and (A)(2), NASSP supports the proposed state reform conditions criterion that would require a State to include information in its application on the extent to which the State has demonstrated a commitment to improving the quality of its standards by participating in a consortium of States that is working toward jointly developing and adopting, by June 2010, a common set of K-12 standards that are internationally benchmarked and that build toward college and career readiness by the time of high school graduation. NASSP is an endorsing partner of the Common Core State Standards Initiative, and to our knowledge, the initiative does not advocate for the joint development and implementation of common, high-quality assessments aligned with the consortium’s common set of K-12 standards, although we are very supportive of this proposed state reform conditions criterion. The NASSP Board of Directors approved a position statement in support of national standards in May 2008. In the position statement, we call on Congress to appoint an independent, diverse group of researchers, practitioners, advocates, and experts to develop a common set of national standards and authentic, reliable assessments beginning with Language Arts and mathematics in grades K-12 and examine the feasibility of national standards in other subjects. We also urge the Department of Education to evaluate the progress being made by States on a regular basis and issue progress reports.

III, B. – Proposed Selection Criteria

Under (B)(1), (B)(2), and (B)(3), NASSP supports the proposed state reform conditions criteria that would require a State to include information in its application on the extent to which the State has a statewide longitudinal data system and that the data is accessible to key stakeholders and used by teachers, principals, and administrators with the information they need to inform and improve their instructional practices, decisionmaking, and overall effectiveness. NASSP is an endorsing partner of the Data Quality Campaign, which advocates for such systems. We would also encourage to the Department of Education to require a State to include information on the extent to which a State, in collaboration with its participating LEAs, has a high-quality plan to encourage and support the training of school leaders to improve their ability to collect, manage, and analyze data to improve and personalize instruction, decisionmaking, school improvement efforts, and accountability.

III, C. – Proposed Selection Criteria

Under (C)(1), NASSP would suggest rephrasing the criterion to state: “The extent to which the State has in place legal, statutory, or regulatory provisions that allow multiple routes to certification for teachers and principals, particularly routes that allow for providers in addition to institutions of higher education; and the extent to which these routes are in use.”

While we can support alternative routes to the principalship, we feel that the proposed guidelines place an inordinate emphasis on alternative certification and do not address the reality that many colleges and universities have prepared and are continuing to prepare outstanding principals. Additionally, the proposed guidelines lack any commitment to supporting those higher education programs that are exemplars in their principal preparation programs. We also have a major concern that the alternative routes will not provide the types of principals who possess the skill sets to impact teaching and learning and the ability to evaluate teachers; in effect, they would essentially not have the background expected to provide instructional leadership. Most importantly, as the emphasis on pay for performance for teachers intensifies, a significant credibility issue will surface as individuals with no teaching experience are expected to evaluate teacher performance in the classroom.

Under (C)(2), NASSP supports the proposed state reform conditions criteria to differentiate teacher and principal effectiveness based on performance. However, we would suggest rephrasing the criteria to state: “The extent to which the State, in collaboration with participating districts, has a high-quality plan and ambitious yet achievable annual targets to: a) examine quantitative and qualitative data pertaining to both academic and nonacademic indicators in their evaluation of principals; b) use measurements, in addition to student indicators, for assessing principal performance; c) use multiple assessments that are aligned with common standards, include performance-based measures, and measure individual student growth from year to year in measuring a principal’s performance based on student indicators; d) employ rigorous, transparent, and equitable processes for differentiating the effectiveness of principals using multiple rating categories that take into account data on student growth as a significant factor in addition to nonacademic indicators; e) provide to each principal his or her own data and rating, and that use this information when making decisions to: i) evaluate principals annually and assisting principals in developing individual professional growth plans that include goals and objectives focused on building principals’ capacity to lead schools to higher levels of success; ii) compensate principals as one component of a district’s school improvement plan, including by providing opportunities principals who are highly effective to obtain additional compensation, creating incentives for principals to improve their performance, and providing recruitment and retention incentives; and iii) reward and dismiss principals based on rigorous and transparent procedures for rewarding and for removing principals after they have had ample opportunities to improve but have not done so; and g) making district evaluation processes available to the public.

Under (C)(5), NASSP would suggest rephrasing the criterion to state: “The extent to which the State in collaboration with participating districts, has a high-quality plan to offer principals ongoing, job-embedded professional development that is aligned with district and school improvement plans and individualized to help principals meet their goals.”

The NASSP Board of Directors approved a position statement on performance-based compensation systems for principals in 2008. The position statement should not be misconstrued as an endorsement of such systems. Rather, the recommendations represent a template for states and districts considering the implementation of such systems.

III, D. – Proposed Selection Criteria

Under (D)(3), NASSP would suggest rephrasing the criterion to state: “The extent to which the State has a high-quality plan and ambitious but achievable annual targets to identify at least 5 percent of schools in improvement, corrective action, or restructuring in the State and support its districts in transforming these schools by:

• Putting in place new leadership and a majority of new staff, new governance, and improved instructional programs, and providing the school with flexibilities such as the ability to select staff, control its budget, and expand student learning time;
• Implementing a school transformation model that includes: hiring a new principal, measuring teacher and principal effectiveness, rewarding effective teachers and principals, and improving strategies for recruitment, retention, and professional development; implementing comprehensive instructional reform, including activities to personalize the school experience; increase student engagement, attendance, and effort, and enable schools to provide the level and intensity of student support needed; extended learning time and community-oriented supports, including more time for students to learn and for teachers to collaborate, more time for enrichment activities, and ongoing mechanisms for family and community engagement; or
• To the extent that these strategies are not effective within three years, converting them to charter schools or contracting with national and state education associations or education management organization; or
• Closing the school and placing the school’s students in high-performing schools.

Since 2002, NASSP has identified over 40 middle level and high schools that serve large numbers of students living in poverty and are high achieving or dramatically improving student achievement through the MetLife-NASSP Breakthrough Schools project. As a whole, the group reflects the diversity of U.S. public schools and represents rural, suburban, and urban communities. The schools are all considered high poverty with at least 40% of their students participating in the free and reduced meals program. They also share a commitment to student achievement and have seen growth over time in such measures as graduation rates, state exam scores, and literacy and numeracy achievement.

Selection criteria for the Breakthrough Schools are based on a school’s documented success in implementing strategies aligned with the three core areas of the Breaking Ranks framework for middle level and high schools that have led to improved student achievement, and include the following:

• Collaborative leadership: professional learning communities, shared leadership, and student and staff leadership development;
• Personalization: attention to all students, mentoring, and school/community connections;
• Curriculum, instruction, and assessment: access to rigorous coursework for all students, differentiated instruction with multiple assessments, data-based decision making, and opportunities for career development.

IV – Definitions

Highly Effective Principal

While NASSP supports a federal definition of a “highly effective principal,” we recommend that a highly effective principal:

• demonstrates awareness of and has experiences with the knowledge, skills, and attitudes needed to effectively lead teaching and learning appropriate to the needs of all students in the school;
• has successfully completed a state approved principal licensure program that builds the knowledge, skills, and attitudes to effectively lead people, lead learning, and manage school operations;
• engages in continuous professional development, utilizing a combination of academic study, developmental simulation exercises, self-reflection, mentorship and internship;
• demonstrates capacity to lead in establishing and maintaining a professional learning community that effectively extracts information from data to improve the school culture and personalize instruction for all students to result in improved student achievement;
• demonstrates knowledge of youth development appropriate to the age level served by the school; and
• demonstrates the capacity to create and maintain a learning culture within the school that provides a climate conducive to the development of all members of the school community.

As mentioned previously, the NASSP Board of Directors approved a position statement on highly effective principals in November 2007.

Graduation Rate

NASSP supported the final Title I regulation that requires States to use a uniform and accurate method of calculating graduation rates consistent with the definition adopted by the National Governors Association in 2005. We have long advocated for such a formula to counter the confusion and inconsistencies in current graduation-rate calculations that make it impossible to compare state performance and blur any views of a nationwide graduation rate.

However, NASSP does have concerns with defining the graduation rate as the “four-year adjusted cohort graduation rate.” Because not all students enter the 9th grade reading and writing at grade level, we have long recommended that the graduation rate be extended to within at least five years of entering high school. NASSP supported language in the 2007 Miller-McKeon Discussion Draft on the reauthorization of the Elementary and Secondary Education Act (ESEA) that would have allowed an extra-year adjusted cohort rate. Under the proposal, a secondary school could make adequate yearly progress if the graduation rate increased an average of 2.5% per year for the adjusted cohort rate or 3% per year for the extra-year adjusted cohort rate.

NASSP feels that a State should be required to use, as a supplement to the four-year adjusted cohort graduation rate, extended adjusted cohort graduation rates that are approved by the Secretary. In addition, we feel very strongly that identified special-needs students who complete high school with a state-approved exit document should have until age 21, inclusive, to be counted as graduates as defined by the Individuals with Disabilities Act. The Miller-McKeon Discussion Draft would have allowed a student who has significant cognitive disabilities to be counted as a graduate upon receipt of a regular high school diploma or State-defined alternate diploma aligned with the completion of the student’s entitlement under IDEA and consistent with State law. NASSP supported this proposal.

Designating a four-year timeframe within which students must exit and graduate from high school goes against what we know about student learning, especially for English language learners, and timelines designated by IDEA. In fact, we should be moving in the opposite direction by allowing students additional time to graduate if they require it without penalizing the school, or less time if they have reached proficiency.

Student performance should be measured by mastery of subject competency rather than by seat time. States that have implemented end-of-course assessments are on the right track and should be encouraged to continue these efforts. And Federal law should reward students who graduate in fewer than four years—which could encourage excellence—rather than simply acknowledge minimum proficiency, and the recognition of high-performing students could help schools that are nearing the target of 100% proficiency.

Student Achievement

NASSP would suggest rephrasing the definition to state: “Student Achievement” means, at a minimum: a) for tested grades and subjects: a student’s score on the State’s assessment under section 1111(b)(3) of the ESEA; and b) for non-tested grades and subjects: an alternative measure of a student’s performance (e.g., student performance on interim assessments, rates at which the students are on target to graduate from high school, percentage of students enrolled in advanced courses, including Advanced Placement (AP) and International Baccalaureate, dual-enrollment, pre-AP and similar rigorous courses at the middle level, rates at which students meet goals in their individualized education program, student scores on end-of-course exams).