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Why Common Core Is No ' *<*_ r.^ pE©a¥ED / NOV 9 1 0()<i Independent Regulatory Review Commission / " CUIJ November 21,2013 / INDEPENDENT RcGIil AT„ Consideration of final-form regulation #6-326 (IRRC #2976) Chapter 4 (Academic Standards and Assessment) Good morning Chairman Lutkewitte and fellow Commissioners. My name is Lee Williams, and I serve as Chair of the State Board of Educations Committee on Academic Standards and Chapter 4. I'm pleased to be with you this morning to discuss the final-form revisions to Chapter 4 that have been the subject of much debate and deliberation. I'd like to begin by providing a sense of history related to the key issues addressed in this regulatory package, and then will discuss the process undertaken by the Board that has led us here today. In 2006, concerns were brought to the Board's attention that many students were graduating from high school without adequate preparation for entering the workforce or college. This was evidenced by data that showed more than 40% of Pennsylvania's high school graduates - representing more than 50,000 students each year - were being awarded diplomas without demonstrating proficiency on the state's reading, writing and math tests. Additional data showed that fewer than half of our high school graduates enrolled in college upon graduation, only 37% persisted to their sophomore year, and just one-third graduated from college on time. Further, a February 2009 survey of our state's 14 community colleges and 14 state-owned universities found that 62,000 students at the schools were enrolled in remedial coursework at a cost exceeding $26 million annually. This startling data led the Board to engage stakeholders in conversation about high school reform efforts that would restore value to diplomas issued in the Commonwealth. That conversation culminated in changes to Chapter 4 that took effect in 2010. The revisions to Chapter 4 adopted at that time established a series of end-of- course Keystone Exams in 10 content areas, and required Keystones to count as at least one-third of a student's final course grade. The reforms adopted by the Board in 2010 also established alternate paths to proficiency through a local assessment option and project-based assessments; put in law a requirement that students who were not proficient be offered supplemental instruction; and created supports for school districts through voluntary model curriculum and diagnostic assessments. Let me be clear - provisions establishing Keystone Exams, establishing requirements for supplemental instruction, and establishing requirements for alternate project-based assessments were reviewed by the Independent Regulatory Review Commission and the House and Senate Education Committees prior to their enactment in 2010, and do not represent new requirements ofthe rulemaking currently before you. The formative steps for the current revisions to Chapter 4 moved on two tracks. First, the Board's Committee on Chapter 4 oversaw the review of amendments to the procedures and requirements in the Chapter related to Keystone Exams. This work included multiple opportunities for public input. In winter 2012, the Committee held public hearings to solicit input on draft revisions relating to Keystone Exams. Hearings were held at the Montgomery County Intermediate Unit and Department of Education in Harrisburg. A third hearing was scheduled to be held in Pittsburgh, however, that event was cancelled because no one registered to provide comment to the Committee. In advance ofthe hearings, draft revisions to Chapter 4 were posted on the Board's website for public review. In addition to providing an opportunity to testify before the Committee, the Board also invited individuals to submit written testimony Comments received during this initial drafting process resulted in changes being made to the proposal before it was adopted by the Board as a proposed rulemaking. Subsequent to its adoption of a proposed rulemaking, the Board invited public comment on the regulation and received written comments from 146 individuals and organizations during the 30-day comment period. These comments were taken into consideration and, again, resulted in changes being made to the proposal before the Board adopted a final rulemaking. The second formative track for the current regulatory changes addressed the state's academic standards in English and math. Further study by the Pennsylvania Department of Education concluded that Pennsylvania students would be better served by creating a unique set of state-specific standards in English Language Arts and Mathematics guided by the Common Core and the needs ofthe Commonwealth. Before I discuss the process the Board undertook related to the second formative track, I'd like to give you a sense of perspective related to the Board's lengthy deliberations on state academic standards. State academic standards in Math and English were established in 1999. At that same time, the Board made a commitment to conduct periodic reviews of its academic standards to determine if the standards remained appropriate, clear, specific and challenging. Standards in 12 different content areas were developed between 1999 and 2006 and, upon completion ofthe last set of standards, the Board announced its intention to conduct a periodic review of the first two sets of standards adopted - Math and English. This standards' review commenced in 2007 and marked the first review ofthe state's Math and English standards in almost a decade. The Board engaged teams of Pennsylvania educators to consolidate, clarify and update the standards. Public hearings on the draft revised standards were announced in July 2008, and the draft revisions were posted for public review on the Board's website. Following this opportunity for public comment, in September 2008, the Board approved revisions to the state's Math and English standards as a proposed regulation and prepared the standards to undergo regulatory review. As the Board was preparing to submit its revised academic standards for additional public review, the creation of a collaborative set of academic standards in English and Math - later known as the Common Core State Standards - emerged as a policy goal ofthe National Governors' Association, the Council of Chief State School Officers and more than 45 states and territories. In September 2009, the Board elected to withdraw its independent standards revisions to explore whether Common Core was a sound alternative. To make an informed decision, the Board engaged the University of Pittsburgh to conduct a standards alignment study. The Pitt study found that Common Core was highly correlated with the independent Math and English standards revisions the Board had begun pursuing back in 2007. Given the high degree of alignment, in 2010, the Board advanced a revision to Chapter 4 to adopt the Common Core Standards as the state's academic standards in English and Math and to provide schools with a three-year phase-in period for the new standards. Four public meetings were held across the state to present the Pitt alignment study and gather public feedback. The Board also appeared before the Senate Education Committee to discuss the standards and posted copies ofthe standards on its website for public review and comment. The standards ultimately were reviewed and approved by the Independent Regulatory Review Commission in August of 2010. Following their adoption, the Board continued to engage stakeholders by hosting four roundtables to solicit input on implementation of the new standards. As we continued to work through implementation of these first-ever revisions to state academic standards, further study by the Pennsylvania Department of Education concluded that Pennsylvania students would be better served by creating a unique set of state-specific standards in English Language Arts and Mathematics guided by the Common Core and the needs ofthe Commonwealth. The Department convened teams of Pennsylvania educators to personalize the standards to meet the needs ofthe Commonwealth, and made a public presentation of draft revisions to the standards in March of 2012. The standards revisions were incorporated into broader revisions to Chapter 4 approved by the Board as a proposed regulation in May of 2012, and then offered for public comment. Final-form revisions to Chapter 4 addressing three key areas - strategic planning, high school graduation requirements, and academic standards - were approved by the State Board in March of 2013 and transmitted to the Governor's Office for review. Due to the amount of misinformation and concerns raised by the public, Governor Corbett asked the State Board to review the regulations to ensure they were in the best interest of Pennsylvania students. The Pennsylvania House of Representatives also adopted House Resolution 338, which asked the Board to consider whether revisions to Chapter 4 were necessary to address the concerns being expressed. In June of 2013, the Board withdrew its final Chapter 4 regulation to discuss the concerns expressed in House Resolution 338. Extensive opportunities for public comment were offered at the Board's public meetings in both July and September, and the Board appeared at three hearings before the House and Senate Education Committees to further discuss issues related to Chapter 4. As a result of this additional time for public debate, in September 2013, the Board adopted additional changes to Chapter 4 to address concerns related to local control, national assessments and data collection. These changes make it clear that the state's academic standards do not apply to private, religious or home education students; preclude the Department from mandating a statewide curriculum or statewide reading lists; preclude the Department from using national assessments for students without lEPs; and preclude the Department from expanding its collection of student or personal family data due to the Pennsylvania Core Standards. Additional revisions were made to place decisions about graduation waivers with local school administrators and to remove information on student transcripts related to project-based assessments that raised objections from a state lawmaker.
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