I am in strong opposition to the amended Every Student Succeeds Act (ESSA) measures proposed by the Virginia Department of Education and approved by the Virginia Board of Education. Along with other advocates for public education, I have many concerns about this plan but rather than detailing my issues with the actual changes, I will focus on the misguided basis for the heavy handed amendments in the proposed plan.  My major objections are listed below and I have included documentation that supports my statements where possible so there is no basis for Secretary Gudierra to claim that it is misinformation https://x.com/annabryson18/status/1833847925635494093?s=42).  

• There was no valid reason to make these drastic changes to Virginia's ESSA measures. Early in the Youngkin administration the Governor claimed that there was a need for greater accountability (https://www.washingtonpost.com/education/2022/05/19/virginia-schools-student-achievement-youngkin/) in Virginia’s public schools but that was based on erroneous comparison of the Virginia SOL (Standards of Learning) and NAEP (National Assessment of Education Progress) test results. If the Youngkin administration had properly compared NAEP and SOL proficiency levels by mapping results for comparison (https://nces.ed.gov/nationsreportcard/studies/statemapping/), very different conclusions should have been made. The data would have shown that students in Virginia performed as well or better than students nationwide (https://nces.ed.gov/nationsreportcard/studies/statemappingtool/#/state/Virginia). 

• The Governor claimed that there was an “honesty gap”, that we were claiming that students and schools were doing better than they were actually doing.  This was incorrect. Since the Administration began making their false claims, numerous educators and politicians have objected (https://www.washingtonpost.com/education/2022/05/19/virginia-schools-student-achievement-youngkin/)but that has not stopped Governor Youngkin, his Secretary of Education and his Superintendent of Public Instruction (formerly Jill Balow and now Lisa Coons) from repeating these falsehoods (https://fb.watch/nB6O4yK2Q9/). 

• Even now, two years after this claim was debunked (https://www.washingtonpost.com/education/2022/05/20/youngkin-wrong-about-student-naep-scores/)  in many publications, with errors detailed here (https://www.4publiceducation.org/post/gaslighting-the-public-misinterpreting-student-performance-and-naep-scores), the Governor  has not backed away from the fact his conclusions were the result of faulty analysis of the data. This alleged ‘honesty gap’ is still being used )https://www.foxnews.com/politics/education-bedrock-american-dream-youngkin-t)ells-reagan-forumells-reagan-forum)  by the Youngkin administration as a rationale for this drastic overhaul of Virginia's public school accountability plan.  

• If only the administration had properly analyzed the data in the first place they would have been forced to agree with the consensus that Virginia’s schools are among the best in the country and that the accountability system did not need such a drastic overhaul. Instead they continue to lean on that misinformation to rationalize this major and deleterious change in the accountability plan.  

• All involved, including those who have developed the proposed plan, admit that more than half of Virginia schools will ‘fail’ under this amended plan.  Why is this an acceptable outcome in light of the fact that Virginia’s schools were rated among the best in the country by US News and World Report:  #4 in 2023 (https://www.usnews.com/news/best-states/virginia) but then the ranking dropped to #10 in 2024 (https://www.usnews.com/news/best-states/rankings) 3 years into the Youngkin administration !!!!  Recently a CNBC study reported that “Virginia’s biggest competitive strength is its education system, ranked No. 1 in the nation…[and] That appears to be translating to solid test scores.”  (https://www.cnbc.com/2024/07/11/virginia-americas-top-state-for-business-nations-best-schools-solid-infrastructure.html)

• Of course not all students in Virginia are excelling academically, and it should be a priority to help those students. Schools with high proportions of English language learning students, schools in rural communities, and Title 1 schools tend to perform lower on standardized tests but Virginia is not doing what is the proven way to improve academic performance for those underfunded school systems.  It is known that increasing resources to underfunded schools is the way to improve academic achievement (https://www.urban.org/sites/default/files/2022-12/Will%20the%20Virginia%20Governor’s%20Push%20for%20Higher%20Expectations%20on%20State%20Tests%20Affect%20Student%20Learning.pdf), Yet Virginia continues to allow a huge “support gap” in these schools and the Governor  rejects providing extra funds to the neediest schools (https://vadogwood.com/2024/03/12/is-the-governor-gaslighting-virginia-about-k-12-education-funding/).  

•  It is well established that raising expectations is NOT the way to increase academic achievement (https://virginiamercury.com/2023/03/29/virginia-explained-the-debate-over-student-expectations/) but the Youngkin administration continues to use that ineffective strategy. Why is the Youngkin administration so dead set against providing what schools need to be successful academically when we know it is not raising expectations?  

• The Youngkin administration claims that the new “school performance and support system is intended to find where there are weaknesses and help the schools that need the most support to ensure their students are getting the world-class education they deserve.” However, there is no plan to provide additional support  (https://newsvirginian.com/news/state-regional/education/virginia-schools-education-board/article_5f39de2f-cf9a-5cbc-9ab1-fccf474ef059.html) and it generally takes an additional 40% to 200% in funding for students in poverty to have educational outcomes comparable to students who do not come from poverty, according to studies of funding adequacy (https://edtrust.org/wp-content/uploads/2014/09/FundingGapReport_2018_FINAL.pdf#page=7) . 

• Although the Governor protests that in recent budgets school funding has improved, the state has yet to adequately fund K-12 education and does not meet the funding levels recommended (https://jlarc.virginia.gov/landing-2023-virginias-k-12-funding-formula.asphttps://jlarc.virginia.gov/landing-2023-virginias-k-12-funding-formula.asp)  in the JLARC (Joint Legislative Audit and Review Commission) study, and teacher salaries still lag behind the national average (https://jlarc.virginia.gov/landing-2023-virginias-k-12-teacher-pipeline.asp).

• We must question why the Youngkin administration wants to bring down a well functioning public school system, one that is functioning remarkably well in light of the underfunding of K-12 education. If what has happened in other states can be applied to Virginia, failed ratings may be a setup for a state takeover and the privatization of public K-12 schools. Is that the strategy behind the Youngkin administration’s change in how to measure academic achievement - rationalizing the privatization of Virginia’s public schools?

• There are other reasons to object to the revised ESSA measures and I will mention a couple without going into the details of the problematic plan. 

  •  The plan is not well developed nor is it reviewed by independent experts in elementary and secondary education policy.  There is a desperate need for an independent review of the amended Virginia’s ESSA plan but also of the potential consequences to Virginia’s students and educators if the plan is approved as it stands. 

  • The plan does not increase transparency about how students are performing. Currently there is abundant performance data publicly available online (https://schoolquality.virginia.gov/). There is no indication the proposed plan revisions will improve transparency.    

There are many details in the plan about which I disagree, but my intent here is to point out the invalid basis for the drastic revision of the ESSA measures by the Virginia Department of Education.  There is a need for the US  Department of Education to carefully evaluate the plan that is being submitted for ther approval.