Alabama’s Federal Waiver Request – What Is Changing?

Monday is the deadline for public input on Alabama’s revisions to the waiver from the federal requirements under the Elementary and Secondary Education Act (ESEA), a.k.a., No Child Left Behind. The original waiver was renewed in 2014, and now it’s time for another renewal.

Did you read it? Do you know what’s changing?

There are big changes in this waiver request, changing the way Alabama’s educators will be held accountable for student learning in a big way from the original waiver in 2013.

Those School and District Performance Indices have been removed. Achievement gap measures will no longer be a part of the accountability system. And Alabama’s A-F grading system has been fully disconnected from the federal accountability system.

The Alabama State Department of Education (ALSDE) gave the public an additional four weeks to comment after the initial two-week comment period closed on March 31. They even posted a strikethrough version where we could easily determine which parts of the waiver they proposed to change. All of the attachments are online.

[Direct link to strikethrough version document added 5/12/2015 2:05 p.m. after reader made me aware that the ALSDE had placed that version behind a password today. Thanks!]

What the Waiver Covers

ESEA waivers are the USDOE’s answer to Congress’s failure to reauthorize the ESEA, a.k.a. No Child Left Behind. Alabama waited until the final window to apply for the waiver, and received initial approval in June 2013.

The waiver is Alabama’s plan to develop and implement the following federally-mandated three principles for students:

• Principle 1: College- and Career-Ready Expectations for All Students
• Principle 2: State-Developed Differentiated Recognition, Accountability, and Support
• Principle 3: Supporting Effective Instruction and Leadership

In September 2014, Alabama received an extension of the waiver, with U.S. Education Secretary Arne Duncan noting, “My decision to extend Alabama’s ESEA flexibility request is based on my determination that ESEA flexibility has been effective in enabling Alabama to carry out important reforms to improve student achievement and that this extension is in the public interest.”

The USDOE monitored Alabama on parts of the waiver in December and issued a report that said Alabama is mostly meeting expectations for implementation of Principle 1 (with the exception of administering high-quality assessments), not meeting expectations for Principle 2, and acknowledged Principle 3 was under review.

Principle 1: College- and Career-Ready Expectations for All Students

Nothing substantive changed in this area.

Notably the ALSDE explicitly committed to an “annual review of the college- and career-ready standards (CCRS) by committee based on current student data and educator input”.

Language was added to further explain the implementation process, which should be of interest to those who have been busy implementing these standards in our schools.

There is mention of a state-level task force formed by the ALSDE to review “Alabama’s current processes, laws, Code, procedures, and practices for standards and textbook adoption”. That task force is expected to make a recommendation for any changes to the state superintendent by this fall.

We learn, too, that the ALSDE’s contract with GlobalScholar (Scantron) ends after the 2015-2016 school year, and that further use of these formative assessments will depend on legislative funding. Funding for these tests currently is provided to districts and schools at the state level.

Military enlistment was added to the definition of college- and career-readiness.

The definition is now as follows: “Alabama defines a student as college- or career-ready if the student earns benchmark scores on any of the sections of the ACT test, earns a qualifying score on an AP or IB exam, earns transcripted college or postsecondary credit while in high school, earns a Silver Level on the ACT WorkKeys, military enlistment, or earns an approved industry credential.”

QualityCore End of Course tests were obliterated from the waiver, with the ALSDE stating that the 10th grade ACT Plan (which will be the ACT Aspire 10 next year) will now be used to report achievement in high school.

Assessments for grades 3 through 8 remain unchanged, with the exception that the ACT Aspire Science will be used to assess science achievement in grades 5 and 7, which began this year.

Here’s the updated timeline. Click to make it larger.

Principle 2: State-Developed Differentiated Recognition, Accountability, and Support

When Alabama first decided to seek a waiver from ESEA accountability requirements, the ALSDE made a big deal of wanting to have a single accountability model for schools and districts to keep up with.

So the idea was that the federal accountability system would become the foundation and basis for the state’s A-F grading system (and the various components of that system).

However, the ALSDE has made it very clear in the waiver request that this is no longer a good idea, and has removed all references to the A-F grading system. “Alabama’s A-F law (Act 2012-402) was determined to best serve Alabama’s students if it was separate from Alabama’s ESEA Accountability Model,” the waiver states.

The School Performance Index (SPI) has been dropped altogether.

Instead, the ALSDE proposes using an Annual Measurable Objectives (AMO) Report for accountability purposes.

It will include Achievement, Attendance Rate (for schools without a grade 12 and for districts), Graduation Rate (for schools with a grade 12 and for districts) and Learning Gains.

AMOs will not be set just yet due to the state having shifted to using the ACT Aspire. Multiple years of data are needed to set AMOs, and we just don’t have multiple years of data.

That leaves the accountability model looking like this:

Alabama’s schools will not be held accountable for the gap measure. Rather, learning gains will be measured over a two-year period for each subgroup and will be reported beginning with the 2016-2017 school year.

The waiver proposes to report the aformentioned data items in the public report, disaggregated by subgroup, and then to generate a second, internal report to be “compiled and utilized for recognition purposes and to provide needed support to schools and districts”.

Participation in assessments at the 95% level will be required as it is now, but that participation rate will not be reported as it was in the past.

Two sets of reports? Two sets of books? Hmmm. In the initial waiver, all items were to be reported to the public.

Both the public and internal reports will be used by schools and districts to write Continuous Improvement Plans (CIP).

So Which Accountability Measures Are Schools Using Now and in the Future?

There are accountability measures in four areas: achievement, attendance, graduation rate and learning gains.

Because AMOs for achievement have not yet been established using the ACT Aspire and the ACT Plan/Aspire 10 as the assessment, each school and district will be required to meet AMO targets in one of the the following three ways for the 2014-2015 school year.

• Meet or exceed the state average from the 2013-2014 data.
• Show improvement equal to the improvement of the state.
• Reduce the percentage of non-proficient students by ten percent from the previous year’s data to meet its AMO for each subgroup.

The same method is proposed for the 2015-2016 school year, using the 2015-2016 state data to determine the average.

The 2016-2017 school year will use baselines established using the 2015-2016 data applying a methodology developed by the state Accountability task force.

Full disclosure: I serve as one of the members of the state Accountability task force. The task force has been meeting on a regular basis since 2012. I joined the task force in October 2013.

The 2014-2015 attendance rate AMO can be met in one of three ways:

• Meet or exceed the state goal of 90%.
• Show improvement from the previous year.
• Meet or exceed the state average based on data from the two most recent years’ average for the school/district.

For 2015-2016 and 2016-2017, the same methods will be used, but three years of data will be used for the third option.

The graduation rate AMO target can be met in one of the following four ways for the 2014-2015 school year:

• Meet or exceed the state average from the 2014-2015 data.
• Show improvement equal to the improvement of the state.
• Current year graduation rate is greater than or equal to the previous year graduation rate plus 10% of the difference between the state average and the previous year’s graduation rate.
• Meet or exceed the state average based on data from the two most recent years’ average for the school/district.

The 2015-2016 AMO target is the same, but adds the additional requirement that “if the state average is 90% or above, schools and districts must meet or exceed 90%” and will use three years of data to determine the average for the school/district.

For learning gains, AMOs will be established for each school and district for 2015-2016. Schools and districts will be required to meet or exceed the state average improvement for each subgroup.

Beginning with the 2016-2017 school year, AMOs will be determined by the Accountability Task Force.

A school or district will be required to meet the relevant AMO for any subgroup with more than 20 students, which hasn’t changed from the 2013 waiver.

All of these accountability measures will be used to identify priority, focus and reward schools. The identification of priority districts has been dropped from the renewal request.

The waiver renewal request outlines very specifically how these schools will be identified, how schools will be monitored, and what supports will be given to the various categories of schools.

Principle 3: Supporting Effective Instruction and Leadership

One condition of the original waiver approval was for Alabama to be clearer on its plan to implement Principle 3. Alabama’s plan were reviewed by federal peer reviewers and in December 2014, the ALSDE received feedback from the U.S. Department of Education (USDOE) on Principle 3. The USDOE had a number of concerns that were to be addressed in this waiver renewal request. These concerns centered around the guidelines for teacher and principal evaluations and the support systems to ensure proper implementation.

Principle 3 has been completely rewritten, but it is unclear whether the rewrites were substantive or simply cosmetic.

This entire section should be of great interest to teachers and principals, as it delineates how educators will be evaluated.

The use of student “growth measures” to evaluate educators has been a highly contentious debate across the country, leading to U.S. Education Secretary Arne Duncan’s announcement last August that states could delay using those growth measures in teacher evaluations.

Alabama is proposing to pilot using student growth measures as a part of teacher and leader evaluations during the 2015-2016 school year in selected school districts, with full implementation in the 2016-2017 school year.

The ALSDE is implementing “the teacher effectiveness model” in three sections, with the first two sections not incorporating any student achievement measures.

Section III is where growth measures are utilized. Here’s what the waiver says:

The Teacher Effectiveness Model will use multiple data sources to evaluate performance against the approved qualitative instrument. Each component will have the following weights:

I. Professional Commitment- 30%
II. Professional Practice – 35%
III. Impact on Engagement and Learning – 35%

Within Section III, that 35% will come from surveys (10%) and student growth data (25%).

That student growth data for teachers will be comprised of the following:

Leadership effectiveness will be evaluated a little differently, but student growth will still comprise 25% of a leader’s evaluation. And student, teacher, parent and community surveys will be incorporated into a leader’s evaluation as well.

Here’s what the student growth component for leaders will look like:

While the training and implementation plan is laid out fully in the waiver, if you will be subject to these evaluations, you can get a head start by reviewing it yourself.

What’s Next

It is up to the USDOE to review and approve Alabama’s waiver. The timeline for approval is not clear, but will likely take a few months.

If you have any comments you’d like to share with the ALSDE, those comments are due by close of business on May 11.