As an art educator, I am passionate about the profound impact that arts education has on students' lives. Introducing a Fine Arts diploma seal to Virginia's accreditation standards would provide a powerful recognition of the dedication and exceptional work of advanced Fine Arts students. This seal would not only honor their achievements but also inspire them to engage more deeply with the arts, fostering creativity, critical thinking, and emotional expression.

By pursuing higher-level Fine Arts courses, students develop skills that are invaluable in both their personal and professional lives. The Fine Arts diploma seal would serve as a tangible testament to their hard work and talent, offering a distinct advantage as they apply to colleges and seek employment. It would communicate to post-secondary institutions and employers that these students possess the discipline, creativity, and innovative thinking essential for success in any field.

Moreover, this initiative would elevate the status of Fine Arts education, highlighting its essential role in a well-rounded curriculum. Recognizing and rewarding students' accomplishments in the arts not only validates their efforts but also underscores the importance of fostering a vibrant and dynamic educational environment.

Thank you for considering and supporting this vital request, which champions the growth and recognition of Fine Arts education and its significant benefits to our students' futures.

Why are you trying to add more state testing? I don't think you all understand the INSANE amount of pressure our kids are put under with the SOL testings alone!

Why not start with a test for the students asking different questions on how they feel about the SOL'S? Asking how they are/have been feeling or effected, mentally/emotionally, from the school, the teachers, ect. 

Pick one or the other. There's no reason to stress these kids out more than they already are.

Maybe focus on things that should actually be taught in schools, like ACTUAL things needed in adulthood, and mental health, and stop pushing the fact that college is the best/only way to succeed in their future. 

Do better for the kids!

Please DO NOT approve proposed testing for 5th and 8th grade students. Besides the questionable nature of these particular standardized tests, a standardized test really only assesses a person’s executive functioning skills for taking a test. They are not proven to accurate represent a person’s knowledge. Students need LESS TESTING and MORE LEARNING during school time. Please do not take away more of that limited time for more testing. Thank you!

Kristi Chamberlain M.A. CCC-SLP

Speech Language Pathologist

Please vote NO on the proposed “Performance Task” testing of Virginia 5th and 8th grade students. Standardized testing has not been proven to be an effective method to assess learning, and Virginia students already sacrifice too much valuable educational time on these tests. The last thing our students need is more time taken away from learning opportunities. Please focus on growth assessment and chronic absenteeism. Thank you!

To VBOE,

Instead of more testing, just equally weight Mastery (SOL scores) and Growth (improvement from Spring to Spring), and set chronic absenteeism at the lowest allowable federal minimum. I do not approve of the addition of a new 5th grade and 8th grade performance task test.

Please consider the amount of time, resources and money this will take. There is no need for more tests, if the SOLs don't already meet your need then there is a need to re-think the test we already have to improve that.

This proposed system is too complicated and difficult to understand. There is no need for new labels, beyond what the federal government requires. All of the percentages and calculations make it difficult for parents and families to understand. Just present the information simply without manipulating it. Weighting attendance more than federally required punishes schools for something that they can’t control. Adding additional tasks or assessments takes away from instructional time in the classroom and adds extra burdens to our overworked teachers. Instead of spending all your time on this, why don’t you focus on how to improve instruction and retain teachers 

Please reconsider changing the SOA amendments. The proposed plan is not more transparent at all. 

It is better to have two accountability systems than to switch to the proposed system. 

Reading the information on adding testing for 5th and 8th grade to determine if they are ‘ready’ to move on , not based on any standard of learning or curriculum seems out of date and more harmful to our students than helpful.   Already we have iready which kids speed through, as well as the fact that implementing it for this academic year is irresponsible considering parents have no real information on something that could severely impact our students and schools.   While my preference would be to not implement this at all, there at least needs to be a longer time for parents to ask questions and understand more about it.  

Respectfully,

Lauren Thorne 

Public schools need more instructional hours. Also, the classrooms are also too large for one teacher to get through the materials adequately AND assist students who need additional help. More instructional hours will help with the learning loss and the fact that private schools are academically ahead of public schools. 

The standard school year of 990 instructional hours sells our students short, especially in this post-Covid environment where we are still addressing learning loss. We must raise that number to at least 1,080 hours and require that school divisions meet both the 180 day and 1,080 instructional hour standards to be accredited.

The 990 hour standard places Virginia in the bottom 10 states in the nation for instructional time. School divisions in northern Virginia have been using the tiny 990 hour requirement to short-change our kids, creating calendars that are less than 180 days and creating shortened school days for elementary students rather than paying teachers for the additional hours they need to plan. The state government needs to step in and make sure our kids get the time in school that they deserve.

The standard school year of 990 instructional hours sells our students short. We must raise that number to at least 1,080 hours and require that school divisions meet both the 180 day and 1,080 instructional hour standards to be accredited.

The 990 hour standard places Virginia in the bottom 10 states in the nation for instructional time. School divisions in northern Virginia have been using the tiny 990 hour requirement to short-change our kids, creating calendars that are less than 180 days and creating shortened school days for elementary students rather than paying teachers for the additional hours they need to plan. The state government needs to step in and make sure our kids get the time in school that they deserve.

My 5th grade son can barely write while his friend who moved to Catholic school last year is able to write right on grade level.  The difference in the standards, and the results, of FCPS vs private schools is staggering.

The standard school year of 990 instructional hours sells our students short. We must raise that number to at least 1,080 hours and require that school divisions meet both the 180 day and 1,080 instructional hour standards to be accredited.

The 990 hour standard places Virginia in the bottom 10 states in the nation for instructional time. School divisions in northern Virginia have been using the tiny 990 hour requirement to short-change our kids, creating calendars that are less than 180 days and creating shortened school days for elementary students rather than paying teachers for the additional hours they need to plan. The state government needs to step in and make sure our kids get the time in school that they deserve.

The state needs to take a look at raising the number of actual instructional hours. Many states have more instructional hours than Virginia. Also private schools have more instructional hours than public schools. If public schools want to stay relevant the VDOE needs to increase actual instructional

hours. 

Public students are getting much less instructional time than private school students in the state of VA and it is unacceptable! As an hard-working tax payer I expect the Governor to enforce the accreditation standards for all public schools.

The current standard school year of 990 instructional hours sells our students short. We must raise that number to at least 1,080 hours and require that school divisions meet both the 180 day and 1,080 instructional hour standards to be accredited.

The 990 hour standard places Virginia in the bottom 10 states in the nation for instructional time. School divisions in northern Virginia have been using the tiny 990 hour requirement to short-change our kids, creating calendars that are less than 180 days and creating shortened school days for elementary students rather than paying teachers for the additional hours they need to plan. The state government needs to step in and make sure our kids get the time in school that they deserve.  I sick of the state grabbing my tax dollars and not delivering value for all that money.  Do your job VA!

https://townhall.virginia.gov/l/comments.cfm?stageid=10286

The proposal as presented at the June board meeting focuses on 'advanced coursework' for middle school.  It confuses 'advanced' for acceleration.  Taking high school credit courses in middle school is not an indicator of high school readiness--it IS high school.

It repeatedly references 'eligible' students several times without defining the term.  And it provides no formula for how this would be calculated.

For an A student who is taking grade-level courses that are focused on content and student skills, and is fully prepared for HS as a 9th grader, will schools be penalized for this?  Is it preferable for a student to be enrolled in HS-credit courses before they are ready?  This risks lowering expectations in these courses--the opposite of 'advanced' or creating students who are ready for HS.

It is wholly unclear how schools would staff these courses.  There is already a teacher shortage.

Additionally, if this is to take effect in the 24-25 school year, schedules are already set.  This would be changing the game after the players take the field.

Far too much of the proposal is vague.  Many more details are needed in order for the proposal to be understood.  The details matter.

Please provide more details as to how this portion of the proposal will be measured.

To define a middle school student as ready for high school only if they have successfully completed a high school course does not make sense to me. Additionally, creating a situation where middle schools need to hire teachers licensed to teach high school across three content areas creates inequities in a school's ability to meet this standard. Please reconsider how you are defining the middle school readiness indicator.

I do no agree with adding an additional test (citizenship) for high school when we already have numerous tests in history and social sciences which are not included anywhere in the accountability framework. Additionally, awarding bonus points for the citizenship test has the potential of masking the results of the other contributors to this indicator. 

I am somewhat confused by/ concerned with the mastery index calculation. I am not understanding how giving credit for failing a test (up to .75) or extra credit for passing with an advanced score creates a more transparent system. Isn't the most transparent system a true pass rate? I don't see where just an overall pass rate will be available to the public. It seems like rather than making it transparent, it is just made less clear in a different manner than the current system (with growth included).

To Whom It May Concern:

On behalf of the Virginia Manufacturers Association, please accept the following comments on School Performance and Support Framework.

Bridging the gap between Virginia’s K-12 educational system and workforce development is critical to manufacturing competitiveness. Virginia manufacturers need a reliable and predictable talent pipeline to continue making world-class products. Increasing and expanding access to work-ready and industry-recognized credentials in Virginia’s educational system will strengthen our emerging workforce and pave the way for Virginians to get hired in well-paying jobs in high-demand fields.

Schools and superintendents should be measured on the number of industry-recognized credentials their students earn.?Creating performance standards for credentialing would create greater accountability on work-readiness and incentivize career pathways. To support this new accountability framework, Virginia must create greater transparency around career pathways, credentialling, and the costs and benefits of different educational choices.

Regardless of their immediate career pathway – college or work – every student needs access to training and tools to better align their coursework with their career goals. Beginning in 7th grade, every student should have an Academic and Career Plan – a cloud-based education tool or “e-passport” – that allows students and families to better plan and track their educational progression and make smarter decisions, including which courses to take and when to take them.

A traditional college education should not be the only pathway available to Virginia’s students, but it is certainly the one most heavily promoted to them. It is essential that we better inform students about the opportunities available to them and provide adequate information and tools to help them make informed decisions. By investing in a comprehensive consumer facing data dashboard and career exploration tool, Virginia can increase public transparency on educational pathways, educational costs and affordability, career opportunities, and educational and workforce outcomes to better inform students and families on the benefits of pursuing various industry credentials or licenses.

The success of both Virginia industry and that of our students hinges on the ability of our K-12 schools to prepare them for the workforce – whether they enter it immediately after high school or after additional postsecondary school or training. We must raise Virginia’s expectations for credentialling in our K-12 schools by setting performance standards that incentivize positive outcomes.

Creating a world-class talent pipeline that fuels manufacturing competitiveness starts in K-12. The VMA supports institutional performance measurements that ensure the alignment of K-12 policies, programs, and initiatives with industry credential demands.

Sincerely,

Stacie Gordon, Government Affairs Manager

Virginia Manufacturers Association

I write in support of the revisions to the Standards of Accreditation regulations for the proposed School Performance and Support Framework.

The current system of accreditation is not working.  While there was a plunge in student achievement scores after-COVID, the overwhelming majority of Virginia’s schools are nonetheless deemed to be performing at the highest level. The system needs to reflect changes in achievement.   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, students need to achieve proficiency, not just journey toward it.   VDOE has worked hard to pull together well-thought out and vetted standards of learning.  We should be requiring schools and students to pass the lower end of those standards.  

I 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 strongly support the inclusion of middle school advanced coursework in the performance measure, particularly for math. We want to incentivize schools to meet the needs of all of their students, including the advanced students.   The goal should be to challenge students to their fullest potential.

Lastly, we need to find ways to increase schools’ accountability 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 and for the excellent work that has been done with the School Performance and Support Framework.

I am writing in support of the revisions to the Standards of Accreditation regulations for the proposed School Performance and Support Framework. The current accreditation system is not transparently nor accurately tracking school performance. Despite the learning loss in student achievement scores during and 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, we need students to actually achieve proficiency, not just journey toward it. I also support giving chronic absenteeism a meaningful weight in the performance measure. In-school time is one of the largest impacts on student achievement. 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, we need to find ways to increase schools’ accountability for newly arrived English Learners to ensure that they are being well served and are building content knowledge as well as English proficiency. Thank you for the opportunity to provide comments and for the excellent work that has been done with the School Performance and Support Framework

As the nation's best aviation education program for the past two years, we know just how important it is for students to master their coursework in math, science, technology, engineering, reading and the English language.  Offering more, better and earlier options for students to study these critical subjects will enable them to be prepared to fill one of the 435,000 pilot, aircraft mechanic and air traffic controller jobs that the Boeing Company predicts will go unfilled in North American over the next 20 years!  This will counteract the drop in NAEP scores for 4th graders -- a drop of two times the national average in math and three times in reading.  The focus must be on mastery of the subject matter as student performance across the Commonwealth comes with high expectations to ensure students reach their full potential.  It's also important that we effectively combat chronic absenteeism, because if the students aren't in the classroom they cannot learn all of the material or master the subject matter.  Lastly, the ability to effectively read, write and speak the English language is crucial to one's success in the aviation industry as English is the international standard for pilots worldwide.  Thank you for your time and attention in this regard.

I am writing on behalf of the excessive absenteeism in the public schools. As we all know, an uneducated child can end up being a dangerous child. I have been advocating for years concerning this subject, being a mother and grandmother, whose children attended public schools. I truly believe that accountability needs to be implemented concerning the parents’ responsibility in making sure children are in attendance during school hours. I suggest that a system is implemented in reference to those families that receive any type of TANF, or SNAP services. My suggestion is that if a child has missed 2 days out of each month, benefits should be sanctioned. If we begin to place a system in place I guarantee we will have more parental participation and a decrease in absenteeism.

The current school year of 990 instructional hours is too low, both for normal times and for recovering from learning loss.   We need to do better for our students.  At the very least, VA should raise that number to at least 1,080 hours and require that school divisions meet both the 180 day and 1,080 instructional hour standards to be accredited.

The 990 hour standard places Virginia in the bottom 10 of states.    The bottom 10.  The core part of learning is teachers teaching students.   Both teachers and students need to be in the classroom for this to happen.   School districts have an incentive to do the very minimum.  The state government needs to step in and make sure our kids get the time in school that they deserve.

Thank you for the opportunity to submit public comments through this Virginia Regulatory Town Hall forum. In finalizing revisions to the Regulations Establishing Standards for Accrediting Public Schools in Virginia, Fairfax County Public Schools (FCPS) urges the Virginia Board of Education to be mindful of how outcomes will be measured for students with disabilities, including those taught using the Virginia Essentialized Standards of Learning (VESOL), and for multilingual/English learners, particularly Students with Limited or Interrupted Formal Education (SLIFE). 

Given the options presented to the Board, FCPS suggests adopting the equal Mastery index weighting system, providing even steps between points for each performance level. We highlight the need to ensure that expected Growth targets for students with disabilities and multilingual/English learners within Virginia’s Visualization and Analytics Solution (VVAAS) are appropriately normed to these unique student populations. FCPS supports the inclusion of Virginia Alternate Assessment Program (VAAP) performance within both Mastery and Growth calculations to ensure inclusion for students with significant cognitive disabilities and we recommend that, when reporting scores to the public, results for Standards of Learning (SOL) and VAAP be separated for transparency. Similarly, with the proposed system’s heavy reliance on standardized assessments, we advocate for the adoption of valid and reliable native language assessments--as encouraged within the Every Student Succeeds Act (ESSA) Consolidated State Plan template--to serve as testing accommodations to accurately measure multilingual/English learners' content knowledge and skills. FCPS supports greater implementation of universal design principles, such as "plain language" assessments and continued inclusion of Board-approved substitute exams (e.g., ACT WorkKeys, Advanced Placement) at the high school level, as these tests may offer a more relevant and authentic assessment experience to better reflect content knowledge and skills, including for twice exceptional students. 

Specifically with regard to multilingual/English learners, FCPS advocates for maximizing the percentage assigned to WIDA-based English Learner (EL) Progress within the Mastery indicator calculations (such as 15% rather than 5%). A focus on EL Progress recognizes the critical importance of timely language acquisition in preventing students from becoming Long-Term ELs, who have not reached proficiency after five consecutive years of English language supports. Further, FCPS advocates for maintaining the current research-based allowance of 11 semesters (5.5 years) for language acquisition before students are accountable to reach the proficient level on content standards assessments. If the Board determines it is necessary to reduce the multilingual/English learner adjustment, FCPS strongly encourages using only EL Progress outcomes within Mastery calculations and/or using only Growth calculations for the intervening years. FCPS also supports consistently including Formerly English Learners during their four years of monitoring within both Mastery and Growth calculations.

When making decisions about Readiness indicators in middle and high schools, FCPS urges the Board to consider how to appropriately accommodate students with disabilities and SLIFE students for whom traditional advanced courses may not be appropriate or may be accessed on an adjusted timeline. These Readiness measures should allow adjustments or alternatives for students assigned VAAP for their state assessments. FCPS asks the Board to consider how to adjust or accommodate alternative Readiness options for certain students with disabilities and SLIFE students for whom currently outlined pathways may not be appropriate. One such alternative would be continued acceptance of a student’s documented completion of a high-quality work-based learning or service learning experience within the proposed Ready for Life measure. FCPS likewise urges that the Board continue to recognize employment credentials that promote access for multilingual/English learners and students with disabilities, such as the National Career Readiness Certificate (NCRC), which is earned through qualifying results on multiple subtests in applied skills. Furthermore, we feel it is important to include the current Graduation and Completion Index (GCI) within the Readiness indicator as a way to reflect a full range of diploma and completer outcomes for students with disabilities and multilingual/English learners (e.g., Applied Studies Diploma, High School Equivalency, Certificate of Completion) while also providing students whose individualized education program (IEP) teams or EL committees have determined additional time is needed in high school to prepare for postsecondary success. 

Finally, recognizing the importance of parent/guardian involvement and decision-making regarding their students’ education--particularly for students with disabilities and multilingual/English learners--FCPS urges the Board to maintain current calculation adjustments in cases where a parent/guardian makes the choice to refuse participation for their student in SOL or VAAP assessments. FCPS supports the current accountability approach, in which a parent/guardian refusal counts to fulfill federal participation requirements but is removed from pass rate calculations, since the outcome does not reflect actual student performance. 

Thank you again for this opportunity to provide input in the process and we appreciate your consideration.

Fairfax County Public Schools, Office of Government Relations

For VA to be a leader in academic achievement for all students the policies need to be consistent with that goal.  As such, VA should be a leader in the number of schools days and minimum hours of instruction required.   VA should weight the accreditation system towards mastery to ensure that all students are hitting the minimum targets.  VA should reward schools that provide advanced coursework as that meets the need of the more advanced students.  VA should have an easy to understand, transparent and honest measure for each school so that parents and community members are informed and can help improve the schools.  

I strongly support of 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^thgrade; 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. (In fact, there’s a comment on the Regulatory Townhall opposing the new Middle School Advanced Coursework from one of the architects of VMPI where he does not want districts to be penalized for decelerating 8^th graders who are ready for Algebra 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.

For excellent public school Algebra readiness efforts, we can already look within Virginia to Fairfax County Public Schools (FCPS). One of FCPS’ strategic plan’s goals is to have as many kids as possible successfully take Algebra in 8^th grade. FCPS Superintendent Michelle Reid has spoken about how their Algebra readiness efforts start in early elementary. She was recently favorably featured in the Wall Street Journal for such efforts.

I’m for spending of taxpayers money properly. On the other hand, please stop burning out our don’t teachers and administrators with endless professional development.
Why do we hear enough about requiring parental responsibility and involvement? Why are there low standards and expectations in some schools and not others?  This is unacceptable. Everyone is able to be educated and be successful if given the proper environment and resources. Teachers must be are supported by the administrators and parents. The school district handbook must be followed consistently as well and get rid of the cell phones. 

I am writing in support of the proposed Standards of Accreditation regulations, which will put in place a new school performance and support framework. One of the primary purposes of the new school performance and support framework will be to ensure schools and students receive the needed supports to improve student outcomes. Virginia’s current accreditation system excludes English learners for 11 semesters – effectively 5.5 years. As mentioned at the June Board meeting, this rule excluded an estimated 35,000 students, meaning the performance of 35,000 English learners was not included in the system and those students were not provided targeted support.??

Under the new system, which will braid state and federal requirements together, English learners will be included in the framework after 3 semesters – effectively 1.5 years. This federal requirement was put in place to ensure that schools are provided support quickly since research has shown if schools wait until the 5.5 years after the English learner enters the school to receive support, the window for a student to successfully become proficient in English closes. We must provide targeted support to English learners and schools serving English learners as soon as possible.??

I appreciate the opportunity to comment on these regulations and support the Board’s effort to ensure we are including as many students as possible in the new school support and performance framework.??

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

I strongly support the School Performance and Support Framework.

A revised Framework is needed given the failure of the current accreditation and accountability systems to provide a transparent accounting of school performance. During the post-COVID period, the current system signaled that schools were doing well even as student achievement plunged. The new Framework corrects the prior shortcomings. It assigns a higher weighting to mastery than growth which will incentivize schools to recoup learnings losses.

Virginia is not alone in emphasizing achievement over growth. Massachusetts, which is often cited for its exemplary education policies, uses a 60% weighting for achievement and 20% for growth for elementary and middle schools and explicitly targets a 3:1 ratio of achievement to growth.

For the high school mastery index, Virginia should ensure that the SOL exam results used are not concentrated solely in 9^th grade, so that schools are incentivized to promote academic growth throughout high school. While that can be done readily for reading and science, most high school math SOL exams are currently taken in 9^th grade. To correct this temporal skewing, Virginia should require that all students taking a math course with an end-of-course SOL take the associated SOL exam; this would increase the number of older students taking math SOL exams.

The Framework also excels in giving meaningful weight to chronic absenteeism. Since 2018-19, the share of Virginia students who are chronically absent has roughly doubled. This is troubling as chronic absenteeism correlates with poor academic performance for the student and disrupts overall classroom functioning as well. If we want to boost student performance, we must ensure that students are in the classroom.

Lastly, the Framework addresses the need for greater school accountability for recently arrived English Learners. At present, an elementary school may never be held accountable for the math performance of a recently arrived student who enrolls in 1^st grade. That should not be the case. It is important to bring these students into school performance measures with accommodations as needed, so that they can receive targeted support in a timely manner.

Thank you for the significant progress made with the new Framework; all of Virginia’s students will be the beneficiaries.

Arlington Public Schools thanks the Board of Education for this opportunity to provide feedback on the proposed standards. While there are aspects of this proposal that we disagree with, we support the idea of separating accountability from accreditation. Measuring legal compliance is different from measuring the quality of a school’s teaching, and it will be helpful going forward to have those separate measures in place.

However, we have serious concerns about some of the changes to the standards of accountability. The heavy weighting of mastery over growth is far out of line with most other states, and threatens to classify schools based on the students they admit rather than the skills they teach. Additionally, reducing the number of semesters before English Learners (EL) are counted from eleven semesters to three semesters is inconsistent with best practices. While it has been noted that using three semesters is the federal standard and is the one used by many other states, it is important to also note that the federal standard allows for students in their second and third years to be measured based on their growth rather than their mastery. Since most other states do weight growth much more heavily than is done in this proposal, Virginia’s practice of judging fourth semester English Learners based mostly on their performance on exams in a language they are still attempting to learn would differ greatly from other states’ approaches.

We appreciate the desire to ensure that English Learners master the English language as soon as possible and we share in that commitment. But expecting students in their second year of learning English to perform at a level consistent with their native English-speaking peers is unrealistic. We believe that growth should be weighted as much as mastery, and we believe that English Learners should be given eleven semesters before their scores count alongside other students. But if the Board is committed to the proposed approach, then it should at least allow for students in their early years of learning English to be counted based on their growth, which would properly consider the fact that they are still learning the language. This could be done by weighting WIDA scores more heavily and by giving more weight to growth measures relative to mastery measures for EL students.

We agree with the Board’s goal of getting English Learners up to fluency in English as soon as can be done. However, the proposal set forward would unfairly categorize schools with large numbers of EL students as struggling based largely on the students they serve rather than the education they provide. We urge you to reconsider and to find a better way to achieve our shared objectives. Thank you again for your consideration of our feedback.

Virginia PTA supports the transition to an accountability system that is directly aligned with the federal accountability system and which provides transparent information for parents and students to use in evaluating the effectiveness of a school’s academic program.

Summative Rating: This proposed regulation does not transparently define the new 4-level summative accountability categories or labels. We oppose a summative ranking system based on letters, stars, cardinals, or other like symbols. To provide transparency and promote parent engagement, we support a placement presentation of academic performance showing growth and mastery. If a summative state performance category is used, it should clearly describe the type of state funding and instructional support each school will receive.

Performance Tests & Readiness Category: Virginia PTA supports a robust and transparent assessment (testing) system, however, we do not support high-stakes testing that over-emphasizes a single end-of-year test. Virginia PTA opposes the introduction of new 5th grade and 8th grade Performance Task Tests.  These proposed readiness tests are not tied to SOL curriculum, are not designed to identify achievement gaps or guide new instruction, and have not been developed or piloted.  Additionally, blending tests results with chronic absenteeism in a readiness indicator blurs test result transparency, and reduces the ability to use the assessment results to develop a community action plan for school improvement.  There is opportunity to include new innovative question types demonstrating the 5’C’s within the existing curriculum driven SOL assessments to positively benefit all grade levels rather than adding more 5^th & 8^th grade testing. We urge the Board of Education use current SOL tests to evaluate mastery and growth; and use chronic absenteeism at its lowest federally allowable minimum as the readiness indicator.

Opt-Outs: Parents have a right to make decisions on behalf of their children, and that includes opting them out of state assessments. We oppose counting an opt-out as a zero in the performance mastery index. The consequences of nonparticipation in state assessments should not result in the loss of funding, diminished resources, or meaningful interventions for student subgroups. Student participation should remain the guiding measure for evaluating mastery.