FLAVA supports the creation of a diploma Seal of Biliteracy to honor student achievement in a second language. In today's interconnected world, it is not enough to be able to communicate in only one language. Biliteracy supports the 21st century skills of communication, collaboration, and leadership, allowing Virginia's students to compete economically worldwide as well as lead in finding innovative solutions to global challenges.

Knowing a second language is equally important locally. According to YesVirginia.org, the Commonwealth is home to over 700 companies from around the world. International businesses have invested over $5.6 billion and created more than 34,000 jobs over the past 10 years.  

Several states already recognize the critical importance of bilingual communication and global collaboration by awarding a Seal of Biliteracy. These states have adopted a reasonable set of criteria for the selection of students that can serve as a model for Virginia. This low-cost option serves to validate and certify student language skills for employers and others, encouraging and recognizing language study and global awareness.

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

8VAC20-131, Student achievement expectations –

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

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  The idea that every child can be at the same place on the same day is profoundly outdated.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

8VAC20-131-50, Diploma requirements -

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

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

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

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

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

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

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

Thank you for the opportunity to offer comment regarding the proposed amendments to the Standards for Accrediting  Public Schools in Virginia.

Re: 22.1-253.13:4 Standard 4 Student Achievement and Graduation requirements

D. 2. Proposed requirement that students, beginning in 2016-17, be required to be trained in CPR, AEDs, and first aid is redundant and unnecessarily burdensome.

The events that inspired the introduction of this legislation are indeed tragic and certainly more citizens need to be trained in CPR, the use of AEDs, the emergency first aid. The separate requirement that training in these skills be a condition of licensure for teachers to whose care we intrust our children is a reasonable one (22.1-298.1, D4). The addition of training in these skills into the Standards of Learning for health instruction (22.1-253.13.1. Standard 1, B) is likewise a reasonable requirement and will result in a citizenry widely trained in these skills. Local school boards should, however, be provided with state funding in order to pay the costs of training and equipment without further stretching  scarce local funds and contributing to further inequity in state funding across Virginia school divisions.

Since all Virginia students must take health in the 9th grade in order to earn a standard or advanced studies diploma, it is redundant to then separately require that students be trained in these skills as a condition of graduation. Guidance counselors and other school personnel diligently and carefully work wth high school students to ensure that all graduation requirements are met. The addition of another requirement, in this case a redundant one, presents an unnecesdsary burden on local schools that are already stretched to fulfill unfunded mandates and underfunded SOQ.

Re: 8 VAC20-131-30 Student achievement expectations

A provision to allow students in grades 3-8 to have expedited retakes on SOL tests...

School divisions welcome accountability  for producing graduates with college, career, and innovation-ready skills. SOL tests are designed, however,  to measure attainment of certain discrete-point knowledge and can also serve as one measure of reading skills. Unfortunately, reports from across the U.S., indicate that the current over-reliance and narrow focus on achievement as measured by standardized testing has severely diminished the richness of the learning culture of our classrooms and hindered authentic, inquiry-based learning experiences  that used to produce the innovators and entrepreneurs that were the envy of the world. To not recognize this reality is naive.

Although the proposed provision to allow retakes in grades 3-8 may do little to broaden the conversation about multiple measures of achievement and may only lead to even more skewed emphasis on SOL tests and the pervasive culture of overtesting (testing, to prepare for the test, in order to prepare for the test, etc.) that exists, allowing retakes would at least acknowledge the inherent inequity and out-of-date pedagogy of one-shot testing.

Regarding the requirement that students failing an SOL test receive remediation, there is already sufficient language in the SOA indicating the responsibility of the school division to provide remediation. This new language seems redundant and unneeded.

Re: 8VAC20-131-110. Standard and verified units of credit

The proposal to replace the 140-clock hour requirement for a standard credit with demonstration of content mastery is a welcome change and recognizes the changing modes of delivering instruction to include online and blended models. The wisdom of this amendment also applies to the removal of clock hour requirements for summer school courses (8VAC20-131-120).

Re: 8VAC20-131-270. School and community communications

The requirement to give notice to parents about sensitive or or explicit materials is unnecessary, overly vague, and unenforceable. School boards are already required to establish procedures through which parents can challenge the use of supplemental materials. Given that it would be impossible to establish a common definition of "sensitive materials" in alignment with diverse community standards, teachers and schools would be left in the position of having to guess what might possibly be considered "sensitive" to any one parent. Given the vision of the Board of Education to "derive strength from diversity", the proposed requirement seems incongruous with that vision. 

Thank you for the opportunity to provide feedback.  I have a few notes included below to consider:

8VAC20-131, Student achievement expectations –
•  I agree that it is important for the Board of Education to permit students in grades
three through eight to have opportunities to take an expedited retake of a Standards of
Learning tests.  This should be a high budget priority as students should be afforded this opportunity.  This is a priority area that has been supported by VASS.

• I agree with the provision to require students who fail to achieve a passing score on all
relevant Standards of Learning tests in grades three through eight, and for students who fail
to achieve a passing score on an end-of-course Standards of Learning test required for
verified credit be required to participate in a remediation program or some other form of
remediation. However, I'm concerned about the lack of adequate funding for this provision.  School divisions across the state have received decreased funding for remediation programs over the last several years.  Will additional funding be provided for this provision? 

 •It is necessary for the Board of Education to work toward or research-based assessment program that accurately assesses content and college/career readiness skills.  This cannot be accomplished through multiple choice assessments alone.  School divisions are having to invest a great deal of time to develop these assessments and/or funding to purchase assessments to supplement the state testing program.  It will also be important to vertically align assessments (especially in English:Reading and Mathematics for grades 3-8) so that school divisions can accurately measure student growth over time.  Vertical alignment was being discussed several years ago in Virginia, but no longer seems to be a priority area for the VDOE.  VASS and school divisions across the state continue to advocate for a balanced assessment approach.    

8VAC20-131-50, Diploma requirements -
• While I feel that the requirement for students to be trained in emergency first aid, cardiopulmonary
resuscitation, and the use of automated external defibrillators to be awarded a Standard or an
Advanced Studies Diploma in 8VAC20-131-50 is a worthy cause, this requirement is going to present significant cost and logistical issues when implemented.  I would recommend that it be included in the curriculum for required Health/PE courses and not added as an additional requirement for graduation.

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

• I agree with the elimination 140 clock hour requirement for a standard credit and the proposed requirement that students demonstrate mastery of the course content. This would provide greater flexibility with both school-based and virtual courses.  It also focuses on student mastery of content rather than "seat time."  This adjustment is long overdue and will be a positive change for our schools.

8VAC 20-131-20 – School and community communications –
• I have a concern about requiring language that would be added to include a notice to parents about any sensitive or explicit materials that may be included in the course, the textbook, or any supplemental instructional materials. School divisions have concerns about this requirement due to the cost and logistical problems. For example, “what is the definition of sensitive or explicit?”  Most school divisions already address this concern with “opt-out” provisions for parents who object to certain materials and\or curriculum review committees that include parents.

8VAC20-131, Student Acheivement Expecations:  allowing students in grades 3 =-8 to take expedited retakes of an SOL test has been needed for some time. This change should be a high priority in the budget.

Requirements for remediation are sound however, the requirements necessitates funding.

8VAC20-131-50  Diploma Requirements:  Requirements for training in emergency first aid, CPR and AEDs should be incoroporated in courses that are already rquired for graduation as opposed to being tacked on as a graduation requirement.  Also, training in these areas requires funding to support the requirement.

8VAC20-131-80; 8VAC20-131-90; 8VAC 20-131-100, Instructional programs in elementary, middle and secondary schools:  As previously expressed rememdiation makes sense but will funding be available.  Budget cuts over the last 5 years have already decimated summer programs. 

8VAC 20-131-100 Standard and Verified Units of Credit:  Elimination of the 140 clock hour requirement is supported.  it provides greater flexibility in the use of both school-based and virtual courses.     Seat time required for mastery is antiquated and this revision is greatly needed.

8VAC20-131-20 School and community Communications:  Additional communication regarding sensitive or explicit materials is redundant.  Current local policy and practice already provide methods for people to address concerns about materials used in schools and classrooms. 

The Virginia Foreign Language Supervisors Association supports a Biliteracy seal to recognize the proficiency of high school graduates in two or more world languages (one being English.) Currently, only New York and California offer a Biliteracy Seal; by choosing to add this seal to the diplomas of high school graduates within the Commonwealth of Virginia, we would cast ourselves as a leader in second language acquisition.

A Biliteracy Seal would benefit foreign language learners, communicating to colleges that they are prepared for upper level study as they have mastered the academic language needed for higher level discourse in two or more languages. Hopefully, this would lead to an increase in the numbers of students majoring in a foreign language, and consequently the quantity and quality of K-12 foreign language teachers, often in short supply. Further, the seal would signal to prospective employers that these students possess the skills to be successful in the global marketplace. In addition, a Biliteracy Seal would serve to acknowledge the literacy skills of English Language Learners in English as well as their heritage language.

I fully support the Seal of Biliteracy.  This is not a "nice addition" - this is a necessary part of a diploma that will immediately communicate essential information to universities as well as recognize important student achievements in a global world.

Acquiring world languages is a critical 21st Century skill in preparing our youth to meet the economic and labor demands of an increasing culturally diverse society. Fluency in other languages, including American Sign Language and Braille, in addition to English will enable Virginia’s next generation of business leaders and workers to continue to grow the Commonwealth’s economic capacity. Additionally, research reveals that acquiring a second language is linked with enhanced cognitive development, higher-order thinking, and creativity.

Students who are fluent and literate in more than one language have a competitive edge in today’s job market. The seal would:

1. Certify that an individual is fluent and literate in English and a second language other than English.    
2. Help employers, colleges, and universities clearly distinguish talented applicants with valuable skills. 
3. Celebrate the diversity of our students and their academic achievements.

Since California and New York are the only two states that have established programs, this would place Virginia as a leader regarding biliteracy by formally recognizing, through the establishment of the State Seal of Biliteracy, the linguistic and cultural strengths of Virginia’s students. It builds upon their diverse assets enabling them to become highly literate in more than one language in addition to English and prepared to deal with a linguistically diverse region and a national and global economy.

Lastly, the Seal provides an opportunity for schools to establish a program that is positive, builds upon the strengths of all students who wish to participate and creates positive relationships with parents and the community at-large. Again, this is a “win-win” situation for all.

On behalf of the entire membership of the Virginia Foreign Supervisors Association and World Language teachers throughout Virginia thank you for your leadership on this important issue. We look forward to working with you to recognize the importance of biliteracy in today’s diverse society. 

I support the Seal of Biliteracy. It is an important endorsement for our students.It would benefit our students who demonstrate a mastery of academic language study as well as our heritage language students.

Proficiency in foreign languages is a critical need to ensure that Virginians maintain a competitive edge throughout the rest of the world. The Seal of Biliteracy on high school diplomas will motivate student achievement and bolster the value of language learning among our high school population. This in turn will strengthen the quality of our programs and make them even more effective preparing the next generation of Virginians to be successful on a global scale. I am in full support of adding this endorsement to our high school diplomas.