July 7, 2016
Director of Educator Effectiveness
600 Washington St SE
Olympia, WA 98501
Dear Ms. Anderson,
By this letter, the League of Education Voters (LEV) is providing comments on the Superintendent of Public Instruction’s proposed revisions to Washington Administrative Code 392-191A, regarding the Teacher & Principal Evaluation Program, that will be discussed at the July 7, 2016 OSPI rules hearing. LEV supports efforts to create a more meaningful evaluation system that drives continuous improvement and has some concerns regarding the proposed changes to the current rules and the rulemaking process.
I. Transparency & Community Engagement
Transparency and community engagement should be embedded in the process for updating the rules governing TPEP and should be reflected in the updated rules adopted by OSPI.
- The lack of public and stakeholder engagement outside of the steering committee members is a We appreciate the time and work the steering committee has undoubtedly devoted to this topic. For any individuals or organizations not on the steering committee, however, it is very difficult to know about any changes that are being considered. We became aware of the proposed revisions less than 48 hours before the hearing will be taking place. Many stakeholders beyond the steering committee were involved in the legislation creating TPEP and many more beyond that may be interested. More meaningful outreach and engagement should be done with families, students, and communities.
- Given that low-income students and students of color are usually served by less experienced teachers and are in schools with higher teacher turnover, has there been any analysis on whether these proposed changes would have a disproportionate impact on low-income communities and communities of color?
- It is unclear in the proposed language how focused evaluation scores will be The draft rules propose that a comprehensive evaluation rating will be the rating on record for a teacher when they are on a focused evaluation, but remain silent on how this will impact reporting of scores earned on the focused evaluations. Consistent with current practice, we believe that all scores earned though comprehensive or focused evaluations should be reported to OSPI, and this practice should be clarified in the new rule.
II. Continuous Improvement and Consistency in the Process
The evaluation system and its complementary components should consistently reflect a philosophy of continuous improvement that focuses on improving teacher and principal quality to better support students in their educational experience.
- To remain consistent with the philosophy of continuous improvement, the focused evaluations should drive towards growth in areas that would most improve instructional practice and student The rules should establish and clarify that when an evaluator selects a criteria for the focused evaluation the criteria selected should be determined by which focus area would most improve an individual’s instructional practice.
- Do the proposed changes create a system where a teacher’s evaluation score of record can be improved but not lowered through the focused evaluation? If so, we feel this and should be A teacher or principal’s score of record should either 1) remain constant between comprehensive evaluations to enable a focus on areas with the greatest potential for growth or 2) be adjustable (either higher or lower) between comprehensive evaluations.
- Do the proposed changes to the definition of ‘observe or observation’ create the possibility for no actual classroom observations to take place? What is the minimum criteria for what counts as an observation? A minimum floor should be established for what constitutes an observation that supports districts that want to implement more robust evaluations and feedback for teachers and principals to support them in their professional growth.
Thank you for your work and for your consideration.
Amy Y. Liu
League of Education Voters
2734 Westlake Ave N
Seattle, WA 98109