Thank you for the opportunity to offer the following comments regarding the Proposed Amendments to the SOA (8 VAC 20-131)

8VAC20-131, Student achievement expectations –

·         The provision to allow students in grades three through eight to have opportunities to take an expedited retake of a SOL tests is past due, much needed, and should be a high budget priority for the Commonwealth.

·         In addition to retake opportunities, children need to be afforded the opportunity to take tests early by offering multiple test windows.  The idea that every child can be at the same place on the same day is profoundly outdated.  Children should be able to demonstrate their mastery when ready and then to move on to the next program of study.

8VAC20-131-50, Diploma requirements -

·         The proposed revision in accordance with HB 2028 and SB 986, that beginning with the ninth-grade class of 2016-2017, students would be required to be trained in emergency first aid, CPR and AEDs to be awarded a Standard or an Advanced Studies Diploma, in 8VAC20-131-50, is the wrong way to accomplish a noble purpose.  From a diploma perspective, it is a move in the wrong direction. The GA and BOE just consolidated diploma types and now we are adding requirements that are/can be/should be part of the already required courses of Health and Physical Education as an additional “add on” requirement.  These skills are very important, but it makes a great deal more sense to require that they be part of courses already required for graduation.  Further, teaching these skills requires equipment.  Will there be funding for this to help schools who lack the necessary equipment?

8VAC20-131-80, 8VAC20-131-90, 8VAC20-131-100 – Instructional programs in elementary, middle and secondary schools -

·         More remediation and opportunities for students who need it make a great deal of sense, but will the SOQ be funding this?  Summer and remediation programs have been drastically impacted by budget cuts the past 5 years.

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

·         Eliminating the 140 clock hour requirement for a standard credit and replacing it with the requirement to demonstrate mastery of the course content is past due and one of the most needed of the proposed changes!

8VAC 20-131-20 – School and community communications –

·         Language to require yet another notice requirement to parents about any sensitive or explicit materials that may be included in the course, the textbook, or any supplemental instructional materials is impossible to define and wholly unnecessary.  Local School Boards already have policies and procedures in place for when a parent wants to challenge materials.  Those challenges are rare, and when they do occur they involve concerns or sensitivities that are far from universal and therefore nearly impossible to anticipate.   This change would require that there be a definition of “sensitive” and trying to define this andanticipate in advance what the multitude of families we serve will consider “sensitive” simply isn’t possible.  Leave this as it is…people who encounter something that is bothersome to their sensibilities should have a means to express their concerns and have them considered at the local level, and they already do.