April 28, 2010
The Honorable George Miller
Chairman
Committee on Education and Labor
U.S. House of Representatives
Washington, DC 20515
Dear Chairman Miller:
I am writing to express my recommendations and priorities for the revision of the Elementary and Secondary Education Act (ESEA). I thank you for your leadership as you work to reauthorize the law in the 111th Congress, and make essential improvements to this law, last reauthorized as the No Child Left Behind Act in 2002. I know you ardently agree that access to a good education should be a fundamental civil and human right for all children. We now have an historic opportunity to shape the law and significantly expand opportunities for all American children, including those children in greatest need.
To summarize the recommendations I will outline more fully below: overall, it is my belief that it is imperative to make extensive changes to ESEA. However, I firmly believe that these changes must be based on sound research, and models that have been proven to work. I strongly support moving away from some of the education reform policies that have become popular in recent years, several of which were employed in No Child Left Behind, many of which continue to be recommended by policymakers across the political spectrum, in spite of the lack of evidence regarding their effectiveness. My recommendation is to move away from models that would emphasize high-stakes testing using narrow assessments, punitive measures for low-performing schools that include harsh and prescriptive interventions, and any increase in competition for funding among states and districts that would not involve a fair process where all have an equal opportunity. I urge you to move towards emphasizing and providing funding for reforms that have the highest impact for the neediest children. These reforms include providing adequate support and funding targeted at high-need children and their schools, ensuring reliable testing, fostering a strong and diverse curriculum, providing support for students beyond the classroom, and involving parents and communities in the educational system.
Recommendation: Provide Support for Struggling Schools, Not Punitive Interventions
There is no denying the reality that there are far too many schools across this country that are currently performing poorly, and chronically struggling to improve student achievement. There is also no denying that many of these schools will require a significant intervention to help them address the many issues they are facing and improve their ability to meet students’ needs. However, under current ESEA structure, it has become an unfortunate and all-too-common trend to label schools inaccurately or unfairly as failing—including schools that continue to make progress year after year but do not meet achievement targets, or schools that serve disproportionately large numbers of students that are low-performing for a variety of reasons that are out of the school’s control. Even more regrettable, these labels trigger a series of sanctions and intensive reforms, which may or may not be effective or proven, and have not been paired with a supply of adequate funding.
Although many education experts in communities around the nation have acknowledged that these punitive sanctions have not been proven to work, and in many cases have been ineffective or even harmful, there are still others who continue to recommend severe interventions for low-performing schools. I was relieved to see that the President’s Blueprint expresses an effort to move in the direction of recognizing progress and rewarding success in determining whether schools are in need of interventions. We absolutely must overhaul our system for identifying low-performing schools, for the sake of being accurate, as well as for the sake of restoring faith in our government’s ability to fairly make these identifications. But I was disappointed that the President’s “Blueprint for Reform” expresses the Administration’s continued reliance on these intensive interventions, and I have many concerns about the School Improvement Grant Program. The interventions identified as solutions through this program, which involve highly-prescriptive recommendations that include firing specific proportions of staff, converting a school to a charter, and closing schools altogether, are dramatic interventions that should not be taken lightly. Even more worrisome, many scholars and advocates have sounded an alarm because these interventions are not convincingly supported by scientific evidence.
While the large amount of funding that will be made available for these School Improvement Grants is enticing, I am worried about how the process of implementing the program will play out if and when Wisconsin receives this funding. I am concerned that there will be inadequate community, educator, and parental involvement in the decision-making process. I also anticipate that applying these models will have a tremendous disruptive impact on the surrounding communities, and cause a strong emotional reaction in my community, especially if the process is not undertaken carefully and deliberately. I realize that it is the Department of Education that will implement this process, but I strongly recommend that the Committee address the implementation process for these grants in the draft legislation, if the grants are included in the bill as anticipated.
I am very aware that several of Milwaukee’s schools have been identified on the State of Wisconsin’s list of “lowest-performing” schools; in fact, the list is almost entirely made up of Milwaukee schools. My recommendation is that the methods for addressing the problems of struggling schools outlined in ESEA reauthorization should emphasize assistance and support for these schools first and foremost, and utilize severe turnarounds only as a very last resort, if at all. I am supportive of most of the tenets of the “Transformation” model outlined in the School Improvement Grants program. This model involves many of the soundest reforms, including strategies to ensure curriculum reform, leadership and staff development, increased learning time for students, and engaging families and communities. But unfortunately, the use of this model is capped under the “rule of nine” established by the program. I strongly recommend removing the cap on this intervention.
I have heard time and time again that models representing more “incremental” reform have not produced results under No Child Left Behind. I am not arguing that NCLB’s improvement reforms were the ideal solution. But I think it is essential to point out that schools did not have adequate funding or support to fully or effectively implement interventions under NCLB, nor to address out-of-school challenges that impact academic achievement. We now have an opportunity, in ESEA Reauthorization and beyond, to provide significant funding support to implement these interventions in chronically low-performing schools, and to really see what they can do. The idea of holding schools accountable for their student achievement is a good one. But it is my fervent recommendation that ESEA reauthorization prioritize supportive interventions, including those identified in the “Transformation” model, as well as alternate models identified by scholars like Diane Ravitch that are tailored to the needs of schools and communities. Ravitch has recommended sending inspection teams to “challenge” schools, to evaluate the educational and physical condition of struggling schools, and craft a plan for implementing necessary improvements. These improvements could include school safety initiatives, better technology, smaller class sizes, augmented after-school activities, comprehensive staffing (for example, librarians and school nurses), parent education, or a number of other science-based supportive interventions. When we do not provide schools with the resources they need for improvements like these, we are only programming them to fail. There are many methods for turning schools around in a meaningful way that would not spur the major community disturbance that far too often results from overhauling local schools.
Recommendation: Prioritize Targeted Funding for Children With Greatest Need, Not Competition Among States—and Ensure Fairness in Competition
While I have been a longtime advocate for investing in proven reforms, I am also supportive of the idea of encouraging innovation and reform. I know that it is invaluable to continually consider fresh ideas for improving our education system. I also recognize that fostering competition is one way of incentivizing change and novel improvements. However, I have recently become concerned about the unintended effects of shifting the funding of our public schools away from the targeted formula programs schools and students depend upon, and towards a competitive grant system.
First, I have an ideological opposition to the choice—if we must make a choice, due to funding constraints—to limit increases in formula-based funding targeted at high-need children, like Title I, as a trade-off for competitive grants. Second, I have serious doubts about the likelihood that the highest-need districts or states will be able to successfully secure funding through grant competitions. I share this concern with others in school districts and states across the country that have recently voiced their disappointment regarding the large increase in the number of competitive grants recently established via vehicles like the American Recovery and Reinvestment Act (ARRA), and set forth in the Blueprint.
Much of my uncertainty surrounding the competitive grants process stems from states’ recent experience with the Race to the Top program. I know there are many advocates and policymakers who share my misgivings. It is true that there is room for improvement in many states’ first-round Race to the Top applications, including the need for a sufficient level of buy-in from school districts and union leaders. Many of the applications simply did not warrant funding. But it is also evident that the states with the financial capacity to hire highly-skilled grant writers—capacity which in most cases resulted from the receipt of large foundation grants—had an advantage in the process, and were ultimately more likely to be named as finalists. Obviously, not every state or district has the funds to procure this invaluable grant writing support. This means that there is not an even playing field for all applicants. Even worse, the applicants with the highest need may indeed be at a disadvantage.
My recommendation is that as we reauthorize ESEA, we prioritize authorizing funding for the core targeted programs that schools and students depend upon, rather than fostering competition among districts and their students. It is my belief that one of the central roles of the federal government should be providing equal access to effective reforms for all students, and finding ways to identify and disseminate innovative models, rather than encouraging competition. At the very least, if these competitive grants are implemented, our highest priority must be to ensure that the application process is (a) relatively streamlined and simple, (b) not prohibitively time-intensive or labor-intensive, and (c) weighted so that applications from schools facing significant challenges have a greater advantage in the competition. If we are not careful, we may be establishing a process that rewards the already high-achieving schools and districts with the capacity to develop sophisticated proposals, and denies resources to poor students in districts that do not have this capacity. This process would only exacerbate the disparities in our education system. As a fervent advocate for civil rights, I would oppose any scenario that could cause an erosion of equity, or represent backsliding rather than progress.
Recommendation: Increase Funding for Title I to Ensure Equity
One of my core beliefs is that the federal government has the responsibility to provide equal opportunity to quality education for all children, regardless of their socioeconomic status. Right now, as we consider the reauthorization of ESEA, we are in the midst of an economic downturn that has caused widespread state budget crises that have led to severe consequences for school funding. We have a duty to help alleviate this budgetary shortfall, and I urge us all to seize this unique opportunity. It is time to provide the long-overdue funding and support our schools have been waiting for, through funds that are targeted to those children in greatest need.
Although I applaud the President’s proposal, via the Blueprint, to strengthen funding for formula grants for migrant students, homeless children and youth, rural students, and many other high-needs groups, I was startled to see a lack of similar investment in Title I. I have recently heard representatives of the administration repeatedly explain that even though Title I has not been singled out for more resources, there is funding for disadvantaged students to be found elsewhere. But unfortunately, that funding appears to be only available through competitive grants, or through programs like the School Improvement Grants.
My strong recommendation is that ESEA reauthorization include an authorization for noncompetitive funding for Title I that is large enough to make sure that schools with high concentrations of disadvantaged students can serve those students adequately, especially if a reauthorization includes higher achievement standards than currently exist under NCLB. I would even go a step further and urge that we provide full funding for Title I, enough to guarantee that we can serve 100 percent of eligible children. While I recognize that there is a need to look closely at the current Title I formula to guarantee that it is a fair formula, I think we absolutely must significantly increase this funding. Without this support, these students will never be able to compete on a level playing field with more advantaged students.
I find it shameful that in our current system of education funding, the quality of a child’s education is so closely tied to their zip code. I applaud the President’s Blueprint for requiring districts to ensure funding equity between their high- and low-poverty schools, and for requiring states to measure and report on funding disparities and then identify a plan to remedy them. I would even recommend implementing a system like the one laid out in Rep. Fattah’s “Student Bill of Rights,” which would build upon the current requirement that schools within the same school district must provide comparable services and require states to ensure that all their school districts provide comparable educational services. Another option I would encourage you to consider would provide rewards for the states that take the strongest steps towards remedying existing disparities among their schools and guaranteeing funding equity.
But while we can and should do a great deal more to monitor and guarantee funding equity between schools, we also can and should do our part by investing considerably in Title I. When I hear about educators’ and principals’ herculean efforts to overcome the funding shortfalls in their schools, by working 18-hour days, or buying their own school supplies, or spending their spare time calling their students to find out why they are not in class, I often pose the question, “What is it that we are pretending not to know?” We are putting our educators and our schools in untenable situations. One of my greatest fears is that we will let this opportunity, and this moment, pass us by. After so many years of “wandering in the wilderness,” hearing horror stories about massive budgetary shortfalls for Title I resources and other targeted formula programs, it is time for us to provide the increased funding that has been needed for so long.
Recommendation: Ensure the Use of Stronger, More Balanced Tests, and Reform Systems of Accountability
The development of more meaningful, reliable, and multi-subject tests—or other alternative performance-based assessments—should be a central priority of ESEA reauthorization. I also urge the Committee to move towards reforming or altogether replacing No Child Left Behind’s mechanisms for holding schools accountable, in particular the Adequate Yearly Progress or “AYP” measure. Accountability measures should define success by factors beyond these tests, and acknowledge not only achievement in test scores, but progress, as well. And finally, these measures should not be inextricably linked with punitive sanctions, which too often have the effect of punishing the neediest schools and students.
First, I applaud the Blueprint’s intention to require states to work with experts to develop more rigorous and valid state assessments. I am also supportive of the movement towards encouraging states to set high standards, which would help to encourage and ensure the use of a strong curriculum. Under NCLB, too many states have “dumbed down” their tests in order to demonstrate “stronger” student performance. In addition, I believe that our accountability system should encourage a strong curriculum expanded beyond just reading and math, to include a wider array of subjects like art, sciences, history, and civics. Finally, I would encourage the Committee to consider enacting provisions that would expand our ideas of what standardized tests or perhaps alternative performance measures should assess, to include more sophisticated measures of student learning (e.g. higher-order thinking and understanding), as well as the appropriate authorization levels needed to ensure that all communities have access to these assessments.
Second, I am supportive of the Blueprint’s intention to transition from the current mechanism, set forth under No Child Left Behind, which does not adequately acknowledge schools that consistently show progress, towards a model that would recognize school growth. Instead of solely emphasizing whether students are meeting pre-determined levels of academic proficiency, we should also be allowing states to measure progress by looking at students’ achievement growth. We should also be providing a more complete picture of both students’ and schools’ performance, by decreasing our dependence on standardized tests, and increasing our reliance on multiple indicators. For example, some experts recommend utilizing standardized tests in conjunction with other measures of student performance, like writing samples, portfolios, progress towards specified learning objectives, grades, and class participation. Scholars have also recommended that schools themselves be assessed on not only measures of student learning, but on factors like the school’s support for teachers, or their learning environment and conditions. Alternately, schools could be assessed on a regular basis by qualified teams of experts that would evaluate them and recommend research-based interventions, tailored to schools’ needs. There are many suggestions for broadening or tailoring assessments that would be more just than our current metrics.
Finally, I was relieved to see that the President’s Blueprint includes an effort to move in the direction of rethinking the way we determine whether schools are in need of interventions—and I would encourage even more movement in this direction as the Committee develops ESEA reauthorization legislation. In sum, I recommend that we make the most of this opportunity to reconfigure our system of accountability. Our tests must be reliable and valid—and should be considered in conjunction with other student assessments and school indicators. We must reconsider our reliance on “high stakes testing” of students, which have repercussions for teachers, principals, and entire schools, and make a strong effort to resist singularly linking standardized test results and punitive sanctions.
Recommendation: Support Services for Students That Extend Beyond the Classroom
I am a firm believer that although children are deeply affected by what happens inside the classroom, what happens outside the classroom also has a profound effect on their ability to succeed. I also believe that engaging parents and communities in schools is vital to their success. There are dozens of ways in which schools can implement comprehensive strategies for meeting students’ needs outside the classroom walls. However, my priorities for providing interventions beyond the classroom include programs that would: (1) provide programs and funding to augment parental and community involvement, (2) provide community services and family supports, and (3) increase opportunities for pregnant and parenting students.
In recent years, it has become clear that increased parental and community involvement in schools contributes to improved student learning and school success. This involvement has also proven helpful for teachers, as well as for the parents themselves. I recommend that any education reform plan we develop should provide the necessary infrastructure and funding for schools to be used for these purposes. Parental and community engagement programs take a variety of forms and support a variety of services that would allow parents to meaningfully participate in school improvement, including access to services like translation, transportation, and child care. Many advocates have also recommended the development of administrative processes that would more effectively notify parents about both student and parent rights. There are many ways to build parents’ capacity to assist their children’s learning, and many suggestions for designing programs to do this.
But unfortunately, I have not yet seen the emphasis on parental engagement I had hoped to see set forth via the Blueprint—with the exception of somewhat limited potential, within the competitive grants the Blueprint establishes. Nor have I seen evidence that funding will be provided for programs like these. I would strongly encourage the inclusion of these programs in the legislation drafted by the Education and Labor Committee.
In addition to strategies that would facilitate parental and community roles in all aspects of school improvement and school life, I firmly believe that we should be providing resources to schools so that they can offer more comprehensive services and family supports. Research has shown—and I have seen firsthand—that children do better in school when their families and communities do better. Schools are a central access point in communities, where we have the opportunity to provide much-needed services like social services referrals, legal guidance, financial advice, health screening, and adult literacy and GED classes, in an efficient and high-impact way. While the Blueprint establishes a competitive grant process that would support initiatives like these in the form of Promise Neighborhoods, I would encourage the Committee to aim beyond this grant process, and expand access to these services to as many schools in high-need communities as possible.
Finally, I would encourage the Committee to more adequately address the needs of pregnant and parenting students through ESEA reauthorization. The dropout rate for young girls, particularly girls of color, is unacceptably high, and the rate is even higher for girls who become pregnant or have parenting responsibility. These girls face discrimination and often overwhelming obstacles to success on a daily basis. It is time for us to take long-overdue steps to ensure that pregnant and parenting students can stay in school, graduate, and learn essential skills to become college- and career-ready. I recommend that we follow the recommendation of the National Women’s Law Center, and call for the collection of necessary data tracking the number of pregnant and parenting students—data that is currently sorely lacking. We should also be collecting data on how these students are performing, so we know the real story about what is happening to them. In addition, we must provide federal assistance that would help states and local school districts to provide support services for these students, with two intentions: first, to support their attendance and success in secondary school, and second, to support their application and enrollment in postsecondary schools. Providing the necessary support for these pregnant and parenting teens is an investment in their futures, and their long-term economic security—as well as in the security of our communities. This is a priority issue for me, as well as for my constituents.
Once again, I thank you for your visionary leadership in education reform, Chairman Miller. It is a privilege to work with you, and I hope you feel free to reach out to me with any additional questions that may arise as you review my comments and recommendations. I know we share a vision of providing historic educational opportunities for each and every child. I look forward to working with you in the weeks and months ahead.
Sincerely,
Congresswoman Gwen Moore
