Call for a Moratorium on New York State's APPR Regulations.

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Dear Regent Collins, Senator Flanagan, Senator Marcellino, Commissioner Elia & Assemblywoman Catherine Nolan

The Legislative Team of the Erie County Association of School Boards has had its first meeting of the 2015-16 school year, and by unanimous vote declared its first action of business to be the writing of this letter urging the Board of Regents at your Sept. 16-17 meeting to call for a moratorium of at least one year before permanent implementation of the new APPR evaluation regulations.

The concerns are:

The unreasonable deadlines being imposed upon school districts, particularly given the fact that guidance on the new guidelines was released only a couple of weeks ago, with additional needed detail still not provided.

The lack of staffing at the State Education Department to review the plans, even if they were all submitted by the Nov. 1 deadline.

The declaration that while waivers are available, not all will be granted – despite the fact that this puts millions of dollars of critically-needed state aid at risk.

The regulations themselves, which appear to defy all research-based evidence and best practices of evaluation.  It is our understanding that despite numerous inquiries, the State Department of Education has not released any citations of supportive evidence.

While research says student performance measures should not be used as an exclusive method for teacher evaluation, the current matrix, and its recommended scoring ranges, forces the evaluation into precisely that outcome. In other words, it is a matrix designed to drive failure, not guidance for improved performance.

The validity and reliability of the calculation of teacher and student growth scores is so compromised that a lawsuit has been brought.

The sheer volume of opt outs from last spring’s assessments and the widely acknowledged failure of the Common Core Standards’ rollout and implementation would logically invalidate  use thereof for teacher evaluation.

Given that without the regulations in place, there will be no mechanism for granting waivers, and the consequent loss of state aid, we implore the Board of Regents to urge lawmakers to return for an emergency session to enact a moratorium without negative repercussions for school districts.

Teacher evaluation and student assessment are vital tools for improved performance and achievement, and are too important to leave to these compromised and highly questionable new regulations.  We urge you to call upon legislators to enact a moratorium allowing the education community the time and opportunity to ensure that what we do is done correctly and meaningfully for improvement of both teacher and student performance in the years ahead.

Today: Erie County Association of School Boards is counting on you

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