Dear Mr. Bolling,

First, I wish to thank the Virginia Legislature, the Department of Learning and Innovation, and all of the educational activists for their concern and hard work in creating these guidelines for the use of digital devices in K-12 schools.  Virginia now can proudly add its name to the small list of states that are helping set guidelines for the safe and effective deployment of educational technology with schoolchildren, who are particularly vulnerable to its negative physical and mental health effects.

I would like to add comments, based on my 20 years of experience teaching grades 4 and 5 in Massachusetts, to those of the many concerned Virginians. Since retiring from teaching three years ago, I have also worked  -- first as a volunteer, and for the last year as a part-time staff person – as the Screens in Education Program Coordinator at the Children's Screen Time Action Network, which is, in turn, a program of Campaign for a Commercial Free Childhood.

My experiences in the last half dozen or so years as a public school teacher drew me to the Children’s Screen Time Action Network as a retired volunteer at the end of 2018. During those years I began to notice that an increasing number of students in my classes were having difficulty focusing on educational tasks. These same students seem to have a lower tolerance for frustration and boredom, and often created their own distractions when normal class routines were, for them, insufficiently stimulating. I spoke to my veteran teaching colleagues about this, and they agreed: there was something in the digital culture that was making these students less ready for learning. I began to discuss this concern with parents and children, which confirmed my suspicion: the students with the most difficulty sustaining focus were those that were the heaviest users of digital technology at home. I sometimes would ask students what they were thinking about when I needed to cue them in. For boys, it was video games; for girls, social media.

These devices were not designed for young children – and certainly not to “respond to the changing technological needs of students and teachers.” Children do not have technological “needs,” unless you consider paper books, pencils, and paper technology. Furthermore, the skills they “need” to succeed have not changed much over time either. Employers want students who can solve problems, think critically, work in collaborative teams, and communicate orally and in writing. Indeed, these skills, best taught through the guidance of caring teachers in large and small-group discussions and one-on-one coaching will guarantee that “students are ready to meet the demands of an ever-changing labor market.”

Teachers and policy makers need not fret either that students will lose out on “21^st Century learning techniques if digital devices are limited in schools.  These days, basic computer skills are learned at home. And employers do not worry about students being able to use specific computer programs. After all, any specific program is unlikely to still be in use by the time they graduate.  Yes, coding and computer logic are helpful for some jobs, but these need not be taught in K-12 schools, and/or can be learned through high school electives and post-secondary education if the core thinking skills are in place.

For guidance on what are proper uses of digital technology in schools, the Department of Learning and Innovation should refer to the Ed Tech Triangle. Developed by the non-profit organization, EverySchool, those evidence-based guidelines contained there go a long way to ensure that “school digital devices are being used to enhance teaching and learning.”

The Department should also consider the following guidelines when thinking about the types of technology to be introduced in K-12:

• In general, digital devices should be avoided in elementary school classrooms given the proven benefits of offline learning, and lack of evidence supporting the efficacy of screen-based instruction during these years, and the documented physical and mental health concerns related to the use of digital devices by young children. The introduction of online testing in the elementary grades should be prohibited, as it requires the introduction of digital technology in the primary grades (in order to prepare students for the tests). 
• Beginning in middle school, limited use of technology is acceptable to introduce word processing, spreadsheets, and computer-based research. Otherwise, technology should only be used when there is no equally good way to teach a particular skill or concept. 
• Technology-related skills needed by graduation – including word processing, the use of spreadsheets, and the ability to conduct internet- and computer-based research – should continue to be taught in high school, subject to established safe use guidelines. (One reason for postponing the use of computer-based research until secondary school is that  it is only older students that can understand the unethical and manipulative uses of digital technology and can discern good from bad sources.

Given the lack of evidence of positive effects on learning, and the growing evidence of physical and mental health consequences associated with excessive use of digital devices, there are additional policies that the Department should urge and/or require all districts to follow:

• Parents and students should be afforded low-tech and no-tech options whenever requested, including paper copies of all textbooks, reading materials, worksheets, and testing materials.

• Teachers should be instructed to minimize the amount of homework assigned that must be done online. Requiring students to spend time on digital devices interferes with families' abilities to maintain healthy limits on screen time.

• Cell phone use should be prohibited in all classrooms during class time, with phones out of reach.
  

• Districts should develop, institute, and enforce policies to ensure that schools and teachers follow manufacturers' guidelines regarding safe use of digital devices. Parents should be made aware of all manufacturers’ ergonomic and safe use guidelines, and should sign off on their understanding and acceptance of these guidelines prior to devices being issued to students.

• Districts should create teacher, student, and parent education programs about the known and potential health consequences of the overuse of screens, including physical and mental health consequences, and the potential misuses of student data; and such programs should be delivered to all constituents on a yearly basis.  

• School guidance counselors should be trained to recognize and treat potential negative mental health effects of overuse of social media and online gaming.

• In planning for safe use of digital devices for school and homework, administrators should gather and make public data regarding: (a) in-school screen usage by grade level; and (b) the amount of time children, by grade level, spent on digital devices at home doing school-related work.

These policies, along with the helpful guidelines and comments suggested by others for protecting students’ physical health, should not be viewed as just a utopian “wish list.” Let’s take our duty of care toward students seriously and only use technology when it serves a vital learning purpose, and only when it is used in a safe manner. We are at a similar stage in our rush toward educational technology now as we were during the introduction of the automobile over 100 years ago: it is viewed as a “must have,” and adapted with little regard to public safety and public health. Consumer advocacy, many years later, resulted in safeguards like seat belts and other crash safety features. Let’s not make the same mistakes with digital technology.  There is no great rush -- other than that of the industry to capitalize on the pandemic-related surge in remote learning -- to increase the use educational technology. The worst reason to use it is because it is available. A deliberate, thoughtful approach is required. The State of Virginia has begun to take such an approach, but it must be willing to take a broader, holistic look at all of the evidence regarding ed tech’s effectiveness and its relationship to at-home use before issuing guidelines. I hope that these comments are helpful in that regard.