Comment regarding EDU-18-19-0006-ERP, Revised Emergency Regulations pursuant to ESSA and NY's Approved ESSA Plan
Dear Chancellor Rosa, Board of Regents, Commissioner Elia, and Dr. Lisa Long:
We are the Hastings-on-Hudson Board of Education and write to ask that the provisions of the revised emergency regulations regarding opt outs and participation in State tests be revised, so that 1) Title 1 funding consequences are removed, and 2) Districts decide how to handle increasing test participation.
The State's new emergency regulations require that if a District's overall opt out percentages aren't showing improvement by the spring of 2019 -- less than a year away -- then the State can impose a number of mandates on the District. These mandates include having Districts create self-assessments, task forces, and audits, all to address lowering opt outs. This would mean that Districts would be forced to use their limited time and resources to change the attitudes of parents who opt their children out, rather than to address pressing matters, like school safety, mental health crises, drug and alcohol abuse, chronic absenteeism, and more. We also must note that the emergency regulations appear to lack any funding whatsoever for Districts should these mandates be triggered.
Worse, if test participation doesn't improve to the State's liking, the emergency regulations allow the State to force Districts to spend their Title 1 funding on efforts to convince parents to have their children tested. It is this provision in particular that strikes a chord with us in such a way that we must comment and oppose.
Title 1 funds are provided specifically to help poor children be on a more level playing field with their more affluent peers, removing some of the obstacles to a sound education that profound poverty presents, by funding programs like extra reading and math support, and afterschool and summer school academic support programs. As a Board of Education, it is our fiduciary duty to speak out and ensure that these essential funds are never placed in jeopardy, and that our poorest students continue to receive this critical help. For the State to promulgate regulations that would allow these vulnerable children to lose these resources -- for the sake of trying to convince parents about the good of State testing -- is simply not acceptable.
In sum, the above provisions of the revised emergency regulations are not workable, in terms of time, resources, money, and programming. And worse, they take unnecessary aim at our most at-risk students -- those who are poor enough to trigger Title 1 funds.
We therefore ask that the State reconsider and revise the regulations so as to no longer involve Title 1 funding. In addition, we ask that rather than dictate what a school district must do regarding opt out percentages, the State instead leave those decisions up to school districts.
The Hastings-on-Hudson Board of Education