The practitioners have spoken. Now the question is: Will the Regents listen?
The Regents Board met April 4 to hear recommendations from members of the Regents Task Force on Teacher and Principal Effectiveness and ask questions about how best to implement a new evaluation system for teachers and principals.
Just days later, the State Education Department issued draft regulations that incorporate many of the task force recommendations — but there are several areas where different points of view are advanced.
For example, while the task force members believe strongly that locally-selected evaluation measures should not include standardized tests, the draft regulations would allow districts the flexibility to base locally-selected measures on standardized tests.
SED is asking for public comment on the regulations by April 29, leaving only a two-week window during a time when many schools are on spring break. NYSUT is asking SED to extend the comment period to give practitioners more time to respond.
"It's critical to get this right," said NYSUT Vice President Maria Neira.
The state law, which requires school districts to start phasing in the new evaluation system this fall, calls for the Regents to finalize regulations by July 1. But a 113-page report by the Regents Task Force on Teacher and Principal Effectiveness, a 63-member group including teachers, principals, superintendents, school board members and others, casts serious doubt about whether school districts can pull it off that quickly.
"The Regents (Board) must take into account the cost implications to districts as it considers this new policy," the report states. "Districts will need time to build capacity to sustain these changes."
The report notes there are numerous unanswered questions and that members have concerns about getting everything in place in the initial year, due to the complexities and decisions involved at the state and local levels, and the potential cost.
"If the state develops assessments for non-tested subject areas, the number of new assessments that would be needed may be staggering and require a phase-in schedule," the report said. Educators have to be careful not to "over test" or attach too much weight to a single standardized test, the report cautioned.
The current plan calls for the new evaluation system to take effect in September for about 15 percent of teachers — including grade 4-8 ELA and math teachers, along with their principals.
"It's crucial for the Regents to seriously consider the task force's findings," said Neira, who served on the advisory panel. "We're stressing the importance of a comprehensive system that is designed to foster a collaborative culture and continued professional growth. ... If done right, this will be a win/win for our profession and our students."
Teacher representatives on the task force played a key role in the presentations to the Regents, voicing the need for transparency, fairness, flexibility and local decision-making. Teachers also emphasized the importance of ongoing professional development and training of evaluators.
"Teacher evaluation should not be a gotcha system," said Amsterdam teacher Stacey Caruso-Sharpe, a task force member and NYSUT board member. "The ultimate goal should be to improve teaching and learning ... with multiple measures and local determination. What's good for a big city school might not work in a small district."
"That's why this needs to be a rubric of choices, not a checklist," said Michael Mendel of the United Federation of Teachers, noting there needs to be flexibility for collective bargaining provisions.
Plattsburgh teacher Karen Rock, another task force member, made the case to limit standardized test results to 20 percent and to allow teacher-created authentic assessments to be used in the "other locally selected" category. Using standardized tests twice would go beyond the intent of the law, she said, making state exams worth 40 percent of an evaluation. She noted five labor-management school district teams in NYSUT's Innovation Initiative are piloting a new evaluation system that will include multiple measures to assess student achievement.
The union continues to work with SED to resolve challenging issues such as statewide scoring bands and how much weight observations should carry. "There needs to be more thoughtful deliberation," Neira said. "It's crucial to anchor the system with observation, but it's also extremely important to make sure other measures are built into the system."