Testimony of Mary Ann Stewart, Chair of the Board
Good morning; I am Mary Ann Stewart, Chair of the Board of MassPartners for Public Schools and legislative advocacy chair for the Massachusetts Parent Teacher Association. I also serve on the school committee in Lexington.
Three of my MassPartners colleagues join me on this panel. This is the first time in many years that the members of MassPartners for Public Schools feel so strongly about a problem that we wanted to speak with you out of a concern that we all share.
MassPartners is a coalition of the major education organizations in the state. The Board of Directors meets regularly and its members are generally the chief executive of each organization. The organizations that are members are the
- American Federation of Teachers Massachusetts,
- Massachusetts Association of School Committees,
- Massachusetts Association of School Superintendents,
- Massachusetts Elementary School Principals’ Association,
- Massachusetts Parent Teacher Association,
- Massachusetts Secondary School Administrators’ Association, and the
- Massachusetts Teachers Association.
We are here today to support four bills that you are considering: H. 459 by Chair Peisch, H. 375 by Representative James
Dwyer, H. 512 by Representative Chris Walsh, and H. 528 by former Representative Marty Walz.
We are concerned that there is inordinate growth in requirements that are placed on our schools at a time when schools are working on three major change initiatives that will reshape public education in major ways. These are RETELL, educator evaluation, and aligning to the new common core and PARCC test, which will replace MCAS.
Educators have been afraid to speak up about the problem of increasing regulatory demands for fear of being labeled as not willing to change or stuck in the old ways. Today, I suggest you will hear the concern spoken clearly and we thank you for the opportunity.
On behalf of all the members of MassPartners, please accept our thanks for considering our concerns. We believe that teachers, students, and taxpayers deserve a comprehensive analysis of the true costs of excess regulations and paperwork.
We are united in our support of these four bills. MassPartners members are listed as participants in the work that will be required in these bills and we welcome the chance to take a comprehensive look at the initiatives and their demands. Our goals are to develop a well-thought-out plan, a strategic timeline, and more useful reporting rules and procedures.
We think the partnership of practitioners, policy makers, and legislators that would be created by these bills is the kind of partnership that “has the power to make changes”.
MassPartners members who will join me in providing testimony are Glenn Koocher, Tom Scott, and Julia Johnson. Thank you.
Testimony of Glenn Koocher, Executive Director
Massachusetts Association of School Committees
I am here to support H. 459 and to voice support for the other bills designed to limit the volume of regulation imposed on local school districts by gathering data, identifying the costs of compliance, determining the time necessary to fulfill directives, and to address in general the regulatory culture that prioritizes obedience, compliance, and fulfillment of directives that come from someplace other than the community.
We speak directly to the amount of time and energy that educators and policy makers commit not only to follow the law which we respect, but to adhere to literally hundreds of pages of directives at a time when we are under pressure to make continuous improvement in the achievement of our tops-in-the-nation student population.
It’s one thing to drive people harder to help students achieve academically when we have the highest performing students in America – and when even our achievement gap shows the kids at risk outperform their out-of-state counterparts.
Or to continue to sell to the public how rigorous and disciplined our rules and regulations are and how zealously the state ensures that educators and administrators are in full compliance with the nation’s highest standards and voluminous compliance requirements.
Or to continue to operate a ranking system that stigmatizes schools and districts based on standardized testing that uses the highest proficiency standard in the United States to measure progress.
But it’s another matter altogether to realize that, to date, no one has really tallied the cost of compliance with regulations, obedience to voluminous directives, and adherence to highly prescriptive processes.
We found over 800 pages of regulations, guidelines, instructions, advisories, model procedures, and matrices have been issued for educator evaluation alone.
We have cooperated and collaborated but still, in the last two years we’ve had to deal with more than a half dozen significant regulatory requirements:
- We’re well on our way to implementing the new state evaluation system as instructed.
- We’re working through all that needs to be done to identify the district determined measures of student achievement to make the system work.
- We’ve accepted the obligation and expense to implement the common core curriculum and to make it work.
- We’re preparing for the infrastructure that will administer the PARCC examinations even though many districts still don’t have wireless Internet or the hardware to do it.
- We’re having our teachers endure the 30+ hours of additional training to meet the demands of federal bureaucrats for educating English language learners.
- We’ve implemented comprehensive legislation to address bullying.
- A new state nutrition regulatory system is being put in place.
- We’re preparing to implement new legislation to ensure that students who face suspension and expulsion will still be educated.
- Many of us are trying out the Innovation School concept.
- And our teachers are still diligently trying to educate the nation’s highest performing students in the classroom and close the gap between rich and poor which the bureaucracy doesn’t seem to understand takes the whole school day by itself.
And this is all in the last two years. That’s why all these organizations, and every state school boards association in America has joined in a call to state capitals and Washington where legislation has also been filed to:
- Identify the cost and time required to obey all new regulations.
- Limit the right of the Departments of Education to issue new regulations without the expressed consent of the legislatures.
- Curb regulatory abuses where the appointed, but unelected, add to the volume of work educators and local policy makers must complete.
We urge you to join us in the national call to measure the cost of compliance with rulemaking and to bring a halt to any regulations that do not improve services to children in their classrooms.
Testimony of Tim Sullivan, Vice-President
Massachusetts Teachers Association
On behalf of the Massachusetts Teachers Association, I want to express our strong support for the intent of four bills before you today: to establish a task force, special commission or working group to address the growing concern by educators, administrators, educational leaders and local officials that the current state mandates imposed on our public schools and districts have become unworkable and perhaps even counter-productive.
One of the most serious problems that we have identified is that the rules and regulations developed to implement the required initiatives are often developed without sufficient input from those who are required to administer the initiatives. They are also often developed separately for each new initiative, as if one initiative has no relation to, or effect on, another. This development of rules and regulations within separate “silos” has resulted in an incomplete picture of the effect of various initiatives on our schools and more importantly, on student learning.
One of our particular concerns right now is the new educator evaluation system. It will undoubtedly foster new relationships and accountability in our schools and we, as the workforce in our schools, want to make sure we all get it right.
Within the framework of the proposed legislation, MassPartners suggests the following guidelines:
First, there needs to be an evaluation of every requirement to determine whether the costs in time and money are worth the value of the requirement toward improving student learning.
Second, there needs to be an examination of all rules, regulations and reporting requirements to consolidate and to eliminate duplicative or unnecessary requirements.
Finally, after the evaluation and examination, we need a comprehensive plan that coordinates and clarifies the timelines, costs, and benefits of all such rules, regulations and reporting requirements.
Thank you for your consideration of our concerns and we look forward to working with you on this important legislation.
Testimony of Thomas Scott, Executive Director
Massachusetts Association of School Superintendents
Thank you for the opportunity to speak in support of House Bills 375, 459, 512 and 528.
I am joined today by 85 superintendents from across the Commonwealth as an expression of support for these bills and our desire to reduce the impact of mandates on the daily functioning of our schools. These superintendents represent our colleagues around the Commonwealth and an expression of how important this issue is to us.
The good news is that they will not all be testifying. We will have two panels of superintendents representing multiple perspectives on the mandate, the impact these mandates have in our districts, and expression of support for the House Bills.
We want to be clear. Our desire is not to eliminate many of the important reform initiatives under way. Educator Evaluation, RETELL and Common Core alignment and PARCC are demanding and do require a reasonable timeline for implementation. We are looking for increased flexibility in getting this work done right. We are working with DESE on these concerns.
But taking on these major initiatives with all the other mandates pressing on us is very problematic. We are seeking long term relief from the magnitude of mandates and regulations. Are they all necessary, are there redundancies, what are the costs and how do we minimize their impact on time and other resources in our schools?
During the fall of 2012, the Taunton Public Schools estimated that the cost of state and federal rules, regulations, and reporting requirements would cost an additional $6.7 to their $78 million budget over the next few years.
This analysis is included in a packet of information we are providing the Joint Education Committee. Also included is a comprehensive list of mandates required of local school districts.
As a snapshot of the increasing number of regulations and documents requiring action by local districts we looked back in the DESE web site:
- A content search for regulations on DESE web site shows there were 5,382 multiple page documents between 2009 – 2013 (average of 1077 each year) contrasted to 4,055 for the previous 13 years (or an average of 312 each year). In the last four years we have seen four times the rate of regulations since the inception of the 1992 Education Reform Law.
On one of our current major initiatives we have seen over 4,972 documents requiring action in the past 4 years.
We are interested in an overall review of the fiscal impact, uncovering duplicative efforts, naming unnecessary and outdated mandates, and streamlining requirements wherever possible.
In the 1993 Ed Reform Act, section 93 provided the powers of a Regulatory Relief Commission. “This Commission was created to review and evaluate all statutes and regulations to simplify compliance and reduce regulations.”
We do not know if anything resulted from this Commission. What we do know is that in 1993 the legislature recognized that regulatory relief was necessary. Based on our brief review of the past 20 years, the problem cited in 1993 has been amplified multiple times.
We respectfully request that you support these bills or resurrect Section 93 of the 1993 Education Reform Act. Thank you for your consideration of our request.