State Approves Changes to Educator Evaluation Regulations Over Objections from Teachers

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The Board of Elementary and Secondary Education (BESE) voted 9 to 1 at its Feb. 28 meeting to approve Commissioner Mitchell Chester’s recommendations to amend the educator evaluation regulations, despite objections to a core component of the changes from AFT Massachusetts and the Massachusetts Teachers Association (MTA).

In a positive step, the amended regulations eliminate the long-criticized requirement that districts issue a separate “impact on student learning” rating of low, moderate, or high to all educators based on so-called district-determined measures (DDMs) and other measures of student learning such as MCAS scores. Furthermore, districts will no longer be required to create at least two DDMs in every grade and subject, nor will they be required to report any additional ratings to the Department of Elementary and Secondary Education (DESE) beyond the summative ratings of exemplary, proficient, needs improvement, or unsatisfactory.

The troubling news is that the amended regulations replace the separate impact rating with a new Student Learning Indicator under Standard 2 of the Teacher Evaluation Rubric. The new indicator will be one of five indicators that can inform a rating on that standard. A teacher has always needed a proficient or better rating on Standard 2 to receive a proficient or better rating overall, and the amended regulations maintain that rule.

The new Student Learning Indicator will assess whether a teacher demonstrates “expected impact on student learning based on multiple measures of student learning, growth, and achievement,” including “common assessments and, where available, statewide student growth measures.” Evaluators will exercise their “professional judgment” to determine whether the educator is having expected impact, comparing “anticipated student learning gains” to actual gains. In a nod to the complexity of teaching and learning, the amended regulations say that an “evaluator’s professional judgment may include…consideration of the educator’s student population and specific learning context.”


Problems Continue Under New Framework

The new policy framework poses several problems, says a joint letter from AFT MA and the MTA that was submitted to the commissioner and Board members shortly before the Board’s vote. “Placing a Student Learning Indicator under Standard 2…elevates the stakes around student test outcomes and hinders the ability of evaluators and educators to have authentic, educationally valuable conversations about student learning,” the letter states, adding that “the regulations compromise the very activity they purport to encourage.”

The amended regulations also “create the same hurdles that have made the Student Impact Rating impossible to implement,” the letter continues. “Determining an ‘expected impact’ for each educator—including developing methodologies to measure impact in a valid, reliable, and fair manner—persists as a significant issue that has proven impossible to resolve. The final proposed regulations simply replicate the flaws inherent in the current system, and it is likely that the same implementation problems will ensue.”

Given these significant problems, it is unclear how and when the new system will be implemented. Commissioner Chester issued a memo on March 10 to delineate some of the next steps, saying that “the Department will provide guidance for evaluators on using the new student learning indicator to provide meaningful feedback to educators about their impact on student learning.” Meanwhile, AFT MA maintains that any use of the new Student Learning Indicator to make judgments about teachers must first be negotiated between the district and local union.

“Like nearly all educators across the state—including superintendents, administrators, and teachers—we are pleased that the separate student impact rating has been eliminated,” says Dan Murphy, AFT MA’s director of educational policy and programs. “However, we are disappointed that the Department chose to disregard the thoughtful alternatives that were put forward by AFT Massachusetts and the MTA, organizations representing more than 100,000 teachers statewide. The result is a policy that poses a whole new set of questions and challenges. As always, AFT Massachusetts stands ready to assist our local leaders and members.”


Amended Regulations Follow Year of Intense Debate

The final amendments cap off a full year of intense policy debate and discussion over the role of student learning in teacher evaluations.

Commissioner Mitchell Chester faced strong pressure from AFT MA, the MTA, the state superintendents’ association and other stakeholder groups to eliminate the separate impact rating. AFT MA and the MTA issued a joint white paper on this topic in April 2016 and gave joint testimony to BESE in June 2016.

Commissioner Chester responded by proposing revised regulations in November 2016. While the proposed revisions eliminated the separate impact rating, they included the new Student Learning Indicator, a provision that AFT MA and the MTA strongly opposed in formal comments to the Department.

While Chester did agree to some further modifications in the final version of regulations approved by the Board, the problematic Student Learning Indicator remained, making it impossible for AFT MA and the MTA to endorse the changes. Only one member of the Board, Dr. Ed Doherty, heeded the unions’ recommendation to vote against the proposed revisions.

The final amended regulations, including both red-lined and clean versions, can be found on the Department’s website here.