Virginia Regulatory Town Hall View Comments

Department of Education

State Board of Education

Virginia Standards of Accreditation [8 VAC 20 ‑ 132]

Action	Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia
Stage	Final
Comment Period	Ended on 9/25/2024

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9/12/24 8:48 am

Commenter: Jeremy Aldrich

Setting schools up to fail

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:

- Will Pass Advanced be factored into the Mastery calculation (elementary, middle, and high school)? This is not specified in the recent board presentation or supporting documents.

- What IS the mastery calculation for a specific test, such as reading?

- Will subgroup performance be part of any of these calculations (Mastery, Growth, or Readiness)?

- For the Growth calculation, will all students have an expected growth score or only those who had previously failed? How will expected growth be calculated for students achieving at high levels?

- What courses will count as advanced Math, Science, and Social Studies courses for the middle school Readiness calculation? Only EOC (high school credit) bearing courses?

- Questions about the 3E framework for high school (see appendix of the Board of Ed presentation) which is 25% of the high school calculation.

- Does this replace College, Community, and Civic Readiness Index (CCCRI) or live in addition to it?

- Does work-based learning factor into anything for the 3E framework? This has been a major DOE push for several years.

- For 3E enrollment it awards points for 3 AP courses with 3+ scores, OR 3 DE courses...what if a student has some DE and some AP courses totaling 3 or 4?

- For 3E employment it distinguishes between industry credentials for high demand and high wage/high demand careers...but VOEE doesn't have a list of qualifying careers (it only lists high demand, not high wage/high demand) and the VDOE board-approved credential list does not link credentials to specific careers. Since the 3E framework goes into effect this school year how could we possibly guide students to courses/credentials this year to earn a full point on this metric?

- For 3E enlistment it differentiates points by ASVAB scores. How were these score bands determined since a student could literally be ready for enlistment after high school in any branch of the military with a score of 31, which only awards .5 points on this framework?

- How will the Virginia graduation requirements be aligned to match with the 3E framework so that there is a student-level incentive to maximize their points on this calculation, since we don't currently require students to do any combination of things that add up to one point or greater?

CommentID: 227790