Last week, the U.S. Department of Education notified Kansas, Oregon, and Washington that their ESEA waivers were on “high-risk status” due to the states’ inability to implement required teacher evaluation systems in a timely manner. In some regards, this was welcomed news. After all, it’s encouraging to see the Department show some willingness to actually enforce the commitments states made to improve the education of historically disadvantaged students in exchange for waivers. (That’s something we are still not seeing a whole lot of under Race to the Top.)
On the other hand, this action illustrates some of the shortcomings of the Department’s waiver program overall. For starters, this announcement came almost entirely out of nowhere and only spoke to three of the 35 Window 1 and 2 states (i.e., the states for which waivers were granted prior to 2012-13 school year). In addition, teacher evaluation was the only basis made for “waiver jeopardy.” That indicates that either every state’s implementation of its accountability and school intervention plans is going A-OK, or we will learn something different at some point in the future. Right now, only USDOE knows for sure what’s happening with implementation.
While the Department did release state-by-state reports (apparently in April of 2013) after “Part A monitoring” (completed in November 2012) there were no indications that the teacher evaluation issue might be a problem for the three states now at “high-risk status.” That’s because Part A monitoring didn’t closely examine the status of teacher evaluation system implementation. The issues raised during Part A monitoring, however, and upon which states committed to “next steps,” apparently played no role in driving USDOE’s “high-risk” status warnings. Many of these issues, such as interventions in priority and focus schools for the 2013-14 school year, are arguably of more immediate importance.
Worse, the next round of monitoring—aka “Part B”—might not show these problems either. That’s because Part B monitoring is designed to be something of a white elephant gift exchange. Under this second phase—scheduled to be completed some time this fall—states and feds each get to pick a few points of inspection, while all other aspects of a state’s waiver plan go unchecked. For example, one state could choose for the Department to review its progress toward the transition to new standards, while the feds select to inspect that state’s “Priority” schools and other Title I schools, leaving four other aspects of a state’s plan uninspected. Under such a scenario, it’s entirely possible that one or more elements of the waiver plans will be reviewed by USDOE in only a handful of states, if any at all.
Even now, we only have information about state progress on teacher evaluation systems. Are we to assume every state is executing perfectly or even satisfactorily its promises on the identification of priority and focus schools and the types of interventions that are to be implemented to turn them around, many of which were supposed to be in place before the beginning of this school year? It’d be nice to know, especially since the 2013-14 school year in many places, including Kansas City, Kansas, has already begun.
No one—not the states, not teachers, and certainly not students—benefits from the extreme uncertainty brought on by the opaque, spotty, and incoherent monitoring of state waiver implementation that the USDOE has conducted thus far. In a recent anonymous survey of education “insiders” conducted by White Board Advisors, one respondent said: “At this point, the Department is just making things up as they go along. It’s impossible to discern a coherent strategy. [Race to the Top] for states, for districts; waivers for states, for districts. They are leaving federal education policy a complete shambles.” Things may or may not be quite that bad, but the USDOE is offering little, either through word or action, in the way of a substantive counter-argument.
Domenic Giandomenico joined Democrats for Education Reform in 2013 after devoting more than a decade of his career to ensuring that every student of every age, background, and aspiration has access to the excellent education they deserve.