Post

November 1, 2018

Dr. Lisa Long
New York State Education Department
Via E-Mail: ESSARegComment@nysed.gov

Dear Dr. Long:

We share the State Education Department and Board of Regents’ belief that the Every Student Succeeds Act (ESSA) represents an opportunity to advance an equity agenda on behalf of the state’s students.

We write in support of the revised ESSA regulations approved by the Board at its September meeting. In particular, we believe the following changes included in the revised regulations will contribute to a stronger and more meaningful accountability system, and we are grateful that these issues that we and other equity advocates raised in the initial public comment period have been addressed:

• Enacting stronger provisions to ensure parental involvement in the creation of school improvement plans;

• Strengthening language on the importance of translation of parent notices;

• Adopting an explicit timeline and methodology to incorporate the new indicator holding schools accountable for reducing out-of-school suspensions;

• Requiring improvement on both the Core Subject Performance Index and Weighted Average Achievement Index as part of the annual achievement progression; and

• Acknowledging that participatory budgeting is just one of several ways a school can increaseparent and student engagement.

In addition, the revised regulation makes several changes regarding test participation. We believe the Board and Department have worked hard to strike a reasonable balance on this difficult issue.

Finally, we commend the Board and Department for maintaining other important provisions that were included in the proposed regulation, such as improving teacher equity by limiting new teacher transfers into schools identified for Comprehensive Support & Improvement to teachers rated Effective or Highly Effective, subject to applicable collective bargaining agreements. The commitment to identifying “Target Districts” is also an important part of an effective school improvement strategy.

Thank you for the opportunity to submit feedback on the revised regulations. We look forward to future opportunities to build on the state’s progress and hope that the additional recommendations we have made can be considered as the ESSA plan is implemented.

Sincerely,

Ian Rosenblum

Executive Director

The Education Trust–New York