[The following letter was emailed from me to all members of the DC state board of education on December 28, 2021. It contains comments on the board’s efforts to revise the STAR rating and DC’s school accountability measures. The board is slated to vote on changes in January.]

Dear DC state board of education (SBOE),

As a DCPS parent, I wanted to provide you some of my thoughts on, and questions around, DC’s public school accountability system in light of the enormous effort SBOE has made to get public feedback around changing the STAR rating.

For instance, in 2021 SBOE held listening sessions on the STAR rating with invited witnesses and members of the public; promulgated four surveys to four different communities (parents, teachers, principals, experts); and sponsored public feedback meetings on the STAR rating. All of that has gone into an accountability and assessment committee report from 12/9/21 with recommendations for changes, which will be voted on soon by the entire board.

As we have seen repeatedly, the STAR rating closely tracks with the socioeconomics of student bodies. So while awareness of this harm is good, and a revision to the STAR rating on that basis alone is needed, I wanted you to be aware of some things I have observed thus far in this journey.

1. As a parent, I took the SBOE parent survey in October. The parent survey had 567 responses—which is not a small number, but is relatively small compared to the total number of parents in DC’s publicly funded schools. (Assuming 1.5 parents per student, that would be something over 135,000, of which 567 is about 0.4%. Assuming households, not individual parents, 567 represents about 0.6%.)

Moreover, half of the parent survey respondents were apparently White, and most sent their children to schools with either 4 or 5 stars.

In other words, responding parents were not really representative of DC public school parents as a whole. That is not to discount what they said—but merely to point out that the results are a snapshot of a small sliver of households/parents/families/members of the public.

2. On the SBOE parent survey, several of the questions were about school choice in relation to the STAR rating. On the one hand, this is understandable, as the STAR rating has figured prominently on the MySchoolDC website.

But the conflation of accountability and school ratings in general with school choice is as common as it is misleading.

Simply put, accountability in schools is not effectiveness, quality, “performance,” or choice.

Those are all different things—and it is unclear to me how the accountability committee and the entire board are proceeding to acknowledge that, if at all.

Consider: Is a high school more “effective” the more its kids attend college? finish college? apply to college? Can you have an “effective” high school if relatively few of its graduates go to a 4-year college, while some attend a 2-year college or technical school? (That last bit represents the high school I graduated from.)

And does a school have a better “performance” because more people attend it than another school? Or more apply to it? Or more accept seats at it?

And what does it mean for a school’s “performance” if all the kids are happy but don’t re-enroll in high percentages because their households are in flux?

Is a school whose student body has decent test scores but routinely lacks basic supplies or steady funding ever going to be “quality”? (That’s my kids’ main experience in DCPS.)

And how are the answers to any of those questions holding anyone or anything “accountable”? If so, what is being accounted for?

This is why conflating these terms is at best silly and at worst harmful.

Schools are a public good, like libraries, courts, and post offices. Either you want to have schools as a public good AND ensure they are working for the students who attend them OR you want to judge them for a purpose that isn’t related to any of that.

From my perspective, DC has ensured that “accountability” for our schools has long been and continues to be about the latter, not the former. This inaccuracy is reflected in the STAR rating itself, which is a judgement about schools best associated with the household incomes of their student bodies.

Instead, I want accountability to first focus on our schools as a public good—and then on how to support them to best serve the students they have, rather than to serve the tests that are used to judge, and even close, our schools on the basis of students most of our schools do NOT have.

That would mean a wholesale rethinking of accountability. It would mean ensuring that all neighborhoods have a reliable feeder system of municipally run schools of right that are equitably supported and resourced. It would mean ensuring that all students at those schools would be supported in their attendance at those schools (as opposed to penalizing schools with low in boundary participation rates). And it would mean not using aggregated numbers from one test at one point in time (or a single summative rating comprised of different factors), but focusing on what the schools’ actual students—not entire groups, but individual students—do.

Such accountability would have little to do with standardized tests and everything to do with how individual students grow over time, using assessments currently used by teachers and administrators to guide them through the school year. It could in fact span multiple schools at multiple times in one year—because our students are mobile.

For instance, you could have an outline of the percent of each grade at each school that was there in the prior year; the percent at each grade that has come at the beginning of this school year; and the percent expected to arrive mid-year, along with the schools those mid-year and new students came from—and how those new arrivals did at those earlier schools and how they might reasonably be expected to do at this one.

All of that means DC needs a real student tracking system. It also means that DC would have to account for student mobility in ways that it simply ignores right now, to the detriment of some of our most vulnerable students (though to the advantage of school operators that benefit from counseling out students after count day). And it also means that for once, teachers at every DC school would know *exactly* what their students had experienced before landing in their classrooms and thus would be better positioned to help them.

And possibly best of all, it means that the bankrupt pretense that one group of students at one point in time represents the entirety of educational experience at one school in an entire school year would finally be revealed for the lie that it is.

I would welcome that accountability. There is nothing here that is impossible for DC to do. 

So: How about it?

3. Point #11 on the 12/9/21 memo from the SBOE accountability and assessment committee attempts to outline how OSSE could support schools by delineating “inputs” and “outcomes.”

Specifically, “inputs are considered resources and conditions that may be beyond the control of the school (i.e. funding, staff position allocations, programs). Outcomes are the products of school resources and efforts (i.e. growth scores, graduation rates, school climate).”

The memo then goes on to outline 4 different scenarios (high inputs & outcomes; low inputs & outcomes; a mix of high/low of each) and OSSE’s potential response in supporting schools therein.

While I appreciate this outlining (a vast improvement over DC’s ESSA plan from 2017, which basically gave schools at most 4 years to show test score improvements, after which OSSE would take a range of unspecific actions, up to and including takeover by other operators), I urge you to see that it is inevitably flawed.

For instance, what of the “input” that is the presence of students transferring into a school mid-year?

If those students are doing work several grade levels below their actual grade, then one could assume that the best “output” would be to show growth—except that we are not currently showing growth for specific students but for entire schools, by aggregating test scores.

(Not to mention that we also aggregate test scores of tests of different degrees of difficulty, which to be fair does show something—but not about schools, students, or their teachers.)

Thus, even if those below-grade-level students show growth, that may not be sufficient to show up in the overall growth score for the school (assuming, of course, that we actually have a growth score for all our schools). Indeed, the test scores of those below-grade-level students might not be high enough to make the school’s overall score go up—and may actually lower it, thus leading one to erroneously conclude that the school is failing to help its students!

Whose accountability is that—and who and what is it serving?

Or take the “input” of lack of devices to take PARCC on, whether for practice or for the real deal. How do you measure the likely “outcome,” which is that students in schools that routinely lack enough computers for practice are less prepared for the exercise of taking PARCC than students at schools that have computers and staff to help with keyboarding, mouse skills, etc.? How does PARCC scoring (“outcome”) reflect that “input”? (Hint: It doesn’t because it can’t.)

Or take the “outcome” of graduation rates:

If LEAs are not accounting for the churn of students (which we know is legendary in DC), then what does a graduation rate really represent except one year or one set of students who are not necessarily the same as the set of students who began their high school careers at that school years before? And if that’s what you are measuring, how is that at all informative about what a school does over time with its students?

In case you think this little transformative exercise hasn’t happened in DC, rest assured it has and continues. It’s a great advertisement for a school “business”—but not so great as help for students over time or even understanding how students have been helped over time.

Even though it is really attractive to identify “inputs” and “outcomes,” I hope you can see it is neither easy nor even advisable. Worse, I worry that this exercise as outlined would be just a prettier version of the STAR rating: it looks objective, but is hardly that and ignores most of what happens in every school, to the detriment of every school.

4. All of this raises questions related to accountability in our schools that you may have mulled already—but answers to which I have yet to see articulated by any DC education leader:

–Can (and should) kids who do advanced work learn with kids who cannot do advanced work?

–If 70% of a school’s “performance” is based on standardized reading and math test scores, how likely is it that 70% of instructional time will relate specifically to what is on standardized reading and math tests?

–How has the closure of schools in DC advanced segregation in DC’s schools?

–How has the creation and expansion of the lottery and seats of choice, and consequent increased segregation, affected school ratings?

–Where in school accountability does DC account for all the terrible injustices committed by DC agencies with oversight of our schools (to name some in recent years: missing the Ballou graduation scandal, erroneously accusing Ellington students of residency fraud, not collecting out of state tuition, failing to enforce the Healthy Schools Act, allowing charter students to be placed with unregulated interim education providers, failing to act on lead in water, failing to act on lead in playgrounds, failing to fix HVAC before the return of in person learning, failing to institute legally required levels of asymptomatic covid testing, failing to follow the law regarding suspensions, failing to report on a charter school’s finances for a year (leading to its closure), and misreporting of PARCC scores)?

–“Is it really accountability to test students, and then not use the results to hold them individually accountable for those results? And then combine the results from all grades into one or two school-wide averages to evaluate teachers–but not just teachers of the tested students, but all faculty members ambiguously clustered into a single collective entity called the “the school”?” (This is a question asked years ago of a past SBOE rep, Mary Lord, by veteran teacher Erich Martel. As far as I know, he’s not gotten an answer.)

–Where in school accountability does DC account for test cheating? (Corollary: What assurance does the public have that in a heavily test-based accountability system there will be no cheating?)

–Where in school accountability is DC accounting for common stressors of this school year that affect schools and students’ academic performance: lack of meaningful traffic enforcement and management around schools; widespread covid; poor vaccination coverage among DC’s public school students; lack of reliable internet; lack of one-to-one device ratios for distance learning; lack of ability to pivot to virtual for everyone who needs it; lack of substitutes; stress on teachers?

–Can our accountability system accommodate the new reality that covid will likely be with us for a very long time, necessitating some period of virtual instruction for some or even all students every school year?

–Instead of a school rating system to promote accountability, will you consider an education agency rating system that would list all those transgressions of the public interest by education agencies in DC, their effects on our schools, and their resolution?

–Is the purpose of a school rating system to get parents to make better school choices—or to make better schools? (Corollary: Are those two things the same to you?)

–What constitutes a “good” school choice? (Corollary: If parents preferentially choose schools that are socioeconomically tilted to wealthier families, but have higher ratings, does that constitute a bad school choice or a wise decision?)

–As they institute their own school rating system with more “granularity” (as noted in one of your hearings), why isn’t the charter board interviewing personnel from schools that barely made (or failed to make) a designated cutoff in their current rating system, to find out what might have made a difference?

–Do you accept that all school ratings are inevitably arbitrary?

–Why do we still not have a student-based longitudinal data system, so individual students can be tracked over time and across LEAs with fulsome reporting about their academic strengths, weaknesses, courses, and grades? (In case there is any misunderstanding after the March 2021 auditor’s report that we have such a data system, please see what the auditor had to say in June about the nontracking of DC students.)

–Why do teachers not find out about PARCC test results in time to help students?

–Did you (will you) consider a school rating that does not involve PARCC at all, but relies on already used tests that are lower stakes for teachers and give incentives to students to do better?

–Will you recommend lowering reliance on PARCC scores from 70% to the lowest level allowed (55%) in DC’s ESSA plan?

–Can a school be very effective in teaching children even with a poor re-enrollment rate or without a wide range of electives?

–Why did all the examples of report cards in the parent survey use numbers to rate schools? (Corollary: How is this different than a series of summative ratings?)

–Have you ever considered non-numerical school ratings?

–Why do none of the examples of school ratings given in the parent survey account for churn of students?

–Why would you have a rating of schools for the purpose of accountability and not mention how much each LEA administrator is paid; what the district average is; and whether the LEA is above or below it; average teacher pay at each school; average teacher experience at each school; student turnover; teacher turnover; teacher, parent, and student satisfaction as determined by a survey done by people NOT at any of the LEAs/schools in question; how well the school has been funded over years, showing annual budget cuts/ups, staff layoffs, and reorganizations, along with the difference between what a school *said* it wanted and what it got in its budget; food quality as rated by students and outlined specifically in terms of offerings and % of fat and sugar; disaggregated square footage allotted for indoor and outdoor recreation, library, music, art; how many library books the school library has and their average age; whether there is a common area able to accommodate the entire student body; whether the school has an auditorium and its weekly uses (plays, study hall, detention, shelter in place, etc.); whether there is a librarian, art teacher, computer teacher, foreign language teachers, specials teachers and what percentage of the student body they teach weekly; how much time on average students are outside per week during school hours; what school supplies parents are asked to provide annually; the annual rate of teacher absences; training requirements for substitutes; the janitor/pupil ratio; the nurse/pupil ratio; how often school staff contracts per year with vermin control operators; and what percentage of instructional time each week is devoted to standardized testing and preparation for it?

–Why are there no ed specs for DC charter schools?

–Do you think the primary purpose of municipally run schools of right is to receive children disenrolled from other schools and to enroll children who didn’t get lucky on the lottery?

–Is a system of publicly funded, municipally run schools of right in every neighborhood important to you as a basic building block of democracy?

 –Is equitably resourcing a system of publicly funded, municipally run schools of right in every neighborhood of primary importance in your work as an education leader in DC—or is it just another issue?

–Do you believe that school choice is the same for everyone?

–Do you think that an LEA’s “choice of curriculum, teaching materials, mandatory pedagogies, student discipline rules and prohibitions” have nothing to do with student performance? (This was mentioned by veteran teacher Erich Martel years ago to one of your past colleagues.)

5. Finally, here is a plea to you from me, as a citizen and DC parent.

As you may recall from the run-up to the STAR rating system starting with the formulation of DC’s ESSA plan, lots of parents, teachers, and community members spent many months giving feedback to public servants on school ratings and “accountability.”

It was an interesting time. We went into meetings where the conclusions were pre-determined; where the choices for response were manipulated; and where accountability and school choice and test scores were constantly and harmfully conflated by the very people running those meetings and supposedly seeking our feedback. Despite many parents, teachers, and others testifying about, and documenting, the harms of a test-heavy rating system, we got one anyway.

Possibly all of that is because the people in charge have not seemed to understand or care about the idea of public schools as a public service and good.

We have had the chair of our council (and head of public education oversight) continually reference our schools as “businesses,” whose “products” are our children (see here and more recently the Ward 2 ed council meeting here at minute 4:35). The recent DCPS budget presentation featured an accountant (see at about minute 20) discussing its new student-based budgeting formula and how much money each school would “generate.” We had a private organization with monetary interest in privatizing our public schools engage in phone-banking to sway SBOE to approve a test-heavy rating, while many private organizations also weighed in on school accountability with OSSE without any public knowledge of what they said or wanted. We have had multiple chancellors, and multiple deputy mayors for education, annually cut our school budgets, threaten teachers and principals with test-dependent professional assessments, and hint at (or actually succeed in) closing schools based on test scores (which our ESSA plan outlines starting on p. 35). And we have a charter sector that has opposed public involvement in any aspect of school governance, whether with open meetings or FOIA, meeting notifications, school ratings biased against the majority of DC students, and school approvals, expansions, and locations at the behest and whim of operators and not the public at large, while referencing all of that tilted playing field (wherein taxpayers pay for all of this they have no say in) as a “marketplace” in which “competition” will determine winners. (Not mentioned, of course, are the losers—which are actually all of us DC residents as schools & staff are threatened and schools closed.)

For every single one of those things, DC’s ed leaders have said that it’s a result of what the public wants or needs.

Yet the public has been as a practice sidelined in all of those actions and decision making, even while the public itself pushed back again and again, whether with school closures (the latest: Wash Met), school locations (one of the latest: DC Prep), school expansions and creations without public input or demonstrated need, rampant teacher and principal firings (here, one of the latest protests), secretive meetings and lack of FOIA, and budget cuts (here for just one protest). And the public also pushed back against a test-heavy school rating system.

None of this is news.

None of this should surprise any of you.

And it is all deeply disturbing.

Consider that we don’t talk about the ability of our libraries to “generate” their own funding—nor do we discuss the “products” of our courts or post offices as evidence of their success or as “accountability.”

Nor do we presume that if any of those public institutions does have a “product,” that “product” is an actual, living human being.

Yet we do all that with our schools—and with our children.

Who asked for that?

I can assure you that utterly no parent or teacher I have ever had any acquaintance with in my 16 years as a DCPS parent has ever once asked for ANY of it. Not for “competition.” Not for a “marketplace.” Not for our schools to be “businesses” and not for our children to be “products.”

So, while I am gratified that SBOE is considering different ways of assessing our schools after years of harm of the STAR rating and test-based “accountability” scams, here’s my plea to you:

I need to know that you will help ensure that none of the stuff I have outlined above—the terrible injustices, mistakes, and presumption of our schools as anything other than vital public institutions–happens again.

The people who have wanted test-based accountability the most are not the people I see sending their kids to our publicly funded schools.

In fact, none of the people I have seen who have enabled and enacted test-based accountability here in DC appear to even believe in the idea of our public schools as a public good, like libraries, courts, & post offices. Rather, they appear invested in our schools as businesses they can profit from in some manner, with our children (and their minds) as the “products”—while we parents and taxpayers pay for those privatized desires that we have almost no say in, even as we are subjected to propaganda and misinformation about it at every step of the way.

I hope you can see how anti-democratic this is.

And I hope you can accept that my children—and 90,000 others right now in our publicly funded schools–are not anyone’s products.

I also hope that you can accept that our schools are not businesses, but public goods and thus need to be cherished and supported as the vital PUBLIC services they are—not judged or otherwise treated as if they’re interchangeable widgets that must “generate” funds or otherwise earn their keep on the basis of (literal!) scorekeeping.

Please: do better this time. Thank you.