Thank you for the opportunity to provide feedback.  I have a few notes included below to consider:

8VAC20-131, Student achievement expectations –
•  I agree that it is important for the Board of Education to permit students in grades
three through eight to have opportunities to take an expedited retake of a Standards of
Learning tests.  This should be a high budget priority as students should be afforded this opportunity.  This is a priority area that has been supported by VASS.

• I agree with the provision to require students who fail to achieve a passing score on all
relevant Standards of Learning tests in grades three through eight, and for students who fail
to achieve a passing score on an end-of-course Standards of Learning test required for
verified credit be required to participate in a remediation program or some other form of
remediation. However, I'm concerned about the lack of adequate funding for this provision.  School divisions across the state have received decreased funding for remediation programs over the last several years.  Will additional funding be provided for this provision? 

 •It is necessary for the Board of Education to work toward or research-based assessment program that accurately assesses content and college/career readiness skills.  This cannot be accomplished through multiple choice assessments alone.  School divisions are having to invest a great deal of time to develop these assessments and/or funding to purchase assessments to supplement the state testing program.  It will also be important to vertically align assessments (especially in English:Reading and Mathematics for grades 3-8) so that school divisions can accurately measure student growth over time.  Vertical alignment was being discussed several years ago in Virginia, but no longer seems to be a priority area for the VDOE.  VASS and school divisions across the state continue to advocate for a balanced assessment approach.    

8VAC20-131-50, Diploma requirements -
• While I feel that the requirement for students to be trained in emergency first aid, cardiopulmonary
resuscitation, and the use of automated external defibrillators to be awarded a Standard or an
Advanced Studies Diploma in 8VAC20-131-50 is a worthy cause, this requirement is going to present significant cost and logistical issues when implemented.  I would recommend that it be included in the curriculum for required Health/PE courses and not added as an additional requirement for graduation.

8VAC20-131-100 Standard and verified units of credit -

• I agree with the elimination 140 clock hour requirement for a standard credit and the proposed requirement that students demonstrate mastery of the course content. This would provide greater flexibility with both school-based and virtual courses.  It also focuses on student mastery of content rather than "seat time."  This adjustment is long overdue and will be a positive change for our schools.

8VAC 20-131-20 – School and community communications –
• I have a concern about requiring language that would be added to include a notice to parents about any sensitive or explicit materials that may be included in the course, the textbook, or any supplemental instructional materials. School divisions have concerns about this requirement due to the cost and logistical problems. For example, “what is the definition of sensitive or explicit?”  Most school divisions already address this concern with “opt-out” provisions for parents who object to certain materials and\or curriculum review committees that include parents.