NSRA Statement on Part 100 regulations
relating to
new standards, professional development,
etc.
May 25, 1999
Hon. Richard Mills, Commissioner
New York State Education Department
State Education Building
Albany, New York 12234
Dear Commissioner Mills:
The New York State Reading Association (NYSRA) welcomes this opportunity to offer comments on proposed changes related to Part 100 of the Commissioner's regulations and the Academic Intervention Services initiative.
Our Association represents over 6,000 reading professionals who are classroom teachers, reading teachers, school librarians, college educators, school administrators, curriculum specialists and parents. We are committed to the goal of providing all students with essential reading skills and strategies they need to attain high academic standards and to function successfully in our society.
We believe the direction established by the Regents requiring higher
learning
standards and increased graduation requirements for all students is
educationally sound and proactive. All students are able to learn; all
students should be expected to learn; and all students must be equipped with
the appropriate supports, resources and tools necessary to achieve higher
academic expectations. It is within this framework that we present our
comments and observations and ask that you not only consider these comments
in
the constructive vein in which they are presented, but that they also be
incorporated into the final version of the Part 100 regulations.
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Diverse Academic Requirements: NYSRA supports establishment of academic requirements at different grade levels (K-3, 4-8 and 9-12) to reflect the diverse learning needs of students directly affecting their need for extra time and extra help. That is to say, NYSRA supports the concept of a sequential core curriculum with specific performance indicators required for each content subject area much like the core curriculum guides that are being released by the Department. However, we oppose the Department's prescribing the "how" of instruction. These types of instructional decisions and academic
choices must remain with local districts and professional staff. -
Local AIS Development/Reading Teacher Roles: The introduction and implementation of Academic Intervention Services (AIS) is important for our schools. This approach to providing academic support to help students attain higher academic standards will assist in reassuring students and parents that schools have a well-defined plan to provide intensive educational support to prepare students to pass the five mandated Regents exams required to graduate. In order to ensure maximum effectiveness, school districts must be afforded significant flexibility in developing plans and procedures to identify those students who require intervention and to determine the specific type of programming which will benefit these students. The members of the New York State Reading Association join with other professional organizations and teacher unions in emphasizing that the best intervention begins in the early primary years. We support universal pre-kindergarten programs for all children in all communities. We support class-size reduction to levels not exceeding 18 children in kindergarten and first grade and a maximum of 20 children in grades two and three. Additionally, we strongly encourage New York State to begin a long-range planning process to ensure that certified teachers, appropriate physical space and adequate staff development are available in order to effectively initiate adequate class-size reduction. Moreover, as the State Education Department "establishes criteria to help districts determine when a student lacks reading readiness" (per 1/99 School Executive Bulletin), it is essential that reading teachers be involved in determining specific early literacy skills and strategies unique to individual children. We extend to you the resources and statewide capacity of the New York State Reading Association to assist the Department in this effort.
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Flexibility in Selecting Assessments: NYSRA encourages flexibility for school districts to develop local assessments that meet or exceed the State benchmarks, particularly to support the early identification of students who may fail to achieve proficiency on state assessments.
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Planning and Reporting: NYSRA understands the Department's need for local accountability. However, requiring districts to develop local AIS implementation plans approved by local Boards of Education and updated biennially places another unfunded mandate on local districts. When the New Compact for Learning was initially proposed, the "how" or means of achieving higher standards was to remain at the district's discretion. We are concerned about the increasing amount of paperwork and record-keeping required at the local level. Each new regulation seems to be the springboard for yet another reporting form or data collection. While we appreciate the need to monitor implementation and progress toward goals and the need to share useful information with the Legislature and the public, we urge consideration be given to alternative forms of reporting or extending reporting timetables. Added to this is concern that more and more administrative activities are being brought before local school boards for debate and action. This requires significant amounts of time and preparation
for teachers, administrators and Board members. We would support efforts to consolidate these planning requirements and
reporting elements into the Comprehensive Educational Planning process to -
Use of Regular vs. Extended Time: NYSRA understands the concept behind requiring local districts to first use time available during the regular school day for Academic Intervention Services, while using extended time (before, after and summer school) after regular day program slots have been utilized to capacity. However, we would urge the Department to allow these logistics to be decided at the local level based upon local student needs, resources, schedules and staffing patterns. This is the type of issue that should not be decided at the state level.
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Summer Programs/Resources: The State must appropriate funds for expanding summer program offerings. If we are to proceed aggressively with summer school programs, the resources must be there to underscore this priority and to increase the likelihood of school districts implementing summer programming, particularly K-8. In addition, funding reimbursements must be available to support transportation for students participating in summer programs.
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Certified Staff: NYSRA strongly supports the requirement that appropriately certified staff be available to provide services offered under "AIS." Moreover, we strongly urge that only certified reading teachers and/or certified English Language Arts teachers provide instruction to students who are at risk of failing to achieve the English Language Arts standards.
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Early Identification: NYSRA continues its long-term support for identifying at the earliest ages possible those children who are experiencing difficulties with beginning reading skills. If children are unable to read at grade level by the 4th grade, they will experience extreme frustration in achieving the higher standards contained within the new 8th grade assessments and the
Regents examinations. We support the proposal to provide early identification of reading deficiencies requiring AIS resources by the 3rd grade. Only through such early intervention can we hope to offer these children the reading skills and strategies needed to increase their potential for reaching grade level standards by 4th grade. That initial identification simply should not and cannot take place as late as the 4th grade. -
Parent Notice/Involvement: NYSRA supports the concept of notifying parents when their children/students enter and exit "AIS" services, providing justification for the intervention activities and explanations of their child's progress. However, the department's proposal for quarterly reporting will take valuable instructional time to satisfy reporting mandates. It would be sufficient to allow teachers to include a brief annotation on the regular classroom report card rather than impose yet another entirely new report. While the State can suggest reporting mechanisms, we advocate local flexibility in this reporting process.
Additionally, the New York State Reading Association would take this opportunity to offer our support and/or comments on several recommendations of the Safety Net Study Group:<
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we support the requirement that school districts have an assessment system for each grade level. Districts should have the option of whether that will be a local assessment, a standardized or diagnostic test, or informal procedure. For example, we support the concept of the SED-developed Early Literacy Profile. However, it is difficult to be supportive of a document when our Association has not been involved in either the preparation or review of this specific literacy profile. Here again, we urge the department to utilize the resources and capacity of the New York State Reading Association in these efforts;
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we support the requirement that school districts must offer extra time/extra help to enable students to meet the new standards;
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we support, with reservation, the requirement that school districts must provide professional development focused on the new standards and the new assessment requirements. Our reluctance lies in the need for the state to provide additional and substantial financial resources to support every school district in this area. One approach would be to add at least two additional professional development days to school calendars to allow for staff training to be funded through State Aid.
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we urge the department to "suggest" rather than "require" districts to create plans for student promotion from grade-to-grade. Moreover, the Department should contribute to this effort by offering technical assistance and best practice examples to schools faced with difficult situations relative to promotion. For instance, how do districts deal with the situation of a 16-year old student in the 8th grade? This will become a reality as students fail to achieve both grade level and content standards.
We hope these comments and recommendations are useful in the review and revision of the changes being proposed under Part 100 and the Academic Intervention Services initiative. Please feel free to contact us directly or to contact our representatives in Albany at CARR Public Affairs, Inc., at 518-434-8830.
Sincerely,
Dorothy Troike, President
Maureen Goodwin, Governmental Affairs Chair
c.c.: Honorable Members of the Board of Regents
Hon. John Kuhl
Hon. Steven Sanders