Feedback For School Ratings And Accountability (And Seeing DC’s Plan In A New Light)

[Ed. Note: On March 7, DC’s office of the state superintendent of education (OSSE) submitted to the federal department of education an addendum to its state plan for accountability for DC’s publicly funded schools. In its cover letter, OSSE mentioned receiving public feedback. But that feedback was limited to four entities: a charter advocacy organization; a local ed research firm that gets part of its funding from OSSE; the state board of education, which advises OSSE; and a letter from a private citizen. The feedback was generally not critical of OSSE efforts to slightly revise DC’s school accountability plan in light of the pandemic.

But that private citizen, Jeff Schmidt (author of Disciplined Minds), was very critical. Addressed to the federal secretary of education as a letter, Schmidt’s feedback on DC’s school accountability plan (reprinted below with his permission) calls out OSSE for not collecting public feedback more robustly—and for setting low goals.

His criticism comes at an opportune time. In January, the state board called on OSSE to revise DC’s school report cards, to de-emphasize test scores and eliminate the STAR rating (which others have provided ample rationale for.) This month, OSSE is holding feedback sessions on changes to its school accountability plan, with a further adjustment set to be submitted this summer. Be sure to attend and let OSSE know your thoughts on measuring the work of our schools and student growth.

(NB: As of this blog post, I was unable to find this information on OSSE’s accountability website here. For more information about these sessions, or any updates, contact Donna Johnson (who provided this information to me) or other personnel under “data and reporting” at this website.)

Ward education council meetings:

Wednesday April 13 5:30 pm

Thursday April 21 10:30 am

Wednesday April 27 5:30 pm

Parent sessions:

Tuesday April 19 6 pm

Monday April 25 6 pm

Education advocacy organizations sessions:

Thursday April 14 1 pm

Thursday April 21 6 pm

And read on for a view that calls into question many assumptions behind school accountability (with possibly the most insidious being the politically convenient conflation of individual student performance, accountability, and school ratings.]

By Jeff Schmidt

1 March 2022

United States Secretary of Education Miguel Cardona

Dear Mr. Cardona:

Will the Biden administration allow District of Columbia public schools to have lower academic achievement goals for Black and Latino children than for White children until the year 2041? DC officials are asking you to approve a plan to do that. (The draft plan is posted here; academic achievement goals are here.)

Two generations of students would be victims of the unequal academic expectations: the 93,000 children now in DC public schools and, over the next two decades, a comparable number of children, most of whom haven’t even been born yet.

You cannot in good conscience endorse this plan.


DC’s current education plan is already one of the least ambitious in the country, as it allows schools to have lower academic proficiency goals for minority students than for White students until 2039. The federal government should not have approved it in 2017.

But now, using the covid pandemic as an excuse, DC seeks your permission to move the day of racial equity in academic goals from 2039 to 2041. Thus, instead of committing itself to getting back on track over a period of 5, 10, or even 15 years, and closing the racial proficiency gap by 2039, DC is again taking the least ambitious path and simply declaring the past two years a total loss in terms of academic gain. (See, for example, the high school math goals here.)

This is not to imply that DC’s 2039 equity plan was ever acceptable. Saying that schools will practice racial equity in academic expectations in 2039 amounts to saying “never,” and everyone knows that. When DC education officials chose 2039 as their target date, they knew that education frameworks don’t last that long. The “No Child Left Behind Act” lasted about 14 years before Congress scrapped it and replaced it with the “Every Student Succeeds Act,” under which DC’s 2039 plan exists.

As you know, the federal ESSA law says that academic goals must be “ambitious.” Yet the plan that DC is asking you to endorse only requires schools to teach 31% of today’s black 7th graders to do math at grade level by the time they are tested in high school 3 years from now.

However, according to DC’s plan, schools had better pay close attention to their White students, for administrators will be in trouble unless White students are proficient at almost double that rate (61%).

Such a system deprives minority children of their right to be treated and judged as individuals. A school with unequal academic goals tells a Black student, in essence, “We don’t expect as much from you, because many other Black students have performed poorly.” Would you explain the plan’s prejudgment to a Black child any differently? DC officials offer no explanation whatsoever, as you can see in their request. The closest they come is using the phrase “historically underperforming student groups” in a different context (see here, p. 16).

DC’s mayor, deputy mayor for education, superintendent of education, and board of education have decided in advance that tens of thousands of Black and Latino children who are yet to be born will enter the classroom with a badge of inferiority–their minority status. No matter how hard a minority child works, her public school will see her as being in a low-expectation group until 2041 and that will undermine her education. Countless education studies and experiments have confirmed the obvious fact that expectation affects outcome.

Alternative to academic racial profiling

If DC really wants to eliminate the racial achievement gap, then it must not engage in academic racial profiling, which undermines the necessary teacher expectations and student morale.

The Every Student Succeeds Act does not require schools to set lower academic proficiency goals for minority children than for White children. If DC wants to set different proficiency goals for different students, then it should do so according to each student’s proficiency, which DC measures every year, not automatically according to the student’s race. It is arguably reasonable to have a lower end-of-year proficiency expectation for a student who begins the year with extremely low proficiency–but not simply because the student is Black.

DC should shift to adaptive testing to pinpoint each student’s proficiency as a grade level, such as “grade 4.6 in math” or “grade 9.2 in English.”

DC could easily come up with an education plan that is free of racial prejudgment, simply by replacing grouping-by-race with grouping by actual measured proficiency. Each proficiency-level group would have its own year-end proficiency goals, which would be set to require greater growth by lower-proficiency groups. Within each proficiency group, students of all races would have exactly the same academic goals, and so there would not be racial profiling.

Achieving the proficiency-group goals would also raise the scores of racial groups by amounts that could be calculated and reported. Scores of low-performing students and racial groups would increase the most.

DC could set academic goals for minority students in each proficiency group–the same as the goals for the White students in those groups. It could rate schools on how well they achieved those goals and on how equal were the gains of minority and White students within each proficiency group.

Hide failure

The plan that you are being asked to endorse, with its timetable of essentially “never” for racial equity in education, aims to make it as easy as possible for DC officials to say that they are meeting their federally approved education goals and thereby hide their failure to make students proficient.

DC education officials appear to give highest priority to hiding their failures. I will describe here another current example: their plan to change DC’s school-rating system in a way that hides the failure of schools to make students proficient.

DC schools are highly segregated racially. The Supreme Court said in 1954 that separate education is inherently unequal. Whether or not that is true in theory, it is true in practice. Separate education is clearly not equal in DC schools or elsewhere in the country, and there is no reason to believe that separate will become equal in the future.

Yet no DC education official is calling out the problem. However, DC’s current school-rating system does call out the problem and draw attention to the fact that education in DC is unequal.

DC’s answer is to change its school-rating system in a way that will put lipstick on the pig of racial segregation. The new system will give separate, less-than-equal schools higher ratings, making separate look more equal. This will help to normalize DC’s separate-but-equal approach to schools.

The new school-rating system hides a school’s proficiency data by putting it at the very end of a list of six measures. This hides the key question of whether the school is keeping students up to grade level academically. Black parents are being told that “there’s more to a school than just academics”–and so stop trying to get your children into one of DC’s few integrated schools, where the academic standards are higher.

Such bad advice reinforces DC’s separate-but-equal model of education, which doesn’t work because it is not equal.

The new school-rating system, like the 2041 equity plan, tries to hide the fact that the District of Columbia is not seriously pursuing racial equality in education. Both should be rejected.

Hide academic racial profiling from public scrutiny

George Bush called it the bigotry of low expectations, and DC education officials do not want to be seen as bigots. So it is no surprise that they diligently hide from the public the fact that they have written lower academic achievement goals for Black and Latino children than for White children.

DC officials have done many things to hide their low academic expectations for minority children, including the following:

1. Thirty days is traditionally taken to be the absolute minimum time for a public comment period, and so it was no surprise when DC education officials told the school board that they would give the public no more than 30 days to comment on their 2041 equity plan. (See here, p. 15.)

However, officials then set the comment cutoff time less than 30 days after they revealed the plan on February 2, 2022. So no stakeholder had even the minimum 30 days to formulate a response. (February 2, 2022 to March 2, 2022 is counted as 28 days, because the first full day was February 3, 2022.)

2. They completely ignored your recommendation that they “seek public input through consultation that is broad.” (See here, p. 3.)

3. They completely ignored your recommendation that they seek input from “stakeholders that represent the diversity of the community.” (See here, p. 3.)

4. They completely ignored your recommendation that they conduct “targeted stakeholder outreach.” (See here, p. 3.)

5. They completely ignored your recommendation for “holding focus groups.” (See here, p. 3.)

6. They completely ignored your recommendation for “prominently listing the proposed amendments on the SEA’s website.” (See here, p. 3.) The proposed plan is not mentioned at all on the OSSE home page. To see the plan, you have to already know that it exists, as you have to click on something and then on something else and then on another thing, most of which are not at all obvious choices.

7. They have not “provided the public a reasonable opportunity to comment” on the plan, mainly because they made sure that almost no one even knew about the odious plan. (See here, p. 3.)

Hiding their racially unequal academic goals is nothing new for DC education officials. In 2016 and 2017, they spent a year developing in a very public way the education plan called for by the Every Student Succeeds Act. Very public except for one thing: the plan’s academic goals, which are arguably the heart of an education plan. They developed their racially unequal academic goals in secret, without the knowledge or participation of parents or other stakeholders. They revealed the goals as late in the process as possible, and only because federal rules required a public comment period of at least 30 days. (This August 28, 2017 document describes DC’s work on the original ESSA plan.)

Another clear sign that DC officials do not sincerely want stakeholders to be involved in the development of DC’s education plans is the tiny amount of time they allotted for making changes in response to public comment. They allotted only 3 working days to revise the plan after the end of the truncated public comment period. Obviously, that is insufficient time to make any substantial revision, such as the changes called for in this letter.

That, and DC’s long history of ignoring public input, is why this comment on DC’s revised education plan takes the form of a letter addressed to you. DC education officials can and should seriously consider the comments here, but only a fool would think that they will.

What a mockery of rule by law it would be if for political reasons you threw DC children under the school bus and certified that DC officials met the legal requirements that their plan be “ambitious” and that they “afford a reasonable opportunity for public comment.” (See here, p. 3.) You can’t do that with a straight face.

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s