Bravo for the State Board of Education in Virginia for recognizing that the performance of far too many children and schools in the Commonwealth is sub-par, that the existing performance and accreditation regime is producing far too many "false positives"--and for resolving to bring K-12 education in the Old Dominion into the 21st Century. The proposed new Framework is a huge improvement in a dozen ways. While implementing it will undoubtedly be a heavy lift and some people won't like the revelations (and hard work) that it portends, in the long run this is what Virginia's schoolchildren, voters and taxpayers need and deserve. Congratulations!

I commend the Commonwealth for making the following changes to its School Performance and Support Framework, which move Virginia closer to best practice, and support the twin goals of equity and excellence:

1) ELL FOCUS. The new accountability system stops the abhorrent practice of excluding the progress (or lack thereof) of Virginia's English language learners. Progress in English language proficiency is now part of the "mastery" calculation at each grade band. Under the old state accreditation system's combined rate, non-proficient English Learners were excluded for up to 5.5 years (11 semesters). The new system lowers that adjustment period to 1.5 years.

This will newly include 35,000 students who were excluded under the old state accreditation system.

By including most ELL students in its accountability system, Virginia will encourage school divisions to pay greater attention and provide strong supports to this critical student group.
 
2) N-SIZE adjustment. In the past, VA has left out too many students in its accountability system. Virginia will lower the n-size for disaggregation of information by each subgroup of students for accountability purposes. Virginia will change the minimum n of 30 to 15 students. The State will now better identify low performing schools and provide supports to groups of students within these schools without inappropriately identifying successful schools or permitting unsuccessful schools to avoid accountability.

This is a major step in the right direction!

3) Middle School Advanced Coursework: Prioritizing advanced coursework in middle school to prepare students for success, particularly in math.

This is in line with the recommendations of the National Working Group on Advanced Education, and should significantly increase the number of Virginia students, including those from marginalized groups, ready to access and succeed in challenging high school courses, including Advanced Placement, International Baccalaureate, and Dual Enrollment.

4) Performance Labels: Virginia is proposing clear and transparent language to show how schools are performing and ensure accountability.

Thank you for the opportunity to provide feedback on Virginia's much improved accountability system.

Cordially,

Michael J. Petrilli
President
Thomas B. Fordham Institute

I am writing to express my full support for the new Virginia School Performance and Support Framework. This comprehensive approach is critical to ensuring that our education system is transparent, accountable, and focused on preparing students for success. I strongly endorse the framework for the following reasons:

1. Graduation Rate: Transitioning to the federal graduation rate brings Virginia in line with other states, providing clear and accurate communication about how well our schools are preparing students to graduate on time.

2. Growth and Achievement: Virginia experienced significant learning loss following the pandemic. While progress has been made, we need to continue supporting the Board’s focus on high expectations for all students, ensuring that every student has the resources needed to meet their potential.

3. Chronic Absenteeism: The ALL In VA Plan has successfully decreased absenteeism across the Commonwealth by 16%, with over 1.2 million fewer absences. However, with over 195,000 students still chronically absent, continued efforts are necessary to increase attendance and ensure students are present to learn.

4. English Learners: The current system excludes English learners from accountability for too long. Reducing the exclusion period from 11 semesters to 3 semesters ensures that these 35,000 students receive the support they need sooner, allowing them to become proficient in English and succeed alongside their peers.

5. Performance Tasks: Emphasizing the "5 C's" (Critical Thinking, Creative Thinking, Communication, Collaboration, and Citizenship Skills) starting in 5th grade, along with career exploration in 8th grade, provides students with the holistic education they need to succeed beyond the classroom.

6. Middle School Advanced Coursework: Encouraging advanced coursework in middle school, especially in math, prepares students for future academic and career success. Challenging students early with subjects like Algebra by 8th grade is key to helping them meet the demands of Virginia’s growing economy.

7. Performance Labels and Achievement Targets: Clear and transparent performance labels ensure that schools are held accountable for providing high-quality education, allowing parents and policymakers to make informed decisions about school performance.

8. 3E Framework: By focusing on real-world outcomes, the 3E Framework ensures that students are ready for college, careers, or the military. This new approach measures student success through college course enrollment, earning industry credentials, or military enlistment, providing a holistic view of readiness.

9. Minimum Number of Students for Accountability: Reducing the sample size from 30 to 15 students will identify over 20,000 additional students, including those with disabilities, black students, and English learners, who may need targeted support. This change ensures that no student is overlooked and that schools can provide the necessary resources to help all students succeed.

10. Timing of Work: Despite the decline in SOL scores following the pandemic, 88% of Virginia schools remain fully accredited. This framework focuses on restoring excellence by increasing accountability and transparency, ensuring that schools are truly providing the best education for our students.

In conclusion, I fully support this new framework and believe it is a vital step toward restoring excellence in Virginia’s education system. I urge the Board to continue pushing forward with these reforms to benefit all students across the Commonwealth.

I appreciate the VBOE efforts to ensure an emphasis on mastery of content in evaluation of school success. The reduction in delaying evaluation of English Learner’s from the current three years will provide opportunity for needed services WHICH benefits students AND schools.

These standards provide transparency for stakeholders, accountability for programs to be evaluated for efficacy.

These changes have been implemented in Texas, Florida and Tennessee achieving notable growth for students.

The issue with getting more middle schoolers into advanced math is that the population failing has not retained the foundation needed to excel in these classes. Whether due to home life, disability in some form that may not even need an IEP, lack of interest, or other unseen factors, these children will fail. Their foundation in elementary needs to be boosted by much more practice, parental involvement, and tutoring.

There is insufficient detail in the proposed changes to help schools succeed on these new metrics, and if this accountability system is to be implemented this school year it is too late for schools to make changes to student schedules to earn points in the "readiness" category. The overall goals are fine but as always, the challenge is in getting the implementation details right and as it stands this plan sets schools and divisions up to fail and to be negatively labeled for otherwise-happy parents and communities. Some of the many specific details that are lacking include: 

I think it makes sense to revisit the regulations that establish standards for accrediting our schools in a post-COVID educational environment. The pandemic significantly impacted our students' learning, and the current standards are more focused on producing high-quality programs instead of the students' comprehension and performance.

The proposed changes increase accountability for ELL students who have historically been not given the attention they deserve. Especially in schools where there is a high number of immigrant families, this will make a huge impact not only on the students' learning, but also on the schools' performance reports at the end of the school year and SOL scores.  

As a 20+ year parent of public school students, I oppose the proposed changes to "accountability" measures. These proposed changes ignore the expertise of education researchers and leaders in pedagogy who understand the diversity of learners and how their backgrounds or levels of neurodiversity may impact these manufactured "standards" resulting in lessened accountability of provided services to ensure every student receives an equitable education based on needs, which our teachers more than any non-teacher understand best.

This latest GOP unfunded mandate will harm our reputation and allow more takeover of local control of public education. How about focusing on funding our schools rather than dishonestly changing the way they are measured?

These changes are not needed and will set back progress made in Va public education for the last 50 years.

Hello,

I am a longtime Virginia resident, a product of our state's public school system, and the parent of a child in Hanover County Public Schools. Revision of our accreditation standards is a complex issue that can have far reaching consequences for our students, communities, and economy. Revising accreditation standards at this point is simply "putting the cart before the horse". If we are committed to improving our schools, I submit that several steps need to be completed before accreditation standards are revised:

1. Clarify successes, failures, and achievable goals
2. Detailed proposal to address failures and continue successes
3. Funding specifically to execute the plan
4. Measure the results
5. Revision of Standards

The Action Summary (https://townhall.virginia.gov/L/viewaction.cfm?actionid=6308) provides statistics to state problems, then contradicts itself by saying "Without a clear picture of the relationship between school performance and student performance, neither the Board nor the General Assembly can find the proper solutions to the problems faced by Virginia students".

If the statistics cited in the Action Summary are preliminary and require further study to obtain a "clear picture", then that should be Step One, followed by planning and funding. It also focuses on problems without including the successes of our state's public schools. If we care about our kids and communities, then we should also be asking "what are we doing right"? Wouldn't that also be necessary for a "clear picture"?

 We need to know what standards we are aiming for first. I believe that the Board can accomplish this without harming the accreditation of our public school system. We cannot risk our students' pathways to careers and higher education, as well as potential devaluation of property values in our communities.

I respectfully urge the Board to refrain from any action on revisions to the accreditation standards, and instead, work towards that "clear picture" with an achievable path forward.

Sincerely,

David C. Webb

I am strongly opposed to the amended Every Student Succeeds Act (ESSA) measures proposed by the Virginia Department of Education and approved by the Virginia Board of Education. Along with other advocates for public education, I have many concerns about this plan but rather than detailing my issues with the actual changes, I will focus on the misguided basis for the heavy handed amendments in the proposed plan.  My major objections are listed below and I have included documentation that supports my statements where possible so there is no basis for Secretary Gudierra to claim that it is misinformation.  

• There was no valid reason to make these drastic changes to Virginia's ESSA measures. Early in the Youngkin administration the Governor claimed that there was a need for greater accountability in Virginia’s public schools but that was based on erroneous comparison of the Virginia SOL (Standards of Learning) and NAEP (National Assessment of Education Progress) test results. If the Youngkin administration had properly compared NAEP and SOL proficiency levels by mapping results for comparison, very different conclusions should have been made. The data would have shown that students in Virginia performed as well or better than students nationwide. 

• The Governor claimed that there was an “honesty gap”, that we were claiming that students and schools were doing better than they were actually doing.  This was incorrect. Since the Administration began making their false claims, numerous educators and politicians have objected but that has not stopped Governor Youngkin, his Secretary of Education and his Superintendent of Public Instruction (formerly Jill Balow and now Lisa Coons) from repeating these falsehoods. 

• Even now, two years after this claim was debunked in many publications, with errors detailed here, the Governor  has not backed away from the fact his conclusions were the result of faulty analysis of the data. This alleged ‘honesty gap’ is still being used by the Youngkin administration as a rationale for this drastic overhaul of Virginia's public school accountability plan.  

• If only the administration had properly analyzed the data in the first place they would have been forced to agree with the consensus that Virginia’s schools are among the best in the country and that the accountability system did not need such a drastic overhaul. Instead they continue to lean on that misinformation to rationalize this major and deleterious change in the accountability plan. 

• All involved, including those who have developed the proposed plan, admit that more than half of Virginia schools will ‘fail’ under this amended plan.  Why is this an acceptable outcome in light of the fact that Virginia’s schools were rated among the best in the country by US News and World Report:  #4 in 2023 but then the ranking dropped to #10 in 2024 3 years into the Youngkin administration !!!!  Recently a CNBC study reported that “Virginia’s biggest competitive strength is its education system, ranked No. 1 in the nation…[and] That appears to be translating to solid test scores.” 

• Of course not all students in Virginia are excelling academically, and it should be a priority to help those students. Schools with high proportions of English language learning students, schools in rural communities, and Title 1 schools tend to perform lower on standardized tests but Virginia is not doing what is the proven way to improve academic performance for those underfunded school systems.  It is known that increasing resources to underfunded schools is the way to improve academic achievement, Yet Virginia continues to allow a huge “support gap” in these schools and the Governor  rejects providing extra funds to the neediest schools.  

•  It is well established that raising expectations is NOT the way to increase academic achievement but the Youngkin administration continues to use that ineffective strategy. Why is the Youngkin administration so dead set against providing what schools need to be successful academically when we know it is not raising expectations?  

• The Youngkin administration claims that the new “school performance and support system is intended to find where there are weaknesses and help the schools that need the most support to ensure their students are getting the world-class education they deserve.” However, there is no plan to provide additional support  and it generally takes an additional 40% to 200% in funding for students in poverty to have educational outcomes comparable to students who do not come from poverty, according to studies of funding adequacy. 

• Although the Governor protests that in recent budgets school funding has improved, the state has yet to adequately fund K-12 education and does not meet the funding levels recommended in the JLARC (Joint Legislative Audit and Review Commission) study, and teacher salaries still lag behind the national average.

• We must question why the Youngkin administration wants to bring down a well functioning public school system, one that is functioning remarkably well in light of the underfunding of K-12 education. If what has happened in other states can be applied to Virginia, failed ratings may be a setup for a state takeover and the privatization of public K-12 schools. Is that the strategy behind the Youngkin administration’s change in how to measure academic achievement - rationalizing the privatization of Virginia’s public schools?

• There are other reasons to object to the revised ESSA measures and I will mention a couple without going into the details of the problematic plan. 

  •  The plan is not well developed nor is it reviewed by independent experts in elementary and secondary education policy.  There is a desperate need for an independent review of the amended Virginia’s ESSA plan but also of the potential consequences to Virginia’s students and educators if the plan is approved as it stands. 

  • The plan does not increase transparency about how students are performing. Currently there is abundant performance data publicly available online. There is no indication the proposed plan revisions will improve transparency.    

There are many details in the plan about which I disagree, but my intent here is to point out the invalid basis for the drastic revision of the ESSA measures by the Virginia Department of Education.  There is a need for the US  Department of Education to carefully evaluate the plan that is being submitted for ther approval.

I am in strong opposition to the amended Every Student Succeeds Act (ESSA) measures proposed by the Virginia Department of Education and approved by the Virginia Board of Education. Along with other advocates for public education, I have many concerns about this plan but rather than detailing my issues with the actual changes, I will focus on the misguided basis for the heavy handed amendments in the proposed plan.  My major objections are listed below and I have included documentation that supports my statements where possible so there is no basis for Secretary Gudierra to claim that it is misinformation https://x.com/annabryson18/status/1833847925635494093?s=42).  

• There was no valid reason to make these drastic changes to Virginia's ESSA measures. Early in the Youngkin administration the Governor claimed that there was a need for greater accountability (https://www.washingtonpost.com/education/2022/05/19/virginia-schools-student-achievement-youngkin/) in Virginia’s public schools but that was based on erroneous comparison of the Virginia SOL (Standards of Learning) and NAEP (National Assessment of Education Progress) test results. If the Youngkin administration had properly compared NAEP and SOL proficiency levels by mapping results for comparison (https://nces.ed.gov/nationsreportcard/studies/statemapping/), very different conclusions should have been made. The data would have shown that students in Virginia performed as well or better than students nationwide (https://nces.ed.gov/nationsreportcard/studies/statemappingtool/#/state/Virginia). 

• The Governor claimed that there was an “honesty gap”, that we were claiming that students and schools were doing better than they were actually doing.  This was incorrect. Since the Administration began making their false claims, numerous educators and politicians have objected (https://www.washingtonpost.com/education/2022/05/19/virginia-schools-student-achievement-youngkin/)but that has not stopped Governor Youngkin, his Secretary of Education and his Superintendent of Public Instruction (formerly Jill Balow and now Lisa Coons) from repeating these falsehoods (https://fb.watch/nB6O4yK2Q9/). 

• Even now, two years after this claim was debunked (https://www.washingtonpost.com/education/2022/05/20/youngkin-wrong-about-student-naep-scores/)  in many publications, with errors detailed here (https://www.4publiceducation.org/post/gaslighting-the-public-misinterpreting-student-performance-and-naep-scores), the Governor  has not backed away from the fact his conclusions were the result of faulty analysis of the data. This alleged ‘honesty gap’ is still being used )https://www.foxnews.com/politics/education-bedrock-american-dream-youngkin-t)ells-reagan-forumells-reagan-forum)  by the Youngkin administration as a rationale for this drastic overhaul of Virginia's public school accountability plan.  

• If only the administration had properly analyzed the data in the first place they would have been forced to agree with the consensus that Virginia’s schools are among the best in the country and that the accountability system did not need such a drastic overhaul. Instead they continue to lean on that misinformation to rationalize this major and deleterious change in the accountability plan.  

• All involved, including those who have developed the proposed plan, admit that more than half of Virginia schools will ‘fail’ under this amended plan.  Why is this an acceptable outcome in light of the fact that Virginia’s schools were rated among the best in the country by US News and World Report:  #4 in 2023 (https://www.usnews.com/news/best-states/virginia) but then the ranking dropped to #10 in 2024 (https://www.usnews.com/news/best-states/rankings) 3 years into the Youngkin administration !!!!  Recently a CNBC study reported that “Virginia’s biggest competitive strength is its education system, ranked No. 1 in the nation…[and] That appears to be translating to solid test scores.”  (https://www.cnbc.com/2024/07/11/virginia-americas-top-state-for-business-nations-best-schools-solid-infrastructure.html)

• Of course not all students in Virginia are excelling academically, and it should be a priority to help those students. Schools with high proportions of English language learning students, schools in rural communities, and Title 1 schools tend to perform lower on standardized tests but Virginia is not doing what is the proven way to improve academic performance for those underfunded school systems.  It is known that increasing resources to underfunded schools is the way to improve academic achievement (https://www.urban.org/sites/default/files/2022-12/Will%20the%20Virginia%20Governor’s%20Push%20for%20Higher%20Expectations%20on%20State%20Tests%20Affect%20Student%20Learning.pdf), Yet Virginia continues to allow a huge “support gap” in these schools and the Governor  rejects providing extra funds to the neediest schools (https://vadogwood.com/2024/03/12/is-the-governor-gaslighting-virginia-about-k-12-education-funding/).  

•  It is well established that raising expectations is NOT the way to increase academic achievement (https://virginiamercury.com/2023/03/29/virginia-explained-the-debate-over-student-expectations/) but the Youngkin administration continues to use that ineffective strategy. Why is the Youngkin administration so dead set against providing what schools need to be successful academically when we know it is not raising expectations?  

• The Youngkin administration claims that the new “school performance and support system is intended to find where there are weaknesses and help the schools that need the most support to ensure their students are getting the world-class education they deserve.” However, there is no plan to provide additional support  (https://newsvirginian.com/news/state-regional/education/virginia-schools-education-board/article_5f39de2f-cf9a-5cbc-9ab1-fccf474ef059.html) and it generally takes an additional 40% to 200% in funding for students in poverty to have educational outcomes comparable to students who do not come from poverty, according to studies of funding adequacy (https://edtrust.org/wp-content/uploads/2014/09/FundingGapReport_2018_FINAL.pdf#page=7) . 

• Although the Governor protests that in recent budgets school funding has improved, the state has yet to adequately fund K-12 education and does not meet the funding levels recommended (https://jlarc.virginia.gov/landing-2023-virginias-k-12-funding-formula.asphttps://jlarc.virginia.gov/landing-2023-virginias-k-12-funding-formula.asp)  in the JLARC (Joint Legislative Audit and Review Commission) study, and teacher salaries still lag behind the national average (https://jlarc.virginia.gov/landing-2023-virginias-k-12-teacher-pipeline.asp).

• We must question why the Youngkin administration wants to bring down a well functioning public school system, one that is functioning remarkably well in light of the underfunding of K-12 education. If what has happened in other states can be applied to Virginia, failed ratings may be a setup for a state takeover and the privatization of public K-12 schools. Is that the strategy behind the Youngkin administration’s change in how to measure academic achievement - rationalizing the privatization of Virginia’s public schools?

• There are other reasons to object to the revised ESSA measures and I will mention a couple without going into the details of the problematic plan. 

  •  The plan is not well developed nor is it reviewed by independent experts in elementary and secondary education policy.  There is a desperate need for an independent review of the amended Virginia’s ESSA plan but also of the potential consequences to Virginia’s students and educators if the plan is approved as it stands. 

  • The plan does not increase transparency about how students are performing. Currently there is abundant performance data publicly available online (https://schoolquality.virginia.gov/). There is no indication the proposed plan revisions will improve transparency.    

There are many details in the plan about which I disagree, but my intent here is to point out the invalid basis for the drastic revision of the ESSA measures by the Virginia Department of Education.  There is a need for the US  Department of Education to carefully evaluate the plan that is being submitted for ther approval.

As a resident of southwest Virginia, a parent, and a concerned educator, I oppose the revised accreditation and accountability plan.  The new accountability system discriminates strongly against rural schools where we are often challenged to find math and science teachers even for basic courses, much less advanced ones.   Many of our middle schools are unable to offer the advanced courses that would count towards credit.  If the new system resulted in new funding and support for schools that faced challenges, it conceivably would have some benefit.  However the only purpose of the new plan seems to be to disparage our hard-working teachers, staff, and students.  Creating artificial standards designed to document Virginia schools as failing (the department’s own analysis suggests 70% of Virginia schools would be classified as off-track or in need of support), after the current administration vetoed bills that would have worked to improve our schools, is disingenuous.  This could have severe effects on communities looking to attract employees or businesses, when in the past our public education system has always been a selling point.    

This also creates significant challenges for students who are not native speakers of English and for schools that serve a high proportion of English language learners.  To expect that students newly learning a language would have proficiency enough to have comparable exam scores in other subjects with less than two years in the school system is unrealistic.   The VBOE should be arguing for resources to support these students, not setting them up to fail.

The fact that most of the “public” support for these efforts comes from organizations well-known for their efforts to divert taxpayer dollars away from public schools and into the pockets of private companies seems to be a good indicator of the primary purpose of this attack on public schools.  Please use your positions to support our students and school staff in productive ways, not to needlessly disparage them.

The recent exposure of text scores indicates that Virginia schools need to raise the bar in order to provide a better education to our students. The new framework will work to address the "Honesty Gap" between state assessments and national benchmarks. In doing so, we will obtain a more accurate picture of student performance and help parents to know whether or not their students are on track for true success post-graduation.

We need to increase academic standards and the new system promotes a culture of continuous improvement. The new framework focuses on transparency and accountability while providing real-time actionable data which will enable educators and school administrators to make informed decisions that can directly impact student learning and achievement.

While growth is important, it should not come at the expense of ensuring that students achieve a high level of proficiency. The new framework emphasizes mastery and proficiency over growth. If we are unwilling to make changes to promote higher achievement, we will continue to fail Virginia students and that does not bode well for the future of our state or our country.

My name is Rachel Levy and I am a public school parent & supporter and public school teacher with a PhD in educational leadership and policy. I live in Hanover County, Virginia.

I am firmly opposed to the proposed VDOE accountability measures currently being considered and to the shock-doctrine crisis narrative being promoted by the Youngkin administration and his corporate consultants.

There are many things that can be done to make our schools better for all student--and we should always be striving to--but these accountability measures aren't among them and, in fact, will harm our students, our schools, and our communities. These test and punish policies are recycled from 15 years ago, from the Obama and McDonnell administrations--they didn't work then and were very unpopular, and the same thing is true now. They will unfairly label the vast majority of our public schools as failing, which will set the stage for state takeover of many of our schools and privatization measures. State takeover of schools is not an effective reform strategy, and neither is privatization. It is good, however for corporate and private interests, and it is the agenda of right-wing think tanks such as the Heritage Foundation and Fordham, and even of centrist organizations like the Gates Foundation.

Virginians value and their local public schools and do not want the agenda of these think tanks imposed on their them and their schools. They don't want their schools to be subject to state takeover and privatization. To make our public schools better, we need to invest in them adequately, offer more educational options under the umbrella of our public schools districts, and make sure every student receives a relevant and meaningful education. That's what Virginia parents, students, and citizens want for their public schools.

As a former English for Speakers of Other Languages (ESOL) teacher, I can also tell you that three semesters will not be enough for our ELLs to gain the English proficiency needed to be able to have a fair chance to perform well on these tests. Research shows that such proficiency can take as long as seven years!

Thank you for your time and consideration.

I write to ask you to reject the revisions to the Consolidated State Plan under ESSA for the proposed School Performance and Support Framework. I do sincerely hope that the U.S. Department of Education can see that this is disruption instead of accountability. 

The updated accreditation and accountability system will not work and seems dedicated to punishing schools for having too many English Learner, low-income, or disabled students. 

Despite an expected decrease in standardized scores across the nation post-COVID, the overwhelming majority of Virginia’s schools are nonetheless performing at a higher level than most other school districts in the nation, even accounting for underfunding by the state per the JLARC report. https://jlarc.virginia.gov/landing-2023-virginias-k-12-funding-formula.asp

Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools, but the current VDOE revisions are NOT going to accomplish this. I DO NOT support the Framework’s emphasis on mastery over growth, nor did most of the educators and professionals at the eight listening sessions. While proficiency is important and achievable for many, some students (e.g., English Learners and disabled students) show great success in growth as they journey toward mastery. 

I do not support giving chronic absenteeism such a heavy weight in the performance measures, as it is a measure that is typically outside of a schools’ control, and most districts have seen that efforts to reduce chronic absenteeism have shown minor improvements, but often at the expense of families who are struggling with chronic illnesses. If we want students to progress academically, we need them to be at school, which is why I support greater funding for all schools to ensure that students have access to the arts and activities that keep them IN school.

I do not support reducing the N-size from 30 students to 15 students for reporting, as this will be detrimental to small schools. It will have an outsized impact on smaller schools, particularly rural schools.. 

I strongly DO NOT support the inclusion of middle school advanced coursework in the performance measures. One might say that this “incentivizes schools to challenge students to their fullest potential” but actually it just penalizes schools that cannot offer such classes due to funding, availability, school size, or certified teachers. This is particularly unfair to our rural schools and lower-income schools.

I strongly DO NOT support the requirement for college-level coursework in high school for students to be considered "ready for life." Not only is such coursework inaccessible for the same reasons outlined above, but 

Lastly, it is important to SUPPORT newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency. Thus, I reject your suggestion that English Learners' performance on SOLs count against their schools before they are able to achieve fluency in the language. Changing the requirement from 5-11 semesters to 3 semesters seems like you want some schools to fail merely due to a large number of immigrant families. I truly hope that is not true.

Thank you for the opportunity to provide comments to the revisions to the Consolidated State Plan. I disapprove of the process that you took finding it both opaque and complicated. When I look at the measures that you originally proposed in April before listening sessions across Virginia, they changed very little to the ones that you submitted in July. I am disappointed that I and so many others spent time traveling hours to the listening sessions, just to be shut down during the session, or ignored after the session.

I disapprove of these revised measures, as well, which seem ill thought out, punitive, and overly extensive while offering little guidance or support for schools. They will be disruptive to schools, students, and families while providing little meaningful input. When you combine the sheer number of changes with the intent to also revisit cut scores, this entire plan seems destined to harm rather than help improve education opportunities and outcomes.

It appears that a system of accreditation is being  put in place to ensure our  public schools are "failing" in to justify a future state takeover of  our  schools. 

And,  the continued  comparison of  NAEP and SOL shows the desperation involved to perpetuate the Governor's agenda of "failing" schools instead of  what our schools really need, Funding.

Our students deserve better. The JLARC  study shows that our schools  need better funding!

Please reject any accreditation standards that will label students as "bad", "failing", or that classify schools as "derelict". Virginia has good schools. In 2020, per Forbes and WalletHub, Virginia's schools were fourth in the nation (https://www.forbes.com/sites/reneemorad/2020/08/04/states-with-the-best-public-schools/).  CNBC ranks Virginia's schools some of the best in the nation recently (https://cardinalnews.org/2024/07/15/for-sixth-time-virginia-is-rated-top-state-for-business-here-are-10-takeaways-from-those-cnbc-ratings/). The desire to re-rank them for  the benefit of profiteers is bad for children and Virginia's real estate market. Manipulating data for desired talking points is unfair - a basic premise of good governance is fairness. Perhaps policies that lift students up should be considered instead (ie., the JLARC funding study). This is not to suggest that students be "passed" when truly unsuccessful, but providing them resources to achieve seems like significantly better policy. Instead this process ensures Virginia will spend millions of dollars on tests that tell us what we already know - economics matter. Imagine using test funds to truly improve outcomes instead of predicting them. On the heels of COVID-19, with parents sounding alarms about rising anxiety and depression, it is hard to imagine that Virginia will punish these same students for "not keeping up" or "getting up to speed" on an arbitrary schedule set by the state. Please slow down, think through the implications of the policy shift - good and bad - and do no harm. Lift up Virginia's students, don't put them down. 

There are many unanswered questions and grave concerns about these changes, especially in more rural parts of the state, like where I am in SW Virginia.

We’ve not been told the cost of implementation and how much, if any, additional funding the state is planning to provide to ensure small class sizes and enough experienced teachers are in every school in the state not meeting your new mark of success.

It appears the VA DOE is conveniently ignoring the 2023 JLARC study detailing the systemic underfunding of Virginia’s public schools and placing further unfunded mandates on financially struggling localities.

Too, this appears to be an over-simplified grading system that disregards variables out of the control of public schools, like poverty and home and community life. The high stakes, standardized tests this administration is fixated on never tell the full story about a student, teacher, or school.

The DOE has used the term "honesty gap" when referring to state test scores but the truth is, NAEP and SOL tests are very different from one another and lumping them together creates an apples-to-oranges comparison. For example, proficient on the NAEP test is above grade level and the test isn't given to all students in the state. 

This rush job of an initiative further elucidates a problem we have in education: Just when teachers hit their strides in implementing a program, people removed from the classroom decide to change it.

It’s illogical to expect students who don’t speak English well to perform at the same level as students whose first language is English. The BOE isn’t listening to ELL teachers across the state who’ve shared this concern in much greater detail.

These changes will likely have a domino effect on under-resourced communities when parents decide to eschew the schools in them, further removing desperately needed funding and resources from them.

For good reason, many believe this is more about promoting school choice than about ensuring a quality education for Virginia’s 1.26 million public school students. If we label public schools as failures, they can be privatized for profit and religious purposes. We can confidently infer that almost everyone in favor of these changes is also pro-school choice.

As the parent of high-achieving students in Virginia public schools, it is dismaying to read of the planned changes to accreditation and the harm it will cause our students. Virginia's public school system has been a wonderful place for my children to learn, and the two who have graduated have earned spots at competitive, selective colleges. While no school system is perfect, this misguided attempt to rework the entire accreditation system is going to harm a wide swath of our students. To label local schools as failing our students will not only hurt the students, it will harm the teachers, and the entire community as real estate values near those "failing schools" will drop because uninformed parents will not understand and will not want to buy homes in those zones. To require ESL students to master the English language in just 3 short semesters is cruel and unrealistic. And the 3E strategy is something most parents will not support. Our public schools are for educating our children, not for tracking them into the workforce or military in 7th grade. I would never agree to tracking any of my children. Virginia's job is to educate them so they have unlimited options, not to shut down their options before they are teenagers.

Reject the proposed Statewide Comprehensive Support Plan. This plan threatens the integrity of our public education system and undermines local authority.

Virginia's public schools are among the best in the nation, yet this plan seems designed to artificially lower school ratings and justify an unprecedented state takeover. The drastic reduction in support for Multilingual Learners and the confusing new reporting levels will unfairly penalize our most diverse and vulnerable districts.

This plan appears to advance a political agenda favoring school privatization, bypassing the legislature and ignoring the real needs of our students and educators. Our schools need support, not state control.

If this new accountability system was really good for kids and public education, Secretary Guidera wouldn't need to solicit her "education stakeholders" to flood the public comments with support. 

As a proud product of Virginia Public Schools, I know first hand that Virginia has some of the best schools in the nation.

This plan seems to artificially lower school ratings, meaning that the state would control a larger percentage of our schools without the understanding of the communities affected. 

No one knows what a local school needs better than the community that school serves. In the best interest of all public school students, the state should leave localities in charge of all schools, regardless of the state's measure of performance. The state resources required to create a nuanced approach to a performance improvement plan for each of the schools identified is a waste, as the local community already has identified the problem and asked for the solution: MORE resources to combat their unique challenges.

All of this doesn't even mention the massive cuts to the Multilingual Learners programs, which actually needs an increase in resources so that all Virginians receive a quality education. Spend the massive bloat of money you intended to spend on this plan to deliver valuable resources to those programs and schools most in need.

This whole plan didn't make sense to me until I realized that the goal is to undermine our public education system in an effort to privatize education, not improve Virginia schools. Please look at the details in this plan and speak with your friends, neighbors, and family who work with students every day. They will tell you what they need, and I promise it's not this plan.

Here's the hard truth: some schools aren't getting it done. Kids aren't getting the education they need. COVID put them way behind. That's realization is gonna step on some toes. If you care about outcomes, you welcome the critique and use it to improve.

If your primary concern is that people might feel bad about their schools, either as parents, teachers, or students, then you've missed the whole point. "Little Timmy can't read, but he sure does have pride in his school!" is where that kind of trash leads. Feelings don't mean jack if Timmy can't read or do math. 

I'm a parent of two kids in public schools. I don't care if anyone feels bad about themselves, gets their feelings hurt, or is under a "pall". Give me real data. Make needed changes. Get. The. Job. Done.

Please reject the proposed Statewide Comprehensive Support Plan. This concept of a plan is solely designed to artificially lower scores to lead for easy state takeovers of local school boards  

Virginia has bragging rights over our excellent public schools. The requirement for Multilingual Learners to learn a new language at breakneck pace is designed to unfairly target our most diverse districts.

This “plan” does nothing for our students or our educators. It is designed solely as a backhanded way to privatize our excellent public schools. 

we must reject this concept of a plan. 

I am writing to ask you to reject the proposed Statewide Comprehensive Support Plan. This plan threatens the integrity of our excellent public education system and undermines local authority.

Virginia's public schools are among the best in the nation, yet this plan seems designed to artificially lower school ratings and justify an unprecedented state takeover.

In my opinion, this plan appears to advance a political agenda favoring school privatization, all the while bypassing the legislature and ignoring the real needs of our students and educators. Our schools are not perfect, but they need support, not state control.

Leave schools under local control and reject efforts toward privatization. 

I write in support of the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia.

The current combined accreditation and accountability system is not working. Despite the plunge in student achievement scores post-COVID, the overwhelming majority of Virginia’s schools are nonetheless deemed to be performing at the highest level. Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools.

I support the Framework’s emphasis on mastery over growth. While growth is important, it’s more important for students to achieve proficiency. I also support giving chronic absenteeism a meaningful weight in the performance measure. If we want students to progress academically, we need them to be at school. I also strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to challenge students to their fullest potential. Lastly, it is important to hold schools accountable for newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency.

Thank you for the opportunity to provide comments to the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia and for the excellent work that has been done with the School Performance and Support Framework

I strongly support the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia for the proposed Accountability Framework. 

With this new Accountability Framework, Virginia will finally live up to its disclosure responsibilities under the 2015 Every Student Succeeds Act to Virginia students, parents and communities. As is well documented, Virginia’s current combined accreditation and accountability system failed to reflect the dramatic swings in academic achievement from COVID-era learning loss.

Support Mastery vs Growth Weighting

I also strongly endorse the Accountability Framework’s greater weighting of achievement vs. growth similar to Massachusetts. First, parents’ goal for their kids is to reach proficiency or mastery, not to endlessly grow towards it. Second, Maryland’s accountability system weighs mastery and growth almost equally, and Maryland’s accountability system also failed to reflect COVID-era academic achievement swings. As a result, Maryland is revamping its system.

Support Middle School Advanced Coursework Readiness Factor

Lastly, I strongly endorse the Middle School accelerated coursework readiness factor. Civil Rights leader Bob Moses referred to the ability to take Algebra by 8^th grade as a Civil Rights issue. It has been a longstanding goal of the US Department of Education and many organizations. 

With Algebra in 8^th grade, kids can take without doubling up: Geometry in 9^th grade; Algebra II in 10^th grade; Precalculus in 11^th grade; and Calculus in 12^th grade. That math sequence is crucial for kids who are not only interested in STEM, but any quantitative field, such as economics or business.

As noted at the VBOE meetings, Florida has a similar readiness factor they’ve had place for over 10 years that’s working very well there. And Virginia’s readiness factor should take place immediately, considering Virginia schools should have been accelerating 8^th graders into Algebra who are ready for decades now. 

Just 3 years ago, numerous Virginia math school leaders fervently supported the Virginia Math Pathways Initiative’s (VMPI) initial proposal that no kids should take Algebra until 9^th grade, which copied San Francisco’s inequitable Algebra for None program.  Virginia school districts should not be rewarded for doing or having done their own local district versions of San Francisco’s Algebra for None or decelerating 8^th graders who are ready for Algebra in 8^th grade into Pre-Algebra instead.

But just offering Algebra in 8^th grade is not enough – school districts need to start as early as possible to prepare kids to successfully take Algebra by 8^th grade. The Board of Education adding this readiness factor will provide that incentive. Notably, kids with money are already being prepared – in private schools and via tutors and private math supplement companies, like Kumon and Russian Math.

I write in support of the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia.

The current combined accreditation and accountability system is not working. Despite the plunge in student achievement scores post-COVID, the overwhelming majority of Virginia’s schools are nonetheless deemed to be performing at the highest level. Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools.

I support the Framework’s emphasis on mastery over growth. While growth is important, it’s more important for students to achieve proficiency. I also support giving chronic absenteeism a meaningful weight in the performance measure. If we want students to progress academically, we need them to be at school. I also strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to challenge students to their fullest potential. Lastly, it is important to hold schools accountable for newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency.

Thank you for the opportunity to provide comments to the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia and for the excellent work that has been done with the School Performance and Support Framework.

I write in support of the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia.The current combined accreditation and accountability system is not working. Despite the plunge in student achievement scores post-COVID, the overwhelming majority of Virginia’s schools are nonetheless deemed to be performing at the highest level. Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools.I support the Framework’s emphasis on mastery over growth. While growth is important, it’s more important for students to achieve proficiency. I also support giving chronic absenteeism a meaningful weight in the performance measure. If we want students to progress academically, we need them to be at school. I also strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to challenge students to their fullest potential. 

I write in support of the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia.

The current combined accreditation and accountability system is not working. Despite the plunge in student achievement scores post-COVID, the overwhelming majority of Virginia’s schools are nonetheless deemed to be performing at the highest level. Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools.

I support the Framework’s emphasis on mastery over growth. While growth is important, it’s more important for students to achieve proficiency. I also support giving chronic absenteeism a meaningful weight in the performance measure. If we want students to progress academically, we need them to be at school. I also strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to challenge students to their fullest potential. Lastly, it is important to hold schools accountable for newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency.

Thank you for the opportunity to provide comments to the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia and for the excellent work that has been done with the School Performance and Support Framework

I am writing to support the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia.

The current combined accreditation and accountability system is not working. Despite the plunge in student achievement scores post-COVID, the overwhelming majority of Virginia’s schools are nonetheless deemed to be performing at the highest level. Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools.

I support the Framework’s emphasis on mastery over growth. While growth is important, it’s more important for students to achieve proficiency. I also support giving chronic absenteeism a meaningful weight in the performance measure. If we want students to progress academically, we need them to be at school. I also strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to challenge students to their fullest potential. Lastly, it is important to hold schools accountable for newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency.

Thank you for the opportunity to provide comments to the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia and for the excellent work that has been done with the School Performance and Support Framework

As President of the Thomas Jefferson Institute for Public Policy, and as a former Principal and founder of a private school, I want to thank the Virginia Department of Education for their new school performance and support framework which is an important foundational improvement in Virginia’s education system. 

Sadly, Virginia is the “Lake Wobegon” of education where all of our schools are above average.  The Virginia Department of Education’s accreditation system rates 88% of Virginia schools as high performing.  No schools are rated as unaccredited (failing).  There are, however, wide performance differences between schools and districts.  The current system relies on measures of inputs but lacks any real measure of outcomes.  As a former Principal, I am well aware that time teaching, certification, and lesson plans (inputs) are insufficient measures of performance.  A principal needs to know outcomes not just to know if teachers are effective, but to know if we were providing all of the resources necessary.  This is exactly what the new performance measures are meant to achieve on a broader level -- identify gaps in learning, and target resources to help fill those gaps.  This is foundational!

The current system reinforces a false notion to both parents and elected officials that Virginia’s schools are excellent and undermines efforts for improvement.    The new measures will look at student performance and will weigh student growth and achievement.  Under the new system, it is estimated that only 6 percent of schools would have the highest ranking, while over half would be labeled as “off track.”  Importantly, 3 percent would be labeled as needing support (the lowest score).  This information is critical -- and is not meant to “put down” schools needing improvement, but to guide resources and thinking into how to improve those schools.

There used to be a broad agreement that “knowledge is power.”  In education, this is still the case.  Opposing transparency is indefensible and undermines our schools.  Transparency builds knowledge and is a powerful means of ensuring we are doing the best we can for our students in an increasingly competitive world.  

Thank you for the opportunity to be heard on this important issue.  Nothing is more important in the Commonwealth than ensuring we know how well we are educating our children.  Kudos to the Board for taking on this important task!

I support of the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia.

The current combined accreditation and accountability system is not working. Despite the plunge in student achievement scores post-COVID, the overwhelming majority of Virginia’s schools are nonetheless deemed to be performing at the highest level according to current state standards. Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools.

I support the Framework’s emphasis on mastery over growth. While growth is important, it’s more important for students to achieve proficiency. I also support giving chronic absenteeism a meaningful weight in the performance measure. If we want students to progress academically, we need them to be at school. I also strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to challenge students to their fullest potential. Lastly, it is important to hold schools accountable for newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency.

As discussions around the proposed Statewide Comprehensive Support Plan gain momentum, it is imperative that we examine the implications of this initiative critically. At first glance, the plan may appear beneficial, but a deeper analysis reveals its true nature: a mechanism that threatens the integrity of Virginia’s celebrated public education system. The call to reject this plan is not merely an emotional response; it is a reasoned stance against a proposal that seemingly aims to disrupt our educational landscape for reasons that are anything but transparent.

One of the plan's most concerning elements is its potential to artificially inflate failure rates in our schools. By setting unattainable benchmarks and expectations, this initiative may set the stage for an easy takeover of local school boards, thereby undermining the hard work of educators and students alike. Virginia has long been a beacon of quality education, earning recognition for the excellence of its public schools. To jeopardize this legacy for the sake of political maneuvering is neither just nor constructive.

Moreover, the requirement for Multilingual Learners to acquire a new language at an unrealistic pace raises substantial concerns about equity and accessibility within our education system. The districts that will be most affected by these stringent language requirements are often the most diverse, housing a myriad of cultural backgrounds and linguistic needs. Implementing such a rapid-fire approach to language acquisition demonstrates a fundamental misunderstanding of the challenges faced by these learners and effectively targets the very communities that add richness and diversity to our state.

It is essential to recognize that this so-called "plan" does little to benefit students or educators. Rather, it appears to serve a greater agenda aimed at privatizing Virginia's public schools. Such a move could have far-reaching consequences, undermining decades of progress in public education, jeopardizing job security for teachers, and limiting the resources available for students. It is a veiled attack on a system that has successfully served countless families and communities.

I am reaching out to support of the updates to the regulations Establishing Standards for Accrediting Public Schools in Virginia.

The system for determining accreditation and accountability for schools is broken. After years of statistics that show test scores and other metrics falling following the unnecessarily prolonged closures of schools, under the current system most of Virginia's schools are still magically found to be top performers. It's a laughable shell game that fails to provide transparency to families, and fails out students by pretending that everything is going so well, when it is obvious to everyone we have significant challenges that need to be acknowledged and addressed. We don't help our students by pretending most schools are top performers, even when it is obvious challenges continue to negatively impact test scores and achievement. It's time to update our standards to ferret out our problems and really target and address them.

I support the Framework’s emphasis on mastery over growth. While growth is important, it’s more important for students to achieve proficiency. I also support giving chronic absenteeism a meaningful weight in the performance measure. If we want students to progress academically, we need them to be at school. I also strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to challenge students to their fullest potential. Lastly, it is important to hold schools accountable for newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency.

Thank you for the opportunity to provide these comments. 

I write in support of the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia.

I write in support of the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia.

The current combined accreditation and accountability system is not working. Despite the plunge in student achievement scores post-COVID, the overwhelming majority of Virginia’s schools are nonetheless deemed to be performing at the highest level. Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools.

I support the Framework’s emphasis on mastery over growth. While growth is important, it’s more important for students to achieve proficiency. I also support giving chronic absenteeism a meaningful weight in the performance measure. If we want students to progress academically, we need them to be at school. I also strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to challenge students to their fullest potential. Lastly, it is important to hold schools accountable for newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency.

Please reject these inappropriate changes to accreditation standards. The result will be to penalize schools that are already struggling. I like the idea of transparency and accountability, but the process that has led to the changes being considered has been neither and will result in neither. It honestly seems design to sabotage public schools, especially vulnerable schools in low income areas. Instead, consider providing more state funds to these struggling schools. The end result will be better educated adults who will be more productive citizens.

I write in support of the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia.

The current combined accreditation and accountability system is not working. Despite the plunge in student achievement scores post-COVID, the overwhelming majority of Virginia’s schools are nonetheless deemed to be performing at the highest level. Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools.

I support the Framework’s emphasis on mastery over growth. While growth is important, it’s more important for students to achieve proficiency. I also support giving chronic absenteeism a meaningful weight in the performance measure. If we want students to progress academically, we need them to be at school. I also strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to challenge students to their fullest potential. Lastly, it is important to hold schools accountable for newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency.

thank you for continuing to improve education in the State.

Good afternoon,

I am writing in support of the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia.

The current combined accreditation and accountability system is not working. Despite the plunge in student achievement scores post-COVID, the overwhelming majority of Virginia’s schools are nonetheless deemed to be performing at the highest level. Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools.

I support the Framework’s emphasis on mastery over growth. While growth is important, it’s more important for students to achieve proficiency. I also support giving chronic absenteeism a meaningful weight in the performance measure. If we want students to progress academically, we need them to be at school. I also strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to challenge students to their fullest potential. Lastly, it is important to hold schools accountable for newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency.

Thank you for the opportunity to provide comments to the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia and for the excellent work that has been done with the School Performance and Support Framework

Thank you for creating the new accreditation standards for VA schools. Our district leaders need to be held accountable for providing sub par education to our students. We need high standard and increased transparency . The Fairfax County school board and school leadership are failing our kids and communities. They hide unfavorably data and answer to no one. I fully support your new accreditation standards and thank you for being brave and taking steps to make sure our schools are giving our kids the education they deserve - not just implementing equitable grading and passing kids along regardless of subject mastery. Thank you.

Thank you for adopting the new Virginia Dept of Education Accreditation and Accountability regulations in which school districts/ school boards/ superintendents need to actually provide an education for all students.  Being a parent in Fairfax County, I have witnessed the school board constantly asking for more money, when student enrollment is going down, along with student test scores.  

I have had countless newsletters highlighting how terrible and unfair these changes are, especially to our non-native English speakers.  Well, if after 11 semesters, which is over 5 years of education in Fairfax County, non-native English speakers cannot pass standard of learning, then it's on the teachers.  Instead of constantly asking for more money, why can't this school board think of intuitive ways to meet the non-native English speakers in the middle and adapt their teaching?  My child isn't meeting benchmarks, and they were born in the United States.  

Perhaps these new standards will actually hold school boards and counties accountable to educating our students on standards of learning.  Bravo Dept of Education for holding everyone accountable!

I support changes to school accreditation standards proposed by the VBOE

As a mother with children 10 years apart, one graduating 10 years ago and the others being current seniors in high school, it is incredible how the previous actions of the Board of Education from previous administrations have lowered the standards and quality of education our children receive. I applaud the Youngkin Administration and the Governor’s appointees on the Board for taking this critical step to ensure transparency and accountability actually mean something again in education. It is a shame that those in opposition would rather hide the truth from parents than set our children up for success. Focusing on the 3E framework and approaching it with an “and” mindset instead of “or” is so appreciated from a parent with a child who went to college and 2 that are working on obtaining credentials to enter a high demand, high wage, high growth career upon graduating high school here in the Commonwealth. Thank you for the work, it’s time to restore excellence in education, hold our local Superintendents and Principals accountable for failing to support our children, provide the tailored supports divisions/schools need, and ensuring that parents have a clear picture into their children’s educational journey.  

We write today to strongly support the revised Accountability and Accreditation Framework. The current system is failing to provide the type of transparency families need to assess their child’s school’s performance while also complicating efforts to direct support to schools in greatest need. We fully endorse the Framework’s greater weight given to mastery vs. growth. We also firmly support a mastery index (vs. a simplistic proficiency measure). The use of a mastery index which weights differing student outcomes is critical in incentivizing districts to develop students to their full potential. The old system was focused on students passing their SOLs without providing incentive to encourage students to more fully master material. We also support giving chronic absenteeism a meaningful weight in the performance measure; if we want students to progress academically, we need them to be in school. We strongly support the middle school advanced coursework readiness indicator. Every Virginia middle school student who is properly prepared for Algebra in middle school should have the opportunity to take it in middle school. A middle school advanced coursework readiness factor incentivizes Virginia school districts to offer Algebra to any properly prepared middle schooler (not just in 8th grade), and disincentives school districts from removing such crucial opportunities. It also will incentivize more robust Algebra readiness efforts, which are crucial for Virginia’s future workforce. 

Please reject the proposed Statewide Comprehensive Support Plan. This plan threatens the integrity of our excellent public education system and undermines local authority. Schools should be under local control.

Virginia's public schools are among the best in the nation, data supports this.And ye, this plan seems designed to artificially lower school ratings and justify an unprecedented state takeover.

This plan appears to advance a political agenda favoring school privatization, all the while bypassing the legislature and ignoring the real needs of our students and educators. Our schools are not perfect, but they need support, not state control. I am asking you to reject efforts toward privatization and reject this plan.

I write in support of the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia.

The current combined accreditation and accountability system is not working. Despite the plunge in student achievement scores post-COVID, the overwhelming majority of Virginia’s schools are nonetheless deemed to be performing at the highest level. Families and communities need an honest and transparent accounting of school performance so that they can advocate for improvements within their schools.

I support the Framework’s emphasis on mastery over growth. While growth is important, it’s more important for students to achieve proficiency. I also support giving chronic absenteeism a meaningful weight in the performance measure. If we want students to progress academically, we need them to be at school. I also strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to challenge students to their fullest potential. Lastly, it is important to hold schools accountable for newly arrived English Learners to ensure that they are building content knowledge as well as English proficiency.

Thank you for the opportunity to provide comments to the Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia and for the excellent work that has been done with the School Performance and Support Framework

I am writing in support of the proposed Standards of Accreditation regulations, which will put in place a new school performance and support framework. Virginia students' SOL scores have declined significantly following the impact of the pandemic. Further, Virginia had the largest drop in NAEP scores for 4th graders among all states between 2017 and 2022, with performance declining two times more than the national average in Math and three times more in Reading.  

But even with Virginia’s students struggling greatly, the current accreditation system declares 88% of schools as accredited- the highest category available- in the 2023-2024 school year. The current accreditation system signals that the majority of schools are doing well while our students are falling behind.  The current accreditation and accountability systems are overly complex and mask the true proficiency rates of schools, denying support to students in need.  

Additionally, I support the greater weight placed on mastery. Given the current state of student performance across Virginia, it will ensure high expectations for all students is at the core of the work and all students will meet their potential. 

I am writing in support of the proposed Standards of Accreditation regulations.  In 2022-2023 the number of students that were chronically absent, missing just 2 days of school a month, doubled from 2018-2019. As shown through Virginia's SOL results, students in grade 3-8 who missed 18+ days of school scored?18% lower than students with regular attendance. Students in grade 3-8 who missed 36+ days (2 months of school) scored 31% lower than?students with regular attendance in reading. Students cannot learn if they are not in the classroom.  

The Virginia Department of Education has provided deep support to schools to address chronic absenteeism, including through the ALL In initiative. Divisions have also stepped up and implemented policies and practices to ensure students are regularly attending school. Chronic absenteeism is a focus of the current system and should continue to be a focus under the new school performance and support framework. We appreciate the work the Virginia Board of Education and school divisions have done to focus on chronic absenteeism and ensure that chronic absenteeism alone will not lead to a school’s final label.