May 14, 2011

Governor Cuomo’s letter to the Chancellor of the Board of Regents regarding performance evaluations for teachers

Governor Cuomo’s letter to the Chancellor of the Board of Regents regarding performance evaluations for teachers
Source: Office of the Governor

On May 13, 2011 Governor Andrew M. Cuomo sent the following letter to the Chancellor of the Board of Regents Merryl Tisch regarding changes needed to improve and accelerate performance evaluations for teachers.

The Governor's full letter is as follows:

Dear Chancellor Tisch:

Performance is the key to education. It's not about how much we spend, but the results that matter. As data show our education spending hasn't resulted in performance. New York schools spend 71 percent more than the national average, yet rank only 40th in graduation rates and 34th in the nation in the percentage of adults who have a high school diploma or the equivalent.

We must focus on measures and accountability. That is why the State Education Department's ("SED") current process to develop a teacher and principal evaluation system is critically important. We not only need a strong evaluation system that will improve the performance of our children, but also to support our educators so they can continually develop and improve. Our goal should be to have the best system of evaluation in the nation, yet our proposed system falls short of other states, such as Colorado and Tennessee.

What SED establishes today will have a lasting effect for decades to come so it is imperative it's done correctly. The current Draft Regulations for Teacher and Principal Evaluation ("Draft Regulations") that were recently issued, however, need revision if we are to implement a system that will be the building blocks to greater performance in our education system.

Although there are a number of details in need of improvement, we recommend SED make the following comprehensive changes:
    · Increase the percentage of statewide objective data, like measuring student growth on statewide test scores, used to evaluate teacher performance; · Impose rigorous classroom observation and other subjective measures standards on school districts when evaluating teacher performance; · Require a positive teacher evaluation rating be given only when the teacher receives a combined positive rating on both subjective and objective measures, such as student growth on statewide tests; and, · Accelerate the implementation of the evaluation system.

These are discussed in more detail below and, if implemented, will greatly strengthen the evaluation process.
    · First, remove the explicit language prohibiting the same measure of student growth on state assessments from being used for locally-selected assessment measures and state measures simultaneously

The Draft Regulations explicitly bar a school district from using the same measure of student growth on the same assessment for both the state assessment subcomponent and the locally-selected measures subcomponent. We believe such a prohibition is unnecessarily restrictive because it precludes a school district from using the objective state-developed growth measure for the locally-selected measures.

The Draft Regulations should be amended to permit the same student growth measure be used for the state assessment and locally-selected measures. By removing this prohibition in the Draft Regulations, up to 40 percent of the total score could be based on objective student growth measures on state tests—a percentage that is closer to many other states.

This change would ensure that greater balance is struck between using objective teacher evaluation measures, such as statewide testing, and subjective teacher evaluation measures, such as classroom observation. Given that the subjective measures have far greater weight under the evaluation process system, it is imperative that the Draft Regulations adopted do not explicitly reduce the types of objective assessments, such as growth on state tests, available to be used.
    · Second, impose additional standards on school districts to improve the 60 percent of locally-developed rubric requirements, such as the observation process, to make evaluations more rigorous
The Draft Regulations must be strengthened and better defined to make the 60 percent subjective criteria to evaluate teachers more valuable. Already, New York is an outlier as compared to other states in that it requires more weight be given to subjective measures when rating teachers. Therefore, it is critical that the Draft Regulations include greater precision and impose clear standards.

For example, under the Draft Regulations, half of the 60 percent of the locally-developed rubric must be based on classroom observation. Studies have shown that a rigorous evaluation program based on classroom observation is a significant component in promoting student achievement growth. As such, the classroom observation requirement should be increased from half to at least 40 percent of the 60 percent total of the locally-developed rubric.

Moreover, the Draft Regulations should establish baseline standards to make classroom observation a more meaningful measure. At a minimum it is vital that the Draft Regulations require multiple annual observations and include criteria for using third party observers.
    · Third, require a positive teacher evaluation rating be given only when the teacher receives a combined positive rating on both subjective and objective measures, such as student growth on statewide tests
As was discussed above, under the Draft Regulations, objective measurements (e.g. state assessments) have lower weight than subjective measurements to evaluate teachers. In addition, there is no guarantee that objective measures have much meaning in the currently proposed scoring bands. In essence, a teacher could receive a positive rating, such as "developing", based only on subjective teacher evaluation measures.

Other states, such as Delaware and Rhode Island, require "effective" ratings in both the subjective and objective testing measures in order for a teacher or principal to receive an overall "effective" rating. No such requirement exists under the Draft Regulations and therefore diminishes the weight given to objective measurements in the evaluation process. Therefore, at a minimum, the scoring bands should be adjusted to give greater weight to the objective measures by not allowing a positive rating based on subjective measures alone. As an alternative, it is recommended that a teacher or principal be rated "effective" in both objective and subjective categories in order to receive an overall "effective" or "highly effective" rating.
    · Fourth, accelerate the timetable of implementing the evaluation system

I appreciate your assistance in accelerating the process so the evaluation system could be implemented for all teachers prior to the full implementation deadline of the 2012-13 school year. However, we must make sure that school districts begin the process in an expeditious manner. Endless implementation delays will hamper our ability to ensure our children are getting the best education, because a system not implemented is of no use.

Since SED has articulated the criteria for implementing the entire teacher and principal evaluation system, schools districts should fully implement the teacher and principal evaluation system for the 2011-12 school year and therefore the Draft Regulations should authorize school districts to do so.

Finally, my Administration will aggressively seek to incentivize schools districts to implement the evaluation system expeditiously. Therefore, only those districts that actually perform, and implement the teacher and principal evaluation system, would be eligible for the Executive's School Performance Incentive Program—a $500 million program—that I included in the Executive Budget. School districts would potentially lose millions of dollars on state awards for failure to implement the system quickly.

We must not squander the opportunity to set the right course and make New York a leader in evaluating performance in our education system. If done correctly we will revive our education system to ensure students perform better and succeed in their future careers. The recommendations above will help set the course. Now is our chance to make New York a leader in education performance.

Andrew M. Cuomo