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ESEA Reauthorization

At National Journal: The Tobacco Tax is a Place to Start

April 24, 2013

Last week, the National Journal Education Experts blog asked if funding pre-K with cigarette taxes was a good idea.

I argue that seeking out new and creative funding streams has merit and that the tobacco tax is worth talking about. But I also caution that such a tax should not and cannot realistically be the long-term solution:

Key Questions on the Obama Administration's 2014 Education Budget Request

April 11, 2013
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President Barack Obama submitted his fiscal year 2014 budget request to Congress on April 10, 2013. The New America Foundation has reviewed the president’s proposals and generated a list of key questions that policymakers, the media, stakeholder groups, and the public should ask about the proposals.

Early Learning and PreK-12 Education

1. The president’s budget proposes to partner with states to provide high-quality pre-kindergarten programs for all low- and moderate-income 4-year-olds, funded with $75.0 billion over 10 years through a 94-cent increase in the federal tobacco tax. The corresponding budget documents provide some guidance on how quality will be defined, mentioning full-day programs, small class sizes and low child-adult ratios, but they are silent on other issues. How specifically will quality be defined? Will pre-K teachers be required to earn bachelor’s degrees or demonstrate specialization in early childhood education? What about states that want to make more investments in pre-K, but cannot meet the match required by the federal government? What safeguards will be put into place to ensure that the funding would not become another siloed funding stream?  And will any guidance be issued to encourage states to – in the long-term – fund pre-K and kindergarten the same way 1st through 12th grade are funded?

2. The president’s proposal includes $300 million for the Promise Neighborhoods program, a $240 million increase over last year. Some of the program’s funds will reside under a new inter-agency header, Promise Zones, in which housing, criminal justice, education, and economic growth efforts are all deployed within a single geographical area. The number of awards will be split between planning grants and implementation. Is the administration counting on sustaining this higher level of funding for the program moving forward? Should a relatively new program bring on so many new communities, rather than focusing on deepening services for existing grantees?

3. The president proposes $300 million for new competitive grants to encourage high schools to strengthen college and career readiness by redesigning traditional programs and creating partnerships with community colleges and employers so that students graduate with college credit and career skills. How would the Department of Education identify high-quality models that are likely to improve students’ postsecondary readiness, and would certain criteria be prioritized?  Would grantees be required to match any of the funding? 

And how would the High School Redesign competition interact with similar proposals? Dual enrollment, Advanced Placement (AP), early college high schools, and other accelerated programs would be supported in the president’s proposed $102 million College Pathways and Accelerated Learning initiative. The administration would simultaneously overhaul Career and Technical Education programs within high schools that operate under the Perkins Act through a $1.1 billion budget request. And an additional $32 million would supplement Perkins funds to address local workforce needs and support adult learners by allowing them to earn high school and college credit through dual enrollment. How would the department ensure these efforts complement, rather than compete with, one another? 

4. The president’s budget request includes $659 million for a School Turnaround Grants program. This would maintain spending for state School Improvement Grants (SIG), but would also expand the program to include all priority schools under No Child Left Behind (NCLB) waivers and add $125 million in competitive funding for districts to build capacity and maintain progress in schools nearing the end of their 3-year SIG interventions. Will the department issue guidance to encourage schools to add early learning efforts, like pre-K and full-day kindergarten, as part of school turnarounds? And what will the criteria be for districts applying for the new capacity-building grants? How will the department define successful district strategies to support persistently low-achieving schools? Districts’ lack of capacity has been one prominent criticism of the SIG program, but given that over $3 billion has been spent on SIG already, is the additional $125 million too little, too late?

5. The president proposes $215 million for the Investing in Innovation program (i3), an increase of $66 million. But nearly all of the increase ($64 million) would go toward a new program called Advanced Research Projects in Agency-Education (ARPA-ED) modeled after similar efforts in the Departments of Defense and Energy. The i3 fund provides competitive grants to school districts, nonprofits, and consortia to implement, validate, or scale up promising reform efforts. Would the i3 program continue to focus on certain reform initiatives, like teacher and leader effectiveness, or would the program shift focus to other areas, including early learning and student achievement in STEM subjects? Would ARPA-ED share the i3 focus? And how will the Obama administration ensure that ARPA-ED avoids redundancy with the Institute for Education Sciences?  

6. The president proposes to flat-fund the Assessing Achievement program at $389 million, which would replace State Assessments funding in NCLB. The Common Core assessment consortia, PARCC and SmarterBalanced, have been supported with $360 million in 2009 stimulus funds, set to expire in the fall of 2014 – before the tests are fully administered in the spring of 2015. The two consortia would be eligible to compete for an additional $9 million in funding under Assessing Achievement, while the remaining $380 million would be allocated by formula to states. Given pressure for additional assessments in PreK-3rd grade and untested subjects, technology upgrades and increased bandwidth, formative assessments, improved test security, aligned curriculum and professional development, and other supports, will states have sufficient resources to transition to the Common Core assessments while also maintaining and improving their other assessments? And is $9 million sufficient to complete and sustain the work of the Common Core assessment consortia during their first year of full implementation? What guidance will the department provide to help states and the consortia prioritize their activities heading into the critical 2014-15 school year?

Higher Education

7. The president proposes expanding the recently enacted, more generous Income-Based Repayment plan for federal student loans, Pay As You Earn, to all borrowers rather than just new borrowers as of October 1, 2007, and eliminating the tax on loans forgiven for borrowers. Last year, the New America Foundation argued for those exact policy changes – provided that Congress and the administration first address the perverse incentives and windfall benefits the program will provide to graduate and professional students and the schools that enroll them.                

If Pay As You Earn is expanded to all borrowers and loan forgiveness benefits are made tax-free, as the president is proposing, isn’t it even more important to rein in the program’s windfall benefits and perverse incentives? Does the administration have any thoughts on how to address these issues while maintaining the program’s benefits for lower-income and lower-debt borrowers?             

8. The president proposes setting interest rates on student loans at the 10-year Treasury note plus an additional 0.93, 2.93, and 3.93 percent for Subsidized and Unsubsidized Stafford and Grad PLUS loans, respectively.  The rate would adjust every year for newly issued loans based on the Treasury rate, but is fixed the life of the loan. The proposal closely mirrors one originally proposed by the Education Policy Program’s Jason Delisle.

Unlike Delisle's proposal, the interest rate in the president’s budget for Subsidized Stafford loans is lower than those for other loans. However, the Income-Based Repayment program makes the lower rate on Subsidized Stafford loans an unnecessary benefit, given that loans can always be paid as a low percentage of income regardless of the interest rate. What is the justification for the lower rate? Why provide an extra benefit for borrowers when Income-Based Repayment is available for struggling borrowers? Couldn't the budgetary resources used to provide the lower rate be put toward the Pell Grant program instead, where they are certain to help low-income students?

9. The president proposes a program that would allow non-accredited providers of learning to receive federal funding for two-year degrees that are both free to the student and high-quality, with demonstrable outcomes.  The goal of Pay for Success is to provide students with alternate pathways for high-quality, low-cost higher education.  Providers would front the costs and be reimbursed only when and if students succeed. This would allow learning acquired and/or certified through means as varied as MOOCs, work-based training, AP exams, and more to be packaged together to create a free, coherent, high-quality competency-based degree.

The budget documents indicate that demonstrated competencies, passage of field-appropriate licensing tests, and job placement are possible indicators of success. How will these indicators be determined? Will the agreed-upon indicators be transparent? How will the outcomes be verified? Will additional measures include acceptance of the two-year degrees for transfer by four-year institutions? How would this work if the “degrees” are not accredited? If students can demonstrate competencies and the outcomes are solid, what would be the justification for not accrediting these new degree programs? How would findings from this experiment on an outcomes-focused delivery model inform the broader conversation around higher education quality?

10. Providing students and families with better information in order to help them make more informed college-going choices is a recurring theme in the budget. It is highlighted as an area for state reform in the proposed $1.0 billion Race to the Top College Affordability and Completion competition and given as an example of an area to study under a $67.0 billion proposed higher education/financial aid research and evaluation program. And the president unveiled his College Scorecard in the 2013 State of the Union address to provide better, more actionable data to students in a user-friendly manner. Yet one of the main indicators on the Scorecard—employment—is essentially blank. Although the department has said that it is working to provide the information, it is not clear how or when that will occur. Given bipartisan interest in better postsecondary outcomes data, what is the department’s plan to provide accurate employment data to students? Does the president plan to make the Scorecard mandatory? If so, when? If the department wants to encourage states to provide better information, shouldn't it also lead by example?


Don’t Forget Full-Day Kindergarten

February 21, 2013

An under-examined aspect of President Obama’s new early childhood education plan is his proposal to encourage states to create more full-day kindergarten seats – though only after states are able to guarantee access to pre-K for all 4-year olds from low and moderate-income families.

Waiver Watch: The Real Lessons Learned from the Senate Waiver Hearing

February 14, 2013
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Tuesday was a big night for early education and higher education. But what about all the education that happens in between? Teachers were mentioned once, but in the context of deficit reduction, not education. No Child Left Behind (NCLB) and waivers fared even worse, with nary a word. But never fear, waiver watchers got all the coverage they needed last week from the Senate HELP Committee and Council of Chief State School Officers (CCSSO). In a hearing and subsequent CCSSO panel, policymakers and experts debated the early lessons from the waivers and implications for a near- or distant-future NCLB reauthorization.

For those following the waivers, however, the hearings were largely a disappointment – offering few specific insights from year one of implementation. District waivers? Still a possibility. Super subgroups are diluting accountability? Old news. If anything, the discussions mirrored  the HELP Committee markup over a year ago in its attempt at ESEA reauthorization. In fact, we learned more about reauthorization’s prospects than we did about the waivers. The hearing may have promised “lessons learned,” but those lessons depended entirely on who you asked:

Secretary Duncan – obviously – is a big cheerleader for the waivers, as opposed to working with Congress on a reauthorization: “My team and I put in hundreds and hundreds of hours in what proved to be a fruitless effort over the past two years. In all candor, I would like to have gone to waivers earlier.” He highlighted how states are focusing on subjects beyond math and reading, how more schools are being held accountable for student subgroup performance, and how states are promoting teacher quality, instead of credentials.

Although giving states options has benefits, not all states made good choices. As Andy Rotherham asked later, what do waivers look like in the hands of not-so-great state chiefs? Many declined to take advantage of new measures of student growth or postsecondary readiness. Worse, states often backtracked on plans to strengthen graduation rate and subgroup accountability, concerns highlighted by the Alliance for Excellent Education and Education Trust.

Democratic Senators and their allies, including Education Trust’s Kati Haycock, are no fans of NCLB, but have still taken issue with many of the features emerging in states’ waivers: super-subgroups, uneven goals that do not close achievement gaps and are not linked to any consequences, toothless school improvement policies, and more. Unfortunately, these groups are pointing out flaws in states’ waivers, but offering fewer solutions to fix them.

One option is for the Department to require states to amend their waivers if they don’t sufficiently meet the needs of vulnerable students (states can also voluntarily do so, with Department approval). But chiefs, like New Jersey’s Chris Cerf and Kentucky’s Terry Holliday, aren’t keen on the idea of mid-course corrections and more negotiations with ED. Given their reluctance and questions about how to monitor waivers, it seems unlikely that states will make significant changes. This doesn’t mean policymakers won’t learn anything from the waiver experiment, but it may take years for these lessons to be applied.

Another option is to push strongly for reauthorization. But this carries risks for civil rights groups given the preference for local control and even more state flexibility among Republican legislators, state chiefs, and governors. While HELP members like Senators Tom Harkin (D-IA) and Michael Bennet (D-CO) spoke of reauthorization, they appear unable to offer any new solutions that would present a departure from NCLB, recognize the concerns of the civil rights community, and maintain a strong federal role in education.

State schools chiefs, however, are advocating for reauthorization, but for a variety of reasons. First, they point out that many states do not have waivers. To New York Commissioner John King, this means there is no “floor” for state policy to safeguard against poor decisions. Alternatively, Holliday cited the need for long-term stability, because the waivers are subject to the Secretary of Education’s priorities. Regardless, all chiefs would welcome a new NCLB that maintains – or expands – flexibility. And most likely, the level of flexibility in the waivers would be the default starting point for any reauthorization right now. Lawmakers would receive incredible pushback if a new NCLB required states to dramatically alter the plans in which they’ve already invested a great deal of time, energy, and resources.

Republican Senators appear to be aligning most closely with the chiefs on reauthorization – less so in supporting waivers. Senator Lamar Alexander (R-TN) equated the waivers to an inside-the-beltway version of 'Mother May I,’ while Senator Pat Roberts (R-KS) lambasted the “regulatory purgatory” the Department created. In particular, Alexander was adamant that the government should not require states to adopt teacher evaluations based on student achievement. In one exchange with King, Alexander pressed: “We only give you 10 percent of your money. Why do I have to come from the mountains of Tennessee to tell New York that’s good for you?” But despite Alexander’s strong opinions, there is no consensus among the minority either – Senator Johnny Isakson (R-GA) seemed quite pleased with what his state accomplished in their waiver.

In short, reauthorization has not stalled because the waivers are popular. Rather, Republicans cannot make a strong-enough case for the level of local control many in their caucus seek, and Democrats prefer the temporary waiver policy to a decade of local control with little federal oversight. Without a clear alternative to NCLB that also provides a strong, compelling case for federal involvement in education, waivers really are their best choice.

The silver lining, as Bellwether Education Partners' Andy Smarick pointed out, is that with another year, or two, or three of waivers, some actual lessons might emerge that could inform and transform the thinking of those who seek a stronger federal role in K-12 policy – and those that don’t. We’ll be watching for them. Stay tuned.

Waiver Watch: Forecasting Obama's Second Term

January 22, 2013
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Much like the rest of President Obama’s signature education programs from the first term, the policy around ESEA flexibility seems to be shifting. The focus is no longer on how to win a waiver, but rather, on how to implement and monitor the commitments states made. Most states have secured their waiver, with only a handful waiting for approval from the Department of Education. While I’d encourage states to continue to refine their waivers based on lessons learned during implementation, no one has forced states (besides Virginia) to change their plans mid-course. Further, the Department has already shifted their attention to initiatives in early education and higher education.

So where does that leave the NCLB waivers in the second term? As I’ve written before, the waivers are insanely complicated, making it difficult for the public and even policymakers to parse out what states should be doing. That’s why it’s notable that the Senate HELP Committee wants to hold hearings on the waivers as soon as February, with testimony from Education Secretary Arne Duncan and state chiefs overseeing the waivers in their states. The House Education and Workforce committee is also mulling their role in providing oversight.  These hearings would likely involve some of the most controversial issues around graduation rate accountability, super subgroups, and different goals for minority and disadvantaged students.

While the hearings will likely shed light on the best – and worst – attributes of ESEA flexibility, the real question is whether they will lead to any meaningful action. The 112th Congress was the least productive and most polarized in history, and the 113th is not off to an auspicious start, with a so-called triple cliff to resolve before April: sequester, debt ceiling, and the expiration of the last budget continuing resolution. Add to that an unprecedented ‘to-do’ list for education – ESEA, IDEA, HEA, Perkins, WIA, CCDBG, Head Start, and the Education Services Reform Act are all pending renewal – and you have an environment where Congress will likely gripe about the waivers, but fail to reach a consensus on what to do about them.

The Obama administration seems to be betting on it. Over the next three years, states will implement their waivers and work through the kinks. By the time Congress gets its act together, states will have gone so far down the road with their new accountability and teacher evaluation systems that legislators will be hemmed in to passing a reauthorization that mirrors the flexibility policy. Secretary Duncan relayed this game plan in a speech to state chiefs: implementing the waivers “will have a big impact on shaping any reauthorization bill that might emerge.”

Given this context, here is what I’ll be watching in the second term:

District Waivers

For months, there have been rumblings of the Department offering district-level waivers for school systems in states that did not apply or were not approved for the larger flexibility plan – namely, California and Texas. Unsurprisingly, governors and state chiefs are not fans of the idea, and it is unclear what relief exactly the Department could give to districts without undermining the authority and autonomy of state education agencies. That said, eight districts in the California Office to Reform Education, or CORE, signaled their intent to apply for a waiver last week, before the Department even formally offered flexibility to them. How will Secretary Duncan respond to this request? Will the California Governor Jerry Brown or the State Board support their efforts? The CORE districts are some of the largest in California and have adopted reforms – like teacher evaluations – that doomed the state waiver request. Will other districts follow their lead?

Waiver Amendments

The waivers require states to overhaul accountability systems, implement college- and career-ready standards and assessments, and craft teacher evaluation systems based in part on student achievement. While many of these reforms could improve the state of education in the long term, the benefits are contingent on effective implementation.

Monitoring states’ waiver plans presents a significant challenge moving forward. In some states, new school grades and teacher evaluations appear arbitrary or inconsistent with past guidelines. Will states be receptive and responsive to feedback from educators, legislators, and the public? Just as states negotiated with the Department to draft their initial proposals, they have the opportunity to amend their plans at any time – Florida, Oklahoma, and South Carolina have done so already. Further, the Department should not rely on states alone to self-monitor their progress. With more states operating under a waiver than the original NCLB law, does the Department have the capacity to successfully monitor states’ activities? And if states do not follow through with their promises, will they intervene?

Stay tuned to the Waiver Watch for continuing coverage of these issues, and more, as states implement their flexibility plans.

Early Ed’s 10 Hot Spots to Watch in 2013

January 4, 2013
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Each January, Early Ed Watch predicts where we will see the most action, innovation and consternation in the year ahead. Here are the hot spots we see for 2013. Notable is the absence of the reauthorization of the Elementary and Secondary School Act, otherwise known as No Child Left Behind. Prognosticators don’t give the bill much chance of making progress this year, given stalemates between the two houses of Congress.

The Child Care Development Block Grant, on the other hand, could see some action on Capitol Hill.  Debates on how to evaluate teachers will likely continue to dominate, as they did in 2011 and 2012. And at least one topic has popped up consistently since 2010 when we started this exercise: Head Start reform via the new "re-competition” process.

Waiver Watch: Making Sense of Thirty-Five Shades of Grey

October 24, 2012
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Anne Hyslop
This post originally appeared on Ed Money Watch.

Ever since the first waivers were submitted last November, there has been an inherent dilemma in the Obama administration’s No Child Left Behind (NCLB) flexibility plan: the tension between comprehension and precision in states’ accountability systems.

On one hand, NCLB set a goal so high – 100 percent proficiency by 2014 – that it became meaningless. And its blunt measure of school quality (student proficiency only) and prescriptive, top-down improvement activities (based on the number of years a school failed to meet Adequate Yearly Progress, regardless of why the school missed those targets) exposed the limitations of federal policy to identify and improve low-performing schools.

Yet despite its rudimentary measures, at least NCLB required states to create transparent accountability systems, full of black-and-white rules everyone understood: all students and student subgroups worked toward the same 100 percent goal, at the same pace, and all schools were subject to the same labels and interventions based on their success. 

But if school accountability under NCLB was black-and-white, then school accountability under waivers is thirty-five shades of grey. And just like the book, the public is struggling to understand the waiver phenomenon.

Waiver Watch: Making Sense of Thirty-Five Shades of Grey

October 24, 2012
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Ever since the first waivers were submitted last November, there has been an inherent dilemma in the Obama administration’s No Child Left Behind (NCLB) flexibility plan: the tension between comprehension and precision in states’ accountability systems.

On one hand, NCLB set a goal so high – 100 percent proficiency by 2014 – that it became meaningless. And its blunt measure of school quality (student proficiency only) and prescriptive, top-down improvement activities (based on the number of years a school failed to meet Adequate Yearly Progress, regardless of why the school missed those targets) exposed the limitations of federal policy to identify and improve low-performing schools.

Yet despite its rudimentary measures, at least NCLB required states to create transparent accountability systems, full of black-and-white rules everyone understood: all students and student subgroups worked toward the same 100 percent goal, at the same pace, and all schools were subject to the same labels and interventions based on their success. 

But if school accountability under NCLB was black-and-white, then school accountability under waivers is thirty-five shades of grey. And just like the book, the public is struggling to understand the waiver phenomenon.

With flexibility, states could address their grievances with NCLB by developing school accountability systems that 1) measure quality more accurately based on proficiency, growth, and postsecondary readiness, 2) better identify low-performers through letter grades or other ratings, and 3) tailor specific interventions to schools’ needs.

However, this precision comes at a cost. As accountability systems become more nuanced, they become infinitely more complicated.  The waiver applications are hundreds of pages, and many of the new models states use, like individual student growth, are so technically complex that it takes an advanced statistics background to explain them fully.

Today’s accountability systems also include more information. Many states created a web of annual performance targets, school grades, and intervention levels that do not always overlap in predictable patterns, or at all. For example, a school in Ohio could simultaneously miss performance targets for Hispanic and low-income students, earn a “C” grade, and receive a “focus” label for low graduation rates. States will also continue to report all the school data required by NCLB, even if they no longer apply to its accountability system.

Summarizing the implications of each strand in this web to families, elected officials, and reporters could be a frustrating task for state education agencies. Which is more important, the federal “focus” label or the state’s “C” grade? Why wasn’t the school graded lower if several subgroups performed below expectations? Are the improvements needed for the school to earn a “B” next year the same as the improvements needed to exit “focus” status?

This level of nuance cannot be explained in a media soundbite. And that’s one reason why in Virginia, Florida, and elsewhere, public reactions to the state’s waiver-approved performance targets are threatening the legitimacy of the new system. It’s largely a problem of perception, not policy. Given a decade of setting equal targets for all students, it feels wrong to set lower targets for racial minorities and disadvantaged students, even if these groups are expected to make greater annual progress. As Education Week’s Michele McNeil rightly notes, states would be wise to highlight achievement gap closure rates, alongside the proficiency rates, to help explain the logic of the new goals.

It might seem trivial, but these details matter. And unfortunately, the details often get bungled in public discussions of waivers, exacerbating the confusion. A generation of parents, policymakers, and journalists has been trained to expect annual school ratings and use them to make decisions about school quality. Given these expectations, state education agencies need to be much more aggressive in sharing and selling their new accountability plans to legislators, the media, and the public. States’ next generation accountability systems may be more accurate and effective, but no one will care if they can’t understand the system in the first place. 

Romney Says He Won’t Cut Education Funding, and Other Notes on Last Night’s Debate

October 4, 2012

During last night’s Presidential Debate, both candidates linked education into their arguments as a major workforce development issue- rhetoric that is often used by education and labor advocates but less often by presidential candidates, who are more likely to focus on the economy and other top-tier voting priorities.

Romney swung towards the center on many issues last night, and education was chief among them. When it comes to education and student aid, Romney said, “I'm not planning on making changes there.” Once again, he praised Education Secretary Arne Duncan and Race to the Top, and often focused more on what he had in common with Obama’s education policies than where they differ. One big exception, however, came when he touted his “backpack” program, in which students can use Title I and IDEA funds to attend whichever public school they choose. Some have called this a voucher program, though Romney hasn’t used that terminology to describe it.

Obama went after Romney’s approach to balancing the budget, saying that Romney would make cuts that would “[gut] our investments in schools and education.” When Romney announced Paul Ryan as his running mate, the Ryan budget raised eyebrows among many with its drastic cuts in domestic discretionary spending, a pool that includes education. As I and my colleague Clare McCann have noted on Early Ed Watch before, Ryan’s budget could have a big impact on federal education spending—though it won’t necessarily “gut” every education program.

Waiver Watch: What is College-Ready and Who Gets to Decide?

October 3, 2012
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It goes without saying these days that there is a lot of angst around Common Core implementation among state officials, local administrators, educators, and policy insiders. Many worry about the kinds of questions that will be on the new assessments, the quality of instructional materials, curricula, and training for teachers, the lack of technical capacity to handle online testing, and the possibility that federal involvement in Common Core will erode state political support. These are all significant, valid concerns within the K-12 community.

But no matter how well these issues are addressed, Common Core implementation faces a final challenge: how does higher education respond? After all, if Common Core aims to reflect “the knowledge and skills that our young people need for success in college and careers,” then the real test is whether Common Core mastery is seen as legitimate and sufficient preparation within higher education.

Thanks to the Department of Education’s ESEA waivers, this test is already happening. As I’ve written previously, states had to demonstrate adoption of college- and career-ready standards to secure ESEA flexibility. States could meet the bar in two ways: through Common Core or through standards approved by the state’s postsecondary institutions, which certify that students meeting the standards will not need college remediation. Last week, Bellwether's Chad Aldeman examined two recent requests based on the latter option, Alaska and Puerto Rico. Both waivers come up short. Postsecondary institutions support the standards, but not where it counts: policy. Neither assures that students meeting the K-12 standards will enter directly into college-level courses.

But what will encourage states to change remediation policy? It’s clearly not a waiver requirement. In November, Minnesota submitted a nearly-identical letter from its postsecondary leaders to certify the state’s math standards. But the letter admitted Minnesota lacks “any empirical evidence that students who master those standards do not require remediation in higher education." Isn’t that the point? They may say that standards mastery will lead to college-level work, but Minnesota failed to take any real action to guarantee it. Still, the Department approved the waiver request... and will likely do the same with Alaska and Puerto Rico. 

College- and career-ready standards, Common Core or otherwise, are only meaningful if they’re accepted by higher education and legitimized through the admissions and remedial placement process. Unfortunately, postsecondary institutions remain on the periphery of Common Core implementation, even as states begin to link high school exit exams to college readiness standards. The ongoing development of college- and career-ready assessments has allowed institutions to delay making decisions about how they will treat the new standards. But justified delay can become indistinguishable from unjustified avoidance.

Fortunately, not all states are waiting. In 2009, Kentucky adopted statewide performance indicators for readiness that translate from K-12 to higher education and are used to make remedial placement decisions in all public colleges and universities. Placement exams are where college readiness meets reality. No matter the assessment used, these measures serve as significant barriers to entry in higher education – with students identified for remediation much less likely to complete their degree. Since Kentucky requires high school students to take the ACT, many indicators are based on those benchmarks now, but can be updated to include the Common Core assessments in time.

Instead of avoiding the issue and defining readiness on an institution-by-institution basis, more states should follow Kentucky’s lead and adopt uniform performance standards for K-12 and higher education. And the Department can help by raising the bar for states to demonstrate their standards are certified by postsecondary institutions in both ESEA waivers and its ESEA reauthorization Blueprint. Otherwise, the tremendous efforts to implement college- and career-ready standards by governors, chief state school officers, the assessment consortia, and educators, may be for naught. Without concrete state policies, higher education will continue to decide – as they always have – what college readiness really means. 

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