Thank you for the opportunity to offer comment regarding the proposed amendments to the Standards for Accrediting  Public Schools in Virginia.

Re: 22.1-253.13:4 Standard 4 Student Achievement and Graduation requirements

D. 2. Proposed requirement that students, beginning in 2016-17, be required to be trained in CPR, AEDs, and first aid is redundant and unnecessarily burdensome.

The events that inspired the introduction of this legislation are indeed tragic and certainly more citizens need to be trained in CPR, the use of AEDs, the emergency first aid. The separate requirement that training in these skills be a condition of licensure for teachers to whose care we intrust our children is a reasonable one (22.1-298.1, D4). The addition of training in these skills into the Standards of Learning for health instruction (22.1-253.13.1. Standard 1, B) is likewise a reasonable requirement and will result in a citizenry widely trained in these skills. Local school boards should, however, be provided with state funding in order to pay the costs of training and equipment without further stretching  scarce local funds and contributing to further inequity in state funding across Virginia school divisions.

Since all Virginia students must take health in the 9th grade in order to earn a standard or advanced studies diploma, it is redundant to then separately require that students be trained in these skills as a condition of graduation. Guidance counselors and other school personnel diligently and carefully work wth high school students to ensure that all graduation requirements are met. The addition of another requirement, in this case a redundant one, presents an unnecesdsary burden on local schools that are already stretched to fulfill unfunded mandates and underfunded SOQ.

Re: 8 VAC20-131-30 Student achievement expectations

A provision to allow students in grades 3-8 to have expedited retakes on SOL tests...

School divisions welcome accountability  for producing graduates with college, career, and innovation-ready skills. SOL tests are designed, however,  to measure attainment of certain discrete-point knowledge and can also serve as one measure of reading skills. Unfortunately, reports from across the U.S., indicate that the current over-reliance and narrow focus on achievement as measured by standardized testing has severely diminished the richness of the learning culture of our classrooms and hindered authentic, inquiry-based learning experiences  that used to produce the innovators and entrepreneurs that were the envy of the world. To not recognize this reality is naive.

Although the proposed provision to allow retakes in grades 3-8 may do little to broaden the conversation about multiple measures of achievement and may only lead to even more skewed emphasis on SOL tests and the pervasive culture of overtesting (testing, to prepare for the test, in order to prepare for the test, etc.) that exists, allowing retakes would at least acknowledge the inherent inequity and out-of-date pedagogy of one-shot testing.

Regarding the requirement that students failing an SOL test receive remediation, there is already sufficient language in the SOA indicating the responsibility of the school division to provide remediation. This new language seems redundant and unneeded.

Re: 8VAC20-131-110. Standard and verified units of credit

The proposal to replace the 140-clock hour requirement for a standard credit with demonstration of content mastery is a welcome change and recognizes the changing modes of delivering instruction to include online and blended models. The wisdom of this amendment also applies to the removal of clock hour requirements for summer school courses (8VAC20-131-120).

Re: 8VAC20-131-270. School and community communications

The requirement to give notice to parents about sensitive or or explicit materials is unnecessary, overly vague, and unenforceable. School boards are already required to establish procedures through which parents can challenge the use of supplemental materials. Given that it would be impossible to establish a common definition of "sensitive materials" in alignment with diverse community standards, teachers and schools would be left in the position of having to guess what might possibly be considered "sensitive" to any one parent. Given the vision of the Board of Education to "derive strength from diversity", the proposed requirement seems incongruous with that vision.