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The Massachusetts Board of Elementary and Secondary Education

Educator Evaluation: Proposed Amendments to the Regulations on Student Impact Rating

To:
Members of the Board of Elementary and Secondary Education
From:
Mitchell D. Chester, Ed.D., Commissioner
Date:
November 18, 2016

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This memo revisits a topic discussed by the Board of Elementary and Secondary Education during your spring 2016 as well as the September and October Board meetings. This month I am presenting proposed amendments to the Educator Evaluation Regulations and recommend that the Board vote to release the proposed amendments for public comment. The enclosed proposed amendments were developed in light of the feedback received from a range of stakeholders regarding the challenges districts have faced in determining a separate student impact rating for each individual educator, a requirement under the current regulations.

Importantly, the proposed amendments eliminate the separate student impact rating, but preserve a focus on student learning in the evaluation framework. This approach addresses the concerns about a separate student impact rating while retaining evidence of student learning based on multiple measures, including common assessments and statewide student growth measures, as a component of the educator's summative performance rating.

I believe strongly in the efficacy of Massachusetts's teachers and administrators, including their ability to engage in honest inquiry about how much and in what ways students are learning. At the same time, there is wide variation in the success with which individual educators impact student learning. Because the core work of schools is teaching and learning, I believe that our evaluation framework must reflect both educator practice and student results. A framework that results in a rating focused solely on practices without permitting the evaluatee and the evaluator to consider evidence of student learning (which some have advocated) fails to take into account key evidence about the educator's efficacy.

Background

As a reminder, under our current Educator Evaluation regulations, teachers and administrators receive two separate ratings: (1) a summative performance rating; and (2) a student impact rating. Both ratings are based on the professional judgment of the evaluator; neither rating is determined by the application of a formula. The regulations provided for staggered implementation, with districts adopting the process for determining a summative performance rating first, and subsequently adopting the process for determining the student impact rating.

For the past five years, districts have been implementing the process for determining summative ratings. Implementing the student impact rating has been more challenging. As the Department has worked with stakeholders to develop guidance and solicit feedback on the rollout of the student impact rating, we have heard concerns about assigning individual educators a student impact rating. At the same time, we have also heard from stakeholders that evidence of student learning, including evidence from common assessments and statewide assessments, is an important component of educator evaluation.

Designing the Proposed Amendments

Stakeholder feedback has been a primary driver of the proposed amendments I am recommending. Several of our key stakeholder groups have called for changes that would eliminate the student impact rating, while retaining evidence of student learning as an indicator used in educator evaluation. For example:

  • The Massachusetts Association of School Superintendents (M.A.S.S.) issued a "Statement on District-Determined Measures Amendment" dated June 13, 2016. It states: "We value common assessments/district-determined measures and believe they provide valuable input to the overall evaluation process." M.A.S.S. proposed changing the regulations to eliminate the requirement for a separate student impact rating. The M.A.S.S. proposal included that the Board "may require that school districts consider student performance data which indicates a student's learning, growth and achievement, including but not limited to standardized statewide testing data, as an element of the educator evaluation process …"

  • Similarly, the Massachusetts Teachers Association (MTA) and the American Federation of Teachers Massachusetts (AFT-MA) released a joint position paper in April 2016 on the student impact rating and the Educator Evaluation Framework, which includes their proposal for a "relatively simple fix": "Eliminate the impact rating mandate while keeping indicators of student learning as a source of evidence in the educator development and evaluation process."

    In addition, in testimony to the Board in June 2016, President Madeloni of the MTA stated, "Student learning is central to what we do every day. Student learning is also embedded in the Educator Evaluation System in many ways."1 Beverly Miyares of the MTA echoed those comments in her presentation: "Student learning is at the center of Educator Evaluation Framework." Similarly, Dan Murphy, of AFT-MA, described the AFT-MA's commitment to student learning in the Educator Evaluation Framework and to the use of common assessments: "Student learning is central to the five-step evaluation process, as President Madeloni pointed out. Evaluators already have the ability to look at common assessments. We are pro common assessments, if used well, and other types of student learning as part of the evaluation process."

In designing the proposed amendments to the educator evaluation regulations, Department staff considered how best to eliminate the separate student impact rating while retaining student learning as an essential part of the framework. We worked with the organizations referenced above to develop ideas, relying on them to advise on feasibility for schools and districts. Ultimately, I believe the proposed amendments respond to many of the concerns raised about the separate student impact rating, while reflecting my commitment that evidence of student learning must be included in the body of evidence evaluators use to determine educator ratings.

Summary of Proposed Amendments

The proposed regulatory amendments include the following:

  • Eliminating the separate student impact rating of high, moderate, or low, which was to be reported to the Department at the educator level.

  • Retaining the 5-step cycle, which culminates in a summative performance rating based on multiple categories of evidence and the professional judgment of the evaluator. (See the attached Quick Reference Guide for more information about the evaluation process.)

  • Establishing a "student learning indicator" under Standard II: Teaching All Students (for teachers) and under Standard I: Instructional Leadership (for administrators). Standards describe the broad categories of knowledge, skills and performance of effective practice, and indicators describe specific knowledge, skills, and performance for each standard. By including a student learning indicator, impact on student learning is a component of the rating for the Standard. The rating for the Standard, in turn, is a component of the Summative Performance Rating. The student learning indicator does not result in a separate stand-alone rating.

  • Providing additional information about the types of measures that can be used as evidence of educator impact on student learning, including: a definition of common assessments, establishing the use of common assessments and statewide growth measures in the evaluation process as optional for educators who are not responsible for direct instruction, and clarity that other evidence of student learning beyond common assessments and statewide growth measures may be considered.

  • Adding a new definition of "expected impact" on student learning to guide evaluators and educators in understanding the role of professional judgment in looking across multiple measures to understand an educator's impact on student learning.

In addition, the proposed amendments also include technical changes unrelated to the student impact rating, such as removing provisions describing timelines that have expired.

Next Steps

Our goal is to support meaningful educator evaluation while maintaining student learning as a central consideration. I look forward to discussing the proposed regulatory amendments with the Board on November 29. Should the Board vote to release the proposed amendments for public comment, my staff and I will continue to engage with stakeholders to refine these proposals. After reviewing the responses received during the public comment period and determining whether further changes are needed, I plan to bring the amendments back to the Board in February 2017 for final adoption.

Enclosures:

Download PDF Document  Download Word Document
Quick Reference Guide to educator evaluation process
Download Word Document
Proposed amendments to Regulations on Evaluation of Educators
 
Motion to solicit public comment

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Last Updated: November 22, 2016
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