Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Virginia Standards of Accreditation [8 VAC 20 ‑ 132]
Action Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia
Stage Final
Comment Period Ended on 9/25/2024
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9/25/24  11:56 pm
Commenter: Anjy Cramer

Strongly Oppose the New Accountability Framework
 
I am an Arlington parent. I am very against these new VDOE Accrediation Standards
 
I would first like to add nuance to the narrative shared at the last VBOE meeting. At Arlington Public Schools, Carlin Springs Elementary School is NOT failing because of their students' test performance. Rather, it is because of lack of resources. 
 
 
A Tale of Two Schools
 
Below, I will compare statistics between Carlin Springs, (abbreviated as "C-S" below, a Title I school) to Discovery Elementary, a "high performing" one:
 
Carlin Spring's building capacity is 585; as of 6/30/24, 589 students occupied it.
 
(As compared to Discovery, capacity is 630, 515 students in the building as of 6/30/24).
 
 
It's very nice to have a significantly under-capacity school to spread out and learn in! 
 
 
 
Data here: https://www.apsva.us/wp-content/uploads/sites/57/2024/08/APS-Facility-Inventory-SY24_25-08_19_2024.pdf and here: https://www.apsva.us/wp-content/uploads/sites/57/2024/06/U-MEM_281_Membership-Summary-All.pdf
 
 
 
As of 9/24/24, Carlin Springs has five staff vacancies: 1 Educational Administrative Assistant (posted 7/15/24); TWO EL TEACHER VACANCIES (posted 7/10 and 9/5/24), one Exemplary program teacher (posted 9/23/24), and one Title I Academic Support Teacher (posted 9/23/24). THREE CRITICAL STAFF POSTINGS OCCURRED JUST UNDER ONE MONTH OF THE SCHOOL YEAR! 
 
 
(Title I schools are harder to staff because there's so much more need. Food insecurity, health (physical and mental) and economic vulnerability intersect even before we even discuss academic "achievement").
 
Additionally, Carlin Springs is a "CEP school" which means that every single student qualifies for free breakfast and lunch.
 
 
 
 
Meanwhile, Discovery has only one current vacancy for a SPED teacher (posted 5/17/24). The SPED teacher shortage is real. Please fund Special Education too!
 
As of Dec 2023, only 4% of Discovery's kids qualify for Free and Reduced meals.
 
Data here: https://apps2.winocular.com/arlingtonps/workspace/wSpace.exe?Action=wsJobsMain and https://www.apsva.us/wp-content/uploads/sites/57/2024/01/FREE-REDUCED-DECEMBER-2023.pdf
 
 
 
APS English Learners (English Learners - ELs)
 
Data that I personally FOIAed from Arlington Public Schools in May and Sept 2024 shows that at Carlin Springs, almost 75% of the population are English Learners (ELs) as of January 30, 2024. More students speak Spanish in the hallways than English. (Note: APS supports twelve additional languages at C-S, including Pashto, Somali, Tigrinya and Farsi).
 
At Discovery, as of Jan 30, 2024, EL learners hovered around the 1-2% range. The Spanish speaking population is too small to show up in the data without identifying the students. Discovery does support 7 more languages; Mandarin, Japanese and Korean are spoken at home, amongst other languages. 
 
Those are two totally different student profiles who need vastly different EL supports. 
 
[I am unable to attach these results due to lack of attachment capability on this platform. I suppose you can FOIA the data too].
 
 
 
Resource poor schools like Carlin Springs need more TARGETED FUNDING! NOT MORE MANDATES DESIGNED FOR THE COMMUNITY TO FAIL! FIX THE K-12 FUNDING FORMULA as recommended by JLARC FIRST! If schools continue to "fail" afterwards, then let's talk about opportunity gaps and how to fix them.
 
 
An Example: Dual Language Immersion Programs
 
As I started to think through VBOE's reduction in the number of semesters before English Learners are counted as part of a school's performance from eleven semesters to three, I thought of APS' dual immersion program, which my child participated for two years (i.e., 4 semesters). 
 
None of the English-speaking children knew enough Spanish by the middle of the 1st grade (3 semesters) unless they had supports at home (ie., a Spanish speaking parent/tutor or immersive Spanish in private Pre-Ks before matriculation). Furthermore, most if not all of the English speakers, if given a SOL completely in Spanish even at the end of the 4th grade would happily fail them without intensive supports.
 
If dual immersion programs had this level of learning success, we could end every immersion program after the first grade. Of course, at APS, the Spanish immersion program carries on through 12th grade because it takes significant time to become bilingual AND bi-literate in another language, even in Spanish.
 
(The WIDA test, likewise, measures reading, writing, listening and speaking)
 
https://wida.wisc.edu/assess/model#:~:text=Assessments%20designed%20to%20measure%20students,assessments%20for%20grades%20K%2D12.
 
If implemented, the Spanish Learners will not be held to these same ludicrous standards as English learners AT THE SAME SCHOOL!
 
 
English learners cannot learn a language in three semesters, period. You will be testing EL students on their English skills instead of content mastery, which will make their respective schools "fail" too. 
 
 
Last thoughts:
 
My own child at Discovery Elementary, (as you recall, a "high performance school"), failed every single SOL last school year except one. He just cannot focus enough to take a test. APS/VBOE is measuring his lack of executive function, not his content mastery OR growth. He is a one band, bringing down any school's aggregated standardized test scores for accreditation purposes.
 
And this was just for SY 2023-24 to current standards. He will fail any standard that holds him to "intensified"/middle school accelerated courses as he can't test for content he is not academically ready for.
 
A few years ago, we tried a local private school specifically for neurodivergent learners, and it failed him too, so we brought him back to our excellent public school system. I will say though that the best thing about our private school experience was that they did not even conduct standardized tests, just growth unit assessments.
 
 
 
Children are SO MUCH MORE than their test scores.
 
[For a speech I gave to Arlington's School Board on "academic achievement" on 9/17/24, please see here: https://www.4publiceducation.org/post/systemic-academic-failure-a-reality-or-a-choice]
 
 
 
 
Thank you for considering my response when you make your final decision on this matter.
 
CommentID: 228002