Today’s post comes from Dr. Mary Byrne of the Missouri Coalition Against Common Core.

DESE released the revised PROPOSED RULE 5 CSR 20-100.295 Missouri School Improvement Program 6 for public comment on December 16, 2019

The most recent generation of MSIP (MSIP 5) focuses on student performance [emphasis added] metrics – output measures. The next generation will continue to emphasize standards for student performance, but will also emphasize leading indicators – inputs in economic terms – that will ensure healthy school systems and the continuous improvement process.

In other words, DESE is effectively proposing standards that will diminish local control and centralize school district management at the department level.

DESE’s MSIP 6 webpage describes the difference between its current standards (MSIP 5) and the proposed standards:
 

WHAT YOU CAN DO

ACTION REQUESTED:
 
January 15, 2020 at 5:00 PM the public comment period for DESE’s revised MSIP 6 standards will close. The number of responses DESE receives is VERY important — remember the first proposed rule was withdrawn because DESE received almost 1500 responses.
 
Please send your comments to DESE within the next 5 days by going to the MSIP 6 comment webpage[1] and responding to the overall document as well as individual standards.

The following are sample responses for the complete rule and for several individual standards provides for your consideration. Background information and discussion of the sample comments for complete rule and individual standards may be found in the Appendix of the linked document below.

You may use the sample language below or respond in your own words. Please read the entire proposed rule available on the website to consider other standards for comment.

 Sample comment on the complete rule:

DESE’s proposed MSIP standards change Missouri’s school district accreditation standards to effectively centralize authority over districts at the state level in violation of Missouri law. That is, several proposed standards limit the discretion of local school boards to manage districts and determine personnel needs by requiring boards to structure their purpose and personnel organization in specific ways in order to be accredited.

 Proposed MSIP 6 standards create a double standard in which local districts are held accountable for compliance with state statutes, but DESE evaluators are not accountable for standards that are themselves incompliant with Missouri statutes. Furthermore, word choice used in several standards, for example, stakeholders (which is not defined in Missouri statute and may include non-resident representatives of advocacy organizations) rather than taxpayer (which would require representation of residents), allows DESE evaluators to determine the definition of terms; thereby increasing its power to control the influences affecting policies districts will be compelled to implement to score well on MSIP 6 evaluations.

 Recommended Action: Proposed MSIP standards should be reviewed for alignment with Missouri law and ensure protection of local school board authority.

 Sample comments on individual standards (click on the individual links in the right column of the table on the webpage to insert your response for specific standards):

 L1-B essentially rewrites the Missouri Constitution, changing the legislature’s mandate to provide a free education to children of Missouri as a means of protecting their rights and liberties to assuming responsibilities of parents and charities. The department’s mission creep into areas of individual support of students expands the scope of the state government’s responsibility for the general welfare of the people of Missouri. Changing the wording of the Missouri Constitution involves a process managed by the legislative branch of state government. Proposing standards for the oversight of school districts that do not enforce Missouri’s constitutional law violates the limits imposed on the department by the separation of powers described in Article II, Section 1.

Recommended Action: Delete “and individual support” from L1-B.

_______________________________________________________________________

L4 insertion of the phrase “and well-being” essentially rewrites the Missouri Constitution, changing the legislature’s mandate to provide a free education to children of Missouri as a means of protecting their rights and liberties to assuming responsibilities of caring for children – that is, DESE’s mission creep into areas of individual child well-being expands the scope of the state government’s responsibility for the general welfare of the people of Missouri. Changing the wording of the Missouri Constitution involves a process managed by the legislative branch of state government. Proposing standards for the oversight of school districts that do not enforce Missouri’s constitutional law violates the limits imposed on the department by the separation of powers described in Article II, Section 1.

Recommended Action: Delete “and well-being” from L4.

_______________________________________________________________________

L4-A — The phrase, “and matters of equity” apparently refers to a separate section with the heading Equity and Access (EA) which included in the original proposed MSIP standards that the State Board of Education withdrew in October. The section was eliminated from the currently proposed standards. Therefore, L4-A should only refer to the priorities of L4, which are found in CSIP.

Recommended Action: Delete “and matters of equity” from L4-A.

_______________________________________________________________________

L4-E — While proposed MSIP Standard L4-E appears to hold districts accountable for transparency of fiscal management of contracts, it does not hold them accountable for compliance with state law requiring transparency of comprehensive fiscal management for public scrutiny, which is, posting detailed financial and budgetary information on the district website as per state law. The standard is inadequate for equipping the public to hold local school districts accountable for its management of expenditures.

Recommend Action:  Insert “and transparency in fiscal reporting to the public” before the period at the end of L4 E.

________________________________________________________________________

L6 Missouri statutes 168.201 and 168.205 clearly honor the discretion of local school boards to determine whether to hire or not hire superintendents with the deliberate insertion of “may” in the statutes. Language in L6 assumes the district will have hired a superintendent, and therefore, remove the discretion of local school boards to determine whether to hire a superintendent or share a superintendent with another district – a freedom protected by existing statutes.

            Recommended Action: Delete L6

_______________________________________________________________________

 L6-A RsMO 162.621 stipulates the powers and duties of the elected members of the board of education using the mandatory language shall and comprehensive word all when referring to the board’s function in the administration of the public school system. There is no language in the statute that allows elected officials to delegate responsibilities assigned to them to unelected employees. Furthermore, 168.211 which states, “The superintendent of schools shall have general supervision, subject to policies established by the [local] board,” not subject to policies established by the state board. Rules for district evaluation must not conflict with statutes by insisting on a transfer of power from elected officials to unelected bureaucrats.

 Recommended Action: Delete L6-A

_______________________________________________________________________

L9-C Missouri statutes 168.201 and 168.205 clearly honor the discretion of local school boards to determine whether to hire or not hire superintendents with the deliberate insertion of “may” in the statutes. The hiring of assistant superintendents, as indicated in the heading of the first table in L9-C, assumes the district will have hired a superintendent, and therefore, removes the discretion of local school boards to determine whether to hire a superintendent or share a superintendent with another district – a freedom protected by existing statutes.

            Recommended Action: Delete L6 and the first table in L9-C.

_______________________________________________________________________

 L10-A   RsMO 160.011 does not define the term “stakeholder,” but it does define the term “taxpayer.” Without reference to taxpayers in the standard, stakeholders could be construed to mean members of advocacy organizations who do not live in Missouri and who are committed to an agenda other than the constitutional purpose of public education in Missouri.
 
Recommended Action: Expand language in L10-A to include district taxpayers and parents of enrolled students in the definition so as to ensure representation of parents whose children are affected by the policies of the district.
 
________________________________________________________________________

L10-A.3 could be construed to force districts to pay for clinical care of extended family members of students or other persons outside of the schools’ enrolled students or personnel regardless of the “crisis” they present, potentially putting undue burden on districts by making districts responsible for providing mental health services to any or all members of a community for any reason. DESE is not authorized to force districts or the state to raise public dollars for dispensing a broad range of mental health services to a broad category of consumers.

Recommended Action: Modify L10-A.3 to restrict responsibility of district to provision of mental health support to students, school personnel, and families for school-related crises.

Background information and discussion of the sample comments for complete rule and individual standards may be found in the Appendix of the linked document below
 

MSIP 6 Response

 
Anne Gassel

Anne has been writing on MEW since 2012 and has been a citizen lobbyist on Common Core since 2013. Some day she would like to see a national Hippocratic oath for educators “I will remember that there is an art to teaching as well as science, and that warmth, sympathy and understanding are sometimes more important than policy or what the data say. My first priority is to do no harm to the children entrusted to my temporary care.”

Facebook Twitter