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Dr. Ryan Schoenfeld, Vice-President and Political Liaison for the Empire State Supervisors and Administrators Association (ESSAA), submitted the following position paper to the U.S. Department of Education outlining our concerns about the Every Student Succeeds Act (ESSA) based upon a recent survey of our members.


November 7, 2016

Mr. James Butler

U.S. Department of Education

400 Maryland Avenue SW., Room 3W246

Washington, DC 20202

Dear Mr. Butler:

This letter is being submitted on behalf of the Empire State Supervisors and Administrators Association (ESSAA).  ESSAA is the second largest administrative union in New York State with over 3,500 members, who dedicatedly serve learning communities throughout our diverse state.

This position paper is being offered to share practitioners concerns from the field on the United States Department of Education’s Notice of Proposed Rulemaking on Title-I – Improving the Academic Achievement of the Disadvantaged – Supplement Not Supplant under the Elementary and Secondary Education Act, as amended by the Every Student Succeeds Act (ESSA).

Firstly, our unit has been meeting monthly with our commissioner over the past four years.  Most recently we have been pleased with Commissioner Elia’s inclusive and transparent approach.  Her letter submittal to you has great specificity and detail, which resonates with our group.  We concur with her statement that the provisions of the Title I Supplement Not Supplant draft rulemaking goes well beyond the law’s regulations.  Moreover, the conditions set forth certainly places local educational agencies in an awkward position once again.  We foresee the need to navigate through restrictive red tape, additional paperwork, wasted time, rather than prioritizing on programming based on local needs.

We recognize the desire to reauthorize the Every Student Succeeds Act (ESSA) in an effort to assure equity and access for our students.  We commend you on your commitment to our students.  Over the past four years our group has been at the forefront of implementing Common Core accountability measures with limited funding, adjustments, and tireless efforts to be rewarded with unintended consequences that will take years to recuperate.  We have over 20% of parents excluded or refusing to take NYS grade 3-8 state assessments in ELA and Math.  The data has been unreliable, invalid and useless in improving instruction.  This has built up a lack of trust with the state education department and in our federal government.

In preparation for the submittal of a position paper a survey was administered to our ESSAA members.  Open-ended questions were the most insightful, harvesting strong positions.  Three areas which were prevalent amongst respondents were 1) the concern of unfunded mandates – requiring local districts to follow through on actions without properly financing the expectation 2) unintended consequences – outcomes that veer from the desired outcome and cause harm 3) implementation schedules that do not allow for local educational agencies to properly plan, restructure, train, and implement.  4) Local education agencies must be given back local control – ESSA has some good aspects, however it takes away local control.

A colleague submitted their view that “Politicians must remove themselves from the plan”.  That is not entirely true, politicians must recognize that educators are the professionals who know their students and communities best.  Local control is where decision-making must occur to restore faith in our educational system and meet the needs of our students, who require different things based on their unique needs.  More regulation is not going to help close the achievement gap.  The State, more importantly each district must look closer at the core issues their students and community is facing and respond accordingly.

One of our practitioners, Dr. Kevin McCahill shares that lower standardized test results and poverty have been highly correlated through multiple studies.  Let us build a system of measurement that acknowledges this aspect and seeks to discover if another form of assessment is better suited for ALL children in the state of New York.

There is way too much intervention, oversight, and money spent on bureaucracy than on education.  Please heed the heartfelt and thoughtful recommendations from the professionals in the field who are well educated, experienced, and do the important work in the best interest of OUR children.  In closing I would like to reiterate the four areas of concern that we implore you to address: 1) unfunded mandates 2) unintended consequences, and 3) appropriate implementation schedules that are mindful, and 4) give back our local control

Thank you for your time, attention, and consideration.  We welcome you to contact the Empire State Supervisors and Administrators Association (ESSAA) to further discuss the contents of this letter, or anything else. (716) 432-5106

Respectfully submitted,

Dr. Ryan Schoenfeld

ESSAA Vice-President & Political Liaison.

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