Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Virginia Standards of Accreditation [8 VAC 20 ‑ 132]
Action Revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia
Stage Proposed
Comment Period Ended on 7/5/2024
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7/5/24  9:59 am
Commenter: Nicholas Munyan-Penney, EdTrust

Defending Changes for More Inclusion of English Learners
 

Dear Virginia State Board of Education,

The undersigned organizations are writing to express our support for the Virginia Department of Education’s (VDOE) proposed changes to its state accountability system to move from excluding English Learner (EL) academic outcomes from school rating for 11 semesters to 3 semesters, in alignment with federal requirements.

State accountability systems are designed to improve student outcomes by 1) allowing state officials and policymakers to prioritize resources and build the capacity of the schools and districts with the most need, 2) providing schools and districts with clear goals for improving student outcomes through additional supports and resources for the lowest-performing schools, and 3) empowering families and communities with data to demand action when schools and districts are not serving the needs of their students.

Accountability systems can do this, in part, by identifying schools producing the lowest outcomes for students, including schools that are not serving students from groups historically underserved by the school system such as students of color, students from low-income families, ELs, and students with disabilities. This is imperative for driving towards a more equitable education system that meets the needs of all students. However, in order for accountability systems to work as intended, students’ performance and growth need to be “seen” by the accountability system, meaning that the ratings schools receive are a signal of how well they are actually serving all students.

One of the provisions in the Every Student Succeeds Act (ESSA) designed to ensure all students’ performance is seen by accountability systems is a limit on the amount of time since enrolling in a US school ELs’ academic outcomes are allowed to be excluded from a school’s rating. ESSA sets this time frame at 3 semesters, or 1.5 school years. This time frame is designed to balance fairness to schools—giving them time to identify and provide the types of language supports students need before holding them accountable for results—with ensuring that the system is able to identify when schools may not be adequately supporting ELs so they can meet grade level academic standards in English language arts and math.

Currently, Virginia effectively has two parallel accountability systems: one formal system approved by the US Department of Education and a separate state system of accountability that, while not aligned with all federal requirements, largely drives district and school level decision making. While the federally approved system follows ESSA requirements on the limits of excluding EL academic outcomes, the separate state system allows the performance of newly arrived ELs to be excluded for up to 11 semesters—more than five school years.  

As Virginia works to unify their bifurcated state accountability systems into a single system aligned with federal requirements under ESSA, the state has wisely proposed that the single system will follow the 3 semester exclusion requirements—a move that we strongly endorse. By the state’s own estimation, this change will allow for the performance of an additional 35,000 students to be included in school academic ratings statewide. While school and district leaders may be concerned that these changes could dramatically change how they are rated, this increase in the number of ELs whose performance is “seen” by Virginia’s accountability system prevents schools from masking the underperformance of ELs and will ultimately enable the VDOE to better support ELs. By more accurately identifying schools that need additional resources and support to address the needs of ELs, state, district and school leaders can more effectively support the unique needs of ELs. Given this, we believe it is imperative that the Virginia State Board of Education approve this change proposed by VDOE.

Sincerely, 

EdTrust

Migration Policy Institute National Center on Immigrant Integration Policy

UnidosUS

CommentID: 226985