Public Comment to NYSED on Teacher Evaluations

I am writing to express my deep concern over the Governor’s proposed education reform to the evaluation of NYS teachers.  It is my belief that this plan would be disastrous to public education in our state for a number of reasons.  

My concern is not unfounded.  Evaluating teachers by “Value Added Methodology” based on student test scores is a deeply flawed plan that has no validity in practice.  Surely the NYS Education Department and the Board of Regents have taken notice of the studies that have thoroughly discredited this methodology.  All one needs to do is “assess the assessment” over the past years.  One-third of New York teachers moved from one category to another each year on that measure.  In other words, a teacher could be found “highly effective” one year, and “developing” or “ineffective,” the next; or vice versa.  There is no consistency in the ratings, which should be a huge red flag to those overseeing the rating system.  Lack of consistency is tantamount to lack of validity.  The proposed plan worsens this effect because a teacher can still receive an ineffective rating, even though they were developing or effective on the other three categories of the system.

A brief prepared jointly by the American Education Research Association and the National Academy of Education warned against using the VAM scores in high-stakes evaluation, https://edpolicy.stanford.edu/sites/default/files/publications/getting-teacher-evaluation-right-challenge-policy-makers.pdf and the American Statistical Society (a group whose findings should be weighted heavily, since this is not an “educational” organization) stated that using these VAM scores “can have unintended consequences that reduce quality.” https://www.amstat.org/policy/pdfs/ASA_VAM_Statement.pdf.  Research states that teachers have at most 1-14% impact on student test scores, yet our governor would like to base 50% of the evaluations on such measures?  It is ludicrous.  

Those teachers most at risk are the ones we need the most. Special education teachers selflessly give to our neediest students. Because these students are often tested at grade level (regardless of their intellectual age) they will not show "growth" on the test scores that judge their teachers. These students show progress in a thousand different ways, but these ways are not going to show on a grade-level test, alternative assessments are needed.  Also at risk are teachers of English Language Learners. Only 3% of these students show proficiency on the test because - duh - they do not speak the language yet. Also at risk are gifted teachers or teachers of highly able students in excellent districts - these students often max out the tests, hitting a "curricular ceiling," and so do not show growth. Teachers in high-poverty communities, where psychological and social problems abound - these students are not going to show growth unless they have the resources of well-funded, well-staffed community schools where they receive social services as well as instruction.

The worst consequences of the proposed evaluation system are on new teachers just entering the profession.  They have four years to receive three “effective” ratings.  Anyone who has stood in front of a classroom remembers those first years of finding self-confidence and developing techniques as a teacher. Many first-year teachers leave the field entirely because of the stress associated with learning the profession.  To tie new teachers to a system that basically counts them out if they receive ineffectives on test growth scores during their first two years, is a plan that dooms many new teachers who may have developed their skills if given time and mentoring.  How would you even determine their growth score for the first year, when they did not have a class the prior year?   If a new teacher somehow miraculously gets effectives the first three years, and then has a rough class the fourth year and gets a developing - well as Assemblywoman Nolan said, they "get another bite at the apple" for a fifth year.  But if that is not effective, they are gone.  No recourse. All the years and expense to get a master's degree so they can put their passion for helping children into a teaching career?  ALL HOPE GONE! They will never teach in NY again. But they will still be saddled with school debt.

Who will want to go into teaching in our state?  Enrollment at teacher prep colleges is already down 20-50% in NY!  We need quality professionals to teach our children.  Who would really consider teaching children with identified disabilities, ELL’s, or teaching in high-poverty areas, when they know they would most likely lose their career after two years??

In Washington DC (where this whole debacle occurred years ago with Michelle Rhee) they dropped the weight of VAM/test scores from 50% to 35%.  Maybe that's because they lost 83% of their work force when they instituted an evaluation system similar to what Cuomo advocates.  Wisconsin has also given teachers more discretion in how student performance factors into their evaluations.  NJ has gone down to 10% weighted on the tests.   TN has also backed down from a reliance on VAM.

The plan for “drive-by evaluators” is also preposterous.  Who will be the evaluators?  Administrators cannot “trade schools” to spend hours evaluating professionals in other districts without putting their own school, their primary responsibility, at risk.  Paid evaluators?  Where will the money come from?  Will it be yet another unfunded mandate?  And who will do this – certainly not Pearson, who already hires the scoring of these all-important high-stakes tests out to anyone with a college degree via advertising on Craigslist and Kelly temps.  And certainly not our State Education Department, who has shown their lack of attention to detail and follow-through in performing important tasks (like vetting exam questions for grade appropriateness and managing the timely scoring of exams, for example). An evaluator cannot do a teacher observation justice without a deep, ongoing understanding of the school culture, population, and issues that affect the community.  

The tests themselves are designed for failure, calibrated to an SAT score of 1630, with “passing” cut scores adjusted after the tests are scored.  Literary analysis indicates that test reading passages and questions are often three grades beyond the age of the children.  “Equally plausible” answer choices (favored by the Pearson tests), require abstract thinking, a cognitive skill that usually does not develop until age 12.  70% of New York State children fail these tests.  I would like an answer to my question of how Pearson and New York State Education Department does not know the literacy level on these tests are years beyond the students' grade, and how they think it is at all fair that they are making a whole generation of students think they are failures.  The psychological and emotional effects of this are profound and will not be fully realized for years, but I am very fearful that we are in for a "statistically significant" rise in mood and personality disorders due to low self-esteem and chronic stress engendered by the tests.

Worse yet, studies show that high scores on tests correlate with superficial thinking skills.  In other words, the better a teacher does at encouraging deep critical thinking, the worse her students may fare on the exams (Alfie Kohn).  We are therefore looking at a system that will put our most qualified, master teachers at risk of losing their jobs.  Before my retirement, three colleagues that I considered master teachers (in-depth projects, critical thinking, heightened student motivation) were labeled “ineffective”  and had to create a teacher improvement plan. They did not understand how their high-functioning students did not show growth, and they could not get an answer from the district or from State Ed as to what formula was used to label them "ineffective" or "developing.". It was completely humiliating for these teachers, who had put more than a decade each into their development as master teachers.

An increase of any amount in the weight of standardized testing on teacher evaluations will most certainly lead to increased emphasis of tests in curriculum and lesson plans, with the children suffering with more test prep as important developmental thinking and "whole-child" instructional goals get put on hold.  No time for debates or projects.  No time for multimedia experiences or field trips.  No time for arts, humanities, music, service projects, character education.  The teachers will have no choice if their career and their livelihood depends on it.   

I am also quite certain that there are lawsuits in NYSED's future should they move forward with firing teachers based on these widely criticized, and poorly constructed, tests.  One entity that should be fired immediately, is Pearson because of their ineptitude, unless they were instructed by State Ed to deliberately make tests that are developmentally inappropriate, confusing, ridiculously long and age-inappropriate for students.

Parents have responded with an overwhelming protest, pulling their children from the tests in record numbers and responding to every survey that has been conducted that, No, they do not agree with increasing the weight of standardized tests in teacher evaluations.  Will you listen?  Or will you also be bullied by our governor, who has nothing but disdain for the students, parents, and teachers he is supposed to represent?