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  7:43 pm
Commenter: Heather Gottlieb

Strongly OPPOSE
 

Harm Virginia’s Long-standing Reputation as an education powerhouse and ideal place to locate a business. Simultaneously, taxpayers and legislators will be on the hook for this unfunded mandate while more than half of Virginia’s students, families, and schools will suffer the consequences of shrinking opportunities, especially in rural, low-income, immigrant, and Black and Brown communities. 

 

What will be the impact of ‘failing school’ designations on local communities and property values? Will this make DC or Maryland properties look more appealing for future homeowners and entrepreneurs?

 

2) Create Radically Inappropriate Measures. VDOE has radically changed academic expectations, likely to produce large-scale school-wide failures for Virginia’s school districts by placing 50-70% of Virginia’s diverse schools in a failing category. VDOE changes will increase current inequities for students while requiring already over-extended teachers to earn additional certifications to teach accelerated coursework in middle school mathematics, science, history and social science. 

 

VDOE has reduced the number of semesters before English Language Learners (ELL) are counted as part of a school's performance from eleven semesters to three semesters is inconsistent with best practices. This means that ELL students are tested on English skills instead of the subject matter, which depresses their scores of the school that they attend.  

 

VDOE expects middle and high schoolers to master accelerated coursework above their grade-level (e.g., Algebra 1 and 2, and English 11 courses in middle school, and Advanced Placement or college dual-enrollment courses in high school). This shows a troubling lack of consideration for the hundreds of schools unable to provide accelerated courses due to logistical and financial accessibility, and teacher certification challenges. Additionally, VDOE is ignoring the developmental readiness of students, which means these revised accountability standards may be setting up students to fail. Nevertheless, VDOE added accountability measures to assess all schools based on above grade-level, accelerated work for middle and high schoolers in mathematics, science, history and social sciences.

 

3) Disrupt with No Known Benefits or Additional State Funding. The new VDOE standards artificially downgrade Virginia schools. Parents and educators know this isn’t accurate, as it contradicts Virginia’s above-average scores on SATs and the Nation’s Report Card. In 2024, Virginia was ranked # 1 state for business and education.

 

There is no reliable evidence or studies showing that VDOE’s plan will improve education outcomes for students, families, and schools. The VDOE plan will require all schools and educators to quickly adjust by changing all curricula, learning disability supports, and education methodologies educators have developed for students over the last decade. 

 

This is an unfunded mandate. There are no state funds allocated for VDOE to fully develop or implement their plans, nor has VDOE provided plans or funding to support the 1,000-1,200 schools they will artificially downgrade to failing (i.e., “off track” or “needs intensive support”). The impact will be even worse in rural, currently underfunded school districts with large populations of students who need greater support. This would likely increase funding needs in Virginia, if more than half of Virginia’s schools are re-classified as "failing," according to VDOE’s own projections. 

 

The VDOE places the heaviest burden on already underfunded public schools to fix a problem manufactured by VDOE bureaucrats and their consultants. To education experts, this is a clear effort to siphon off public taxpayer money to private enterprises, instead of improving public schools.

CommentID: 227945