In public comments submitted today on the proposed Commissioner’s Rules implementing a new teacher appraisal system in Texas, ATPE encouraged newly appointed Commissioner of Education Mike Morath to delay implementation of the rules in order to address several concerns. ATPE expressed particular concern with provisions pushed by the Obama administration in exchange for Texas’s waiver from the burdensome and outdated policies under No Child Left Behind (NCLB), including compelling school districts to use standardized test scores as a measure of evaluating teachers on student growth.
ATPE highlights prominent research that questions the reliance on student standardized test scores (or the use of value-added modeling or VAM) as a measure of student growth and encourages the Texas Education Agency to omit the unproven measure. Such research questions the reliability of VAM for high-stakes decisions affecting educator appraisals, compensation, employment, and preparation program accountability. ATPE’s comments note research published by the American Statistical Association, which issues the following warnings:
- “limitations are particularly relevant if VAMs are used for high-stakes purposes,”
- “ranking teachers by their VAM scores can have unintended consequences that reduce quality,”
- aside from test scores, VAMs “do not directly measure potential teacher contributions toward other student outcomes,”
- “VAM scores and rankings can change substantially when a different model or test is used,” and
- “effects – positive or negative – attributed to a teacher may actually be caused by other factors that are not captured in the model.”
In addition to citing research warning against the use of VAM, ATPE’s comments address several issues that make the use of VAM impractical, unnecessary, and harmful. Among them is the fact that only about 30 percent of Texas teachers will be evaluated on their students’ test scores since VAM can only measure teachers who teach subjects where a STAAR test is administered. “The potential harm created by this bifurcated system, where teachers of certain tested subjects would be isolated from the majority of their peers, is tremendous and will only serve to alienate teachers in tested subjects or discourage teachers from teaching those subjects.”
As we reported last week, today is the last day to submit comments on the proposed rules, which could be adopted as early as today and after adoption would go into effect on July 1. Among the comments submitted to the Commissioner is a letter authored by six ATPE members who served on two T-TESS steering committees that TEA convened to gather input on the development of the new teacher standards, evaluation system model, and proposed rules. The educators’ letter states: “We ask you to delay implementation in order to reconsider inclusion of value-added data as a means to measure student growth. We are proud that the inappropriate use of standardized tests in the public education system has been recognized and change is underway. Please help us continue that effort for the betterment of the 5 million school children across Texas.”
The group’s letter explains that they understood that the inclusion of VAM was a requirement of the waiver Texas had received from the Department of Education in exchange for needed flexibility under No Child Left Behind (NCLB). “At that time, we were willing to accept that our hands were tied and this was not a topic of debate.” However, the group notes, Texas was freed from waiver requirements last month when Congress passed and President Obama signed into law a new federal education law. Passage of the law negates the need for a waiver and returns the decision making on teacher evaluations to Texas and its local school districts. In light of that development, the group encourages Commissioner Morath “to eliminate the inclusion of value-added data or student standardized assessment results as a means for measuring student growth under T-TESS.”
Both ATPE and members of the steering committees encouraged Commissioner Morath to delay implementation in order to address the piece allowing the use of value-added data, or state standardized test scores, as a measure of a teacher’s performance. Read ATPE’s full comments and the letter from members of the steering committees to learn more.