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Missouri Coalition Against Common Core

Comments on Missouri Consolidated State Plan

July 6, 2017

Overall DESEs plan confirms that the state sets goals and tracks progress towards those goals in accordance with
federal requirements for receiving Title I funding. However, if the state follows this plan exactly and exclusively,
then we have given 100% control of our states education system over to distant bureaucratic control for less
than 10% of our total state education spending. Whereas, in public testimony before the Joint Education
Committee May 5, 2017, Dr. Preis stated that it is MSIP, rather than the federal law, that drives DESEs activities
for school improvement, clearly her statement is meant to deflect the effect the ESSA accountability plan will
have on the structure of the version of MSIP currently under development. This return on a minority investment
by Washington is a great deal for DC, but perhaps not such a great one for Missouri. There is nothing in the plan
that speaks to what Missouri has chosen to do on its own.

Also notably missing from the plan is any mention of parents or local community interests for education, with the
exception of migratory parental consultation. A few regional meetings every two to five years, does not represent
the will of the local community who, in most cases, provides the majority of funding for the schools. Notably in
those meetings, which DESE references on page 8 in the plan, there was not 100% consensus on the answers to
the four questions asked. Why, therefore, should there be a universal state vision for education? All
accountability is geared toward meeting state (and thereby) federal targets for college and career readiness
without any clear definition of what kind of college, which careers, or valid measurements of when those goals
are achieved. While there is frequent enumerated reporting requirements for input on meeting those targets,
there is no mention of the desire for LEAs to seek out and accommodate local stakeholder input on the quality
and direction of their schools. In other words, the directionality of state accountability is only to the federal
government for a paltry sum of federal dollars with no accountability to the taxpayers of the state who foot over
90% of the education bill. As previously stated, if this plan is the exclusive direction for education in our state,
then we will be systematically avoiding any true local control of the education of our children.

Comments on Specific Sections

A. Title I Part A

Summary: DESE acknowledges that we have, since 1986, attempted to set standards and measure student
performance to achieve the goal originally set out in ESEA to close educational achievement gaps. They commit
to continuing efforts to achieve this goal, despite the fact that there has been no significant advance in that goal
for several decades.

Comment: The adoption of rigorous subject standards combined with regular assessment and a host of
pedagogical tricks to improve the scores on those assessments has failed to achieve the gap reduction goal. The
2012 Brown Center report on American Educationi found:

Data on the effects of those standards are analyzed to produce three findings. 1) The quality of state
standards, as indicated by the well-known ratings from the Fordham Foundation, is not related to state
achievement. 2) The rigor of state standards, as measured by how high states place the cut point for
students to be deemed proficient, is also unrelated to achievement. Raising or lowering the cut point is
related to achievement in fourth grade, but the effect is small, and the direction of causality (whether a
change in cut point produces a change in test score or vice versa) is difficult to determine. 3) The ability
of standards to reduce variation in achievement, in other words to reduce differences in achievement, is
also weak.

The entire premise of the need for an evaluation paradigm derived from the corporate model of inert product
quality control, that is, standards, assessments and accountability measures, applied to living human beings in
vulnerable stages of growth and development is entirely inappropriate. Yet, our state department and state
Board Of Education persist in the pursuit of federal dollars tied to this paradigm without concern for the harm
that is causes children who dont fit neatly into the predetermined outcomes.
The theory that targeted money would allow school districts to apply teaching practices that would counter the
effects of generational poverty, oppositional culture and single parenthood to produce students who perform as
well as those in their grade who dont face these challenges was and remains a falsehood that DESE seems willing
to perpetuate in order to get more money from the federal government.

ESSA made clear that these monies are to be used to supplementii educational spending, not supplant it. In other
words, state and district funding should be used to meet the educational requirements of most of our students;
and Title I money used to provide additional programming for the very lowest performing students. Policies and
program decisions associated with money used for a portion of the population should describe policies to identify
and support that portion. The policies and procedures in this section apply to all students in all LEAs and thus
the Title I money becomes part of the normal education spending, in opposition to the requirements of the law.
This results in federal overreach into state local board and parental authority to make decisions about education
at their level of influence.

(p. 9) iii Eighth Grade Math Exception

We are pleased to see the state continue with its request iii to offer EOC exams in mathematics in an accelerated
sequence not necessarily in alignment with federal guidelines.

(p. 11) 3. Native Language Assessments

It is entirely appropriate that the state does not now, nor does it intend in the future, to offer assessments in
languages other than English. As English is the #1 language of international commerce we would be placing our
students at a disadvantage if we did not commit to their mastery of this language and would be out of alignment
with the states goal of preparing our children to compete in the global marketplace if we did not prioritize
academic mastery of English.

(p. 14) i. Establishment of Long Term Goals Graduation Rates

Summary: DESE proposes to reduce by half the rate at which student fails to graduate. While individual schools
may have statistically significant differences, our statewide average graduation rate has risen from 87% in 2011
to almost 94% in 2016. As the plan refers to the states objective, not individual districts, this statement implies a
goal of an average 97% graduation rate in 10 years.

Comment: This goal encroaches on reasonable expectations of some students ability to graduate with a goals and
objectives diploma let alone a regular one. It also offers inappropriate incentive to districts to push students
through to graduation who have not truly met the standards for a high school degree in order to cook the data
and report meeting pre-determined goals. We question the appropriateness of states and districts controlling the
personal decisions of students and their families with respect to schooling. At what point does the state take
responsibility for increased dropout rates associated with the common core state standards initiative as
described in the Carnegie-McKinsey study, Opportunity by Design: New High School Models for Student

With such aggressive goals, districts may be incentivized to push these students more than is recommended by
best practices, or worse, to find methods to artificially boost their test scores in order to meet arbitrary state
targets for graduation. This does a disservice to the student and the teacher. A more reasonable goal would be to
state that Missouri will continue to strive to increase graduation rates that are in line with student ability.

90/90 Principle for Attendance: While it is true that a child who misses much of the educational opportunities
offered by the local school district could have a hard time learning enough foundational material to progress from
grade to grade, the 90/90 rule is an arbitrary means of securing an education. The state has long had a truancy
process in place to make sure children do not miss out on the opportunity for a free public education.

Such a process should have flexibility to make accommodate those students who are making adequate progress,
as determined by their teacher, even though they may be missing days of school. Without such flexibility, the
state can and has used this rule to bully parents: whose children are above average or high performing, who wish
to take their children out of school for other enrichment opportunities, or whose children are dealing with
frequent or chronic illnesses, into sending their child in school instead. This aggressive universal application of
the 90/90 rule obliterates parents authority and accountability for their childrens education.

(p. 26) v. Annual Measurement of Achievement

We continue to remain vehemently opposed to the states requirement to assess 95% of an LEAs students on the
MAP. An April 4, 2016 letter signed by 19 U.S. House members clearly stated that parents rights to direct the
education of their children are to be honored and they should be given the option to refuse the statewide
assessments (Exhibit A). The loss of academic achievement points for a district who is honoring parents exercise
of their rights is not a valid reading of the intended requirements of ESSA.

Protection of parental decision-making to opt their minor children out of Missouris statewide assessment is
particularly important in light of the questionable validity and reliability of the MAP/SBAC. vvi Problems reported
with the computer based standardized and/or adaptive assessments include the discriminatory effect of tests
administered on various electronic devices, especially for students from high-poverty communities. The complex
computer adaptive format has not been independently validated. These assessments do not inform classroom
instruction, nor do they assist teachers in addressing the academic needs of their students. The literature
suggests that the item content is not restricted to an objective assessment of what a student knows and is able to
do, but includes assessment of attitudes, values, and mindsets. The integration of social-emotional learning in
assessments of math and reading would certainly compromise validity of the assessment. vii

Transparency about the quality of a states assessment is required in federal law. The Every Student Succeeds Act
Section 1111(b)(2)(b) states,

The assessments under subparagraph (A) shall

(iv) be of adequate technical quality for each purpose required under this Act and consistent with
the requirements of this section, the evidence of which shall be made public, including on the website of
the State educational agency;viii

To date, no such evidence of technical adequacy is posted on the DESE website ix; Iowa has declared a moratorium
on the transition of schools to the SBAC pending further review by the legislature x; and the Connecticut State
Board of Education just eliminated a requirement that SBAC results be used in teacher evaluations. xi

Districts should be required to publish a notice of parents rights to refuse the statewide assessment and a
deadline to inform the district of their intent to do so. No form should be used in order to minimize attempts by
district personnel to systematically remove some children from testing. Such individual parental notices should
be required to be archived for a period of five years for potential future audit.

(p. 28) e. Technical Assistant for Schools Identified for Comprehensive or Targeted Support

Summary: This section describes the Statewide System of Support (SSOS) which includes evidence- based
interventions that support improved student achievement, graduation rates and closing achievement gaps for all
subgroups... This means holding each LEA and school accountable for student outcomes along the students
journey in preparation for post-secondary success. If a school is not demonstrating the expected outcomes for
students, MO- DESE will intervene on behalf of the students with rapid and targeted interventions.

Comment: Such interventions have been tried for decades around the country they have shown very little ability
to move the needle on these indicators. Marylands state superintendent of schools, Nancy Grasmick, conceded
Very little research exists on how to bring about real sea change in schools. Clearly, theres no infallible
strategy or even sequence of them. xii DESEs threat to hold LEAs accountable for outcomes is not in alignment
with the state constitution or federal law which is about access to quality education, not outcomes. The latter is
up to the student and their family, not the state. There is very little which could not be done for or to a student in
the name of producing an expected outcome. We should not authorize this level of expenditure or government
(p. 31) 2. Disproportionate Rates of Access to Educators

Summary: DESE correctly identifies the numerous inequities that occur in society that can lead to inequitable
student outcomes ( e.g. students of color, students from low-income families, rural students, students with
disabilities, students with limited English proficiency). The statement Because of the multiple causes for
inequity in teacher and leader distribution, the solutions must be systemic rather than treating merely the
symptoms, however, appears to be lumping all those causes in together, instead of stating that different causes
would naturally lead to different remedies.

Comment: The teacher evaluation requirements demonstrate that the state is now dictating how districts will
evaluate their teachers for retention thus nullifying local control of district personnel. Since we are not a
collective bargaining state for teachers, it should be up to each district to determine the metrics by which they
will evaluate their teachers.

(p. 33) 4. School Transitions

Summary: This section touts the benefits of the Missouri Post-Secondary Success Project (MPSS), a college-and-
career competency framework educators may use to systematically embed these competencies into course
content. These competencies are integral to both in-school and post-secondary success by supporting students to
be career-equipped, lifelong learners who are socially and emotionally engaged.

Comment: This is social emotional learning wrapped into Competency Based Education. Many parents would
prefer to see the emphasis on providing broad based academic knowledge that children can use to choose
whatever career or academic path they want to pursue, instead of a push for a job skills based curriculum. Worse
is that some of the competencies embedded in such course work attempt to manipulate the child into adopting
approved psycho-social learning targets which can only theoretically be tested and measured accurately.
Behavioral skills such as social engagement, advocacy, leadership, life-long learner and critical thinker are
bandied about casually without commonly understood definitions or parental buy-in and should be dropped
from the states official plan.

(p. 45) Missouris Equity Plan

Summary: According to the Plan the MEP includes various strategies for determining root causes of gaps in
equitable educational opportunities for students. This is determined by an analysis of various measures of data
across different types of schools. Once root causes are identified, strategies are developed and implemented to
eliminate the gaps. Data will be gathered to determine the quality and usefulness of training and support
provided to school and LEAs on this process and the impact it has on addressing gaps of inequitable educational
opportunities for various populations of students.

Comment: The Plan does not provide examples of root causes for various types of gaps. It does not specify if
these are gaps between schools or districts. If such gaps are funding related it does not offer any proposals for
how those inequities, which theoretically are already addressed by the state funding formula, could be reduced.

Strategies that are developed should be tested in a limited controlled experiment to examine their effectiveness
in addressing these root causes. The results of these studies should be published by DESE to allow other districts
to learn from the experiments what works and what doesnt.

(p. 56) J. McKinney-Vento Homeless Assistance Act

Summary: The Plan speaks primarily to what districts will do to make sure their employees are aware of the
MVHA, how they are to resolve logistical disputes (i.e. which school can they go to, who provides transportation,
can they be admitted w/o vaccination records etc.), and making sure an already identified homeless youth gets an
education. Most of these procedures have been in place for years.
Comment: What is not mentioned in the plan is DESEs guidance to districts regarding the placement of students
under provisions of this Act or the hardship that over-interpretation of the MO statute codifying this federal law
has created on MO families. In a September 19, 2012 DESE presentation by Donna Cash Homeless 101: A Primer
on the McKinney-Vento Act attendees were told,

You dont have to tell the parents that theyre entered into your information systems as homeless You can
tell the parents that they can refuse the services under McKinney Vento, but we still have to let the
federal government know. And one of the reasons that we do that as you all know, that numbers are
tied into funding... Funding drives data. Data drives funding. So, if we are serving that many students in
Missouri, we want our piece of the McKinney Vento pie from the federal legislation.

This shows a clear focus on obtaining money, not on doing what is in the best interest of the child. Such guidance
on the part of DESE demonstrates a disregard for parental rights.

To qualify to be offered services under MVHA district personnel are only required to make a determination if a
students housing is fixed, regular and adequate. These three terms are not well defined. They can be, and have
been, used to qualify students who are merely going through a rebellious period and staying with friends for an
extended time, a condition Cash referred to as couch surfing.

The impact of this type of definition manipulation can be devastating to a family. With no formal hearing or due
process, parental rights have been cut off, access to student records and graduation have been denied to at least
two families in Missouri that we know of. DESE has given the nod district personnel that this is acceptable

Further, the act of the school, without due process, declaring a student homeless, places the child under the
conditions of RsMO 431.056.1 which says that a child of 16 or 17 years of age may then be qualified and
competent to contract for housing, employment, purchase of an automobile, receipt of a student loan, admission
to high school or postsecondary school, obtaining medical care, establishing a bank account. Tremendous
damage can come from such decisions made by an immature child, with the school acting only as quasi guardian
ad litem, without any true accountability for the childs future. Credit can be ruined as well as both physical and
psychological health. This is unacceptable.

We would like to see added to this section a discussion of policies to address parental disputes of such a
designation by the school district with the requirement that a representative from Family Court be present for
any such mediation.


In general, the state accountability plan is destined to result in the same failures under NCLB because nothing has
substantively changed in the paradigms used to identify and support failing schools; worse the assessments
described for determining district performance are not validated for that purpose.

The state constitution says that knowledge and intelligence being essential to the preservation of the rights and
liberties of the people, the state will provide free education. That is our directive, not the development of the
whole child into an adult of a particular character preloaded with skills to enable them to contribute to the states
economy. Such a goal requires tremendously more funding than the constitutionally required 25% of the states
overall spending and the erasure of parental rights to raise their children as they see fit.

It is not our job to educate kids for the future world. They will create that world with ideas that we cannot even
imagine today.

Mary Byrne Ed.D. Anne Gassel Gretchen Logue

417-818-1261 636-448-2124 314-378-6568

Missouri Coalition Against Common Core
Exhibit A

iiESSA Title I, Part A (1) IN GENERAL.A State educational agency or local educational agency shall use Federal
funds received under this part only to supplement the funds that would, in the absence of such Federal funds, be made
available from State and local sources for the education of students participating in programs assisted under this part,
and not to supplant such funds. (2) COMPLIANCE.To demonstrate compliance with paragraph (1), a local
educational agency shall demonstrate that the methodology used to allocate State and local funds to each school
receiving assistance under this part ensures that such school receives all of the State and local funds it would otherwise
receive if it were not receiving assistance under this part. (3) SPECIAL RULE.No local educational agency shall be
required to (A) identify that an individual cost or service supported under this part is supplemental; or (B) provide
services under this part through a particular instructional method or in a particular instructional setting in order to
demonstrate such agencys compliance with paragraph (1).