I write to ask you to reject the revisions to the Consolidated State Plan under ESSA for the proposed School Performance and Support Framework. I do sincerely hope that the U.S. Department of Education can see that this is disruption instead of accountability. 

The updated accreditation and accountability system will not work and seems dedicated to punishing schools for having too many English Learner, low-income, or disabled students. 

Despite an expected decrease in standardized scores across the nation post-COVID, the overwhelming majority of Virginia’s schools are nonetheless performing at a higher level than most other school districts in the nation, even accounting for underfunding by the state per the JLARC report. https://jlarc.virginia.gov/landing-2023-virginias-k-12-funding-formula.asp

Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools, but the current VDOE revisions are NOT going to accomplish this. I DO NOT support the Framework’s emphasis on mastery over growth, nor did most of the educators and professionals at the eight listening sessions. While proficiency is important and achievable for many, some students (e.g., English Learners and disabled students) show great success in growth as they journey toward mastery. 

I do not support giving chronic absenteeism such a heavy weight in the performance measures, as it is a measure that is typically outside of a schools’ control, and most districts have seen that efforts to reduce chronic absenteeism have shown minor improvements, but often at the expense of families who are struggling with chronic illnesses. If we want students to progress academically, we need them to be at school, which is why I support greater funding for all schools to ensure that students have access to the arts and activities that keep them IN school.

I do not support reducing the N-size from 30 students to 15 students for reporting, as this will be detrimental to small schools. It will have an outsized impact on smaller schools, particularly rural schools.. 

I strongly DO NOT support the inclusion of middle school advanced coursework in the performance measures. One might say that this “incentivizes schools to challenge students to their fullest potential” but actually it just penalizes schools that cannot offer such classes due to funding, availability, school size, or certified teachers. This is particularly unfair to our rural schools and lower-income schools.

I strongly DO NOT support the requirement for college-level coursework in high school for students to be considered "ready for life." Not only is such coursework inaccessible for the same reasons outlined above, but 

Lastly, it is important to SUPPORT newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency. Thus, I reject your suggestion that English Learners' performance on SOLs count against their schools before they are able to achieve fluency in the language. Changing the requirement from 5-11 semesters to 3 semesters seems like you want some schools to fail merely due to a large number of immigrant families. I truly hope that is not true.

Thank you for the opportunity to provide comments to the revisions to the Consolidated State Plan. I disapprove of the process that you took finding it both opaque and complicated. When I look at the measures that you originally proposed in April before listening sessions across Virginia, they changed very little to the ones that you submitted in July. I am disappointed that I and so many others spent time traveling hours to the listening sessions, just to be shut down during the session, or ignored after the session.

I disapprove of these revised measures, as well, which seem ill thought out, punitive, and overly extensive while offering little guidance or support for schools. They will be disruptive to schools, students, and families while providing little meaningful input. When you combine the sheer number of changes with the intent to also revisit cut scores, this entire plan seems destined to harm rather than help improve education opportunities and outcomes.