The Massachusetts Board of Elementary and Secondary Education
Proposed Amendments to 603 CMR 2.00 — Accountability and Assistance for School Districts and Schools, and the Next-Generation District and School Accountability System
At the June 26, 2018 meeting of the Board of Elementary and Secondary Education (Board), I will make two recommendations to the Board related to the district and school accountability and assistance system. The first will be to vote to approve the proposed amendments to 603 CMR 2.00: Accountability and Assistance for School Districts and Schools. The second will be to vote to approve Massachusetts' new district and school accountability system, which was discussed most recently at the May 14 special meeting of the Board.
Proposed Amendments to 603 CMR 2.00 — Accountability and Assistance for School Districts and Schools
At the March 27, 2018 meeting, the Board voted to solicit public comment on proposed amendments to 603 CMR 2.00: Accountability and Assistance for School Districts and Schools. I recommend that the Board take a final vote to approve the proposed amendments to the regulations, as presented below, at our meeting on June 26.
The memorandum to you dated March 16, 2018 includes the rationale for the proposed amendments. Below, I am providing a summary of the public comment the Department of Elementary and Secondary Education (Department) received, as well as a summary of the discussion with the Board's Accountability and Assistance Advisory Council (AAAC) that occurred on May 8, 2018.
Public Comment
The Department received eight written comments during the public comment period. Copies of all the comments are attached to this memo. The most commented-on issues were:
- The lack of specificity about the accountability system in the regulations.
- The use of the percentile metric to rank schools relative to each other.
- The removal of the Conditions for School Effectiveness.
- A desire to include a formal period of public comment on any future proposed changes to the accountability system.
- The authority of the Board to designate a district as underperforming
- The authority of the Commissioner to modify the turnaround plan for an underperforming school.
- The Commissioner's authority to remove the chronically underperforming designation from a school that is within a district that the Board has designated as chronically underperforming.
Attached for your review is a document that summarizes the comments that were received and the Department's responses, and identifies the individuals and organizations that submitted comments.
AAAC Discussion
The Board's Accountability and Assistance Advisory Council (AAAC) discussed the proposed amendments to the accountability regulations on May 8, 2018. Council members noted that it was not clear in the notice of public comment that comments were invited on both the proposed regulations and the accountability system. However, the majority of public comments received included remarks about the accountability system, indicating that commenters understood the connection between the regulations and the proposed accountability system that the Board has discussed at recent meetings.
The Council also commented on the lack of detail about the accountability system and its measures in the draft regulations. In response to this comment and similar comments from other organizations and individuals (see attached summary), the Department has included additional details about the accountability system in the updated proposed amendments.
Proposed Modifications
In response to the comments received, the Department is proposing the following changes to the amended regulations:
- The inclusion of additional details about the design of the accountability system. These details include how districts and schools will be classified under the new system.
- The inclusion of a public comment period related to any future proposed changes to the accountability system. This would allow stakeholders to provide input on details of the accountability system that are documented in sub-regulatory guidance as well as through the regulatory process.
- Updated language around the Commissioner's authority to modify the turnaround plan for an underperforming school. The Department modified this provision to state that the Commissioner may propose modifications to the turnaround plan for an underperforming school.
Additional changes were technical in nature, and were made to better align the regulatory language with the terminology used in the accountability system.
I recommend that the Board vote on June 26 to adopt the amendments to 603 CMR 2.00 as presented. A redlined copy of the proposed changes to the regulations is attached, along with a motion.
Next-Generation District and School Accountability System
At the December 2017, January 2018, and May 2018 meetings, the Board discussed the overall design of our state's new district and school accountability system and the proposed weighting of indicators within the accountability system. At the June 26 Board meeting, I will ask the Board to approve the accountability and assistance system so that the Department may report district and school results under the new system this fall.
Accountability System Design
State and federal laws require the Department to implement a system of district and school accountability. In recent Board meetings, we have discussed the framework for the new accountability system, as approved in the Massachusetts state plan under the Every Student Succeeds Act (ESSA). While maintaining a single statewide accountability system that meets both state and federal requirements, the new system allows the Department to identify schools that require assistance or intervention and those that are demonstrating success. Highlights of the new system include:
- The inclusion of additional accountability indicators, which will provide information about school performance and student opportunities beyond test scores;
- A focus on raising the performance of each school's lowest performing students in addition to the performance of the school as a whole; and
- The discontinuation of accountability and assistance levels (Levels 1 to 5), which will be replaced with accountability categories that better define the progress that schools are making and the type of support or assistance they may receive from the Department.
The attached summary of the accountability system describes the key components of the system that we have discussed at our last few meetings. Additionally, per the request of Board member Doherty at the May 14 special meeting, a one-page overview of the accountability system is attached, which can be used to communicate with families, communities and other stakeholders about the purpose and highlights of the new system. I recommend that the Board vote on June 26 to approve the accountability system, as described in these two documents.
District and School Report Cards
In addition to detailed accountability reports, the Department will also publish updated district and school report cards in December 2018. The report cards will contain accountability and assessment results in addition to other important information. Measures like student discipline, access to the arts, educator qualifications, course passing rates, and per-pupil spending will also be included. Report cards are intended to compliment accountability and assessment reports to paint a broader picture of school performance and student opportunity.
Senior Associate Commissioner Russell Johnston, Associate Commissioner Ventura Rodriguez, and Associate Commissioner Rob Curtin will be available at the Board meeting to answer your questions.
Enclosures:
