The Honorable Tom HarkinThe Honorable Michael Enzi

ChairmanRanking Member

Senate HELP CommitteeSenate HELP Committee

428 Dirksen Senate Office Building835 Hart Senate Office Building

Washington, DC 20510Washington, DC 20510

May 5, 2010

Dear Chairman Harkin and Ranking Member Enzi:

On behalf of the 30,000 members of the National Association of Secondary School Principals (NASSP), I would like to submit the attached comments regarding reauthorization of the Elementary and Secondary Education Act (ESEA) and share our reaction to the blueprint released in March by the U.S. Department of Education.

The era of reform ushered in by the No Child Left Behind (NCLB) Act of 2001 required principals and assistant principals to excel as instructional leaders working collaboratively with a variety of constituent groups. It is no longer sufficient to deplore the achievement gap; school leaders must be able to make decisions to improve teaching and learning for all students or face corrective action if their schools fail to meet mandated accountability measures. Closing the achievement gap and increasing student achievement are certainly among the highest educational priorities of secondary school principals, and our members accept accountability for results. We have seen gains in student achievement that can be directly related to the law and to the emerging conversations about improved student achievement.

Yet, while embracing the intention of the law, NASSP members have expressed concerns about the consistency, flexibility, and fairness with which the law has been implemented as well as the law’s provisions to help schools build or enhance capacity among teachers and leaders to meet student achievement mandates. In October 2004, NASSP formed a 12-member task force made up of principals and post-secondary educators to study the effects of NCLB on school leaders in the nation’s diverse education structure. The recommendations released by our task force in June 2005 addressed the disconnect that exists between policy created in Washington, DC, and the realities that affect teaching and learning in the school building. NASSP strongly believes that our ESEA recommendations reflect a real-world, commonsense perspective that will help to bridge that gap and clear some of the obstacles that impede principals and teachers as they work together to improve student achievement and overall school quality and close the achievement gap.

Our recommendations address the following issues:

♣National standards

♣School leadership

♣Literacy

♣School turnaround

♣High school reform

♣Middle level reform

♣Graduation rates

♣Growth models

♣Multiple measures of student performance

We hope that you will take these recommendations into consideration as you develop legislation to reauthorize ESEA. If you have any questions or concerns regarding our priorities, please contact Amanda Karhuse, NASSP Director of Government Relations, at 703-860-7241 or karhusea@principals.org.

Sincerely,

Gerald N. Tirozzi, Ph.D.

Executive DirectorNational Standards

NASSP is an endorsing partner of the Common Core State Standards Initiative (CCSSI), and we would support the development and implementation of common, high-quality assessments aligned with the consortium’s common set of K-12 standards.

The NASSP Board of Directors approved a position statement in support of national standards in May 2008: http://www.principals.org/Content.aspx?topic=57526. In the position statement, we call on Congress to appoint an independent, diverse group of researchers, practitioners, advocates, and experts to develop a common set of national standards and authentic, reliable assessments beginning with English/language arts and mathematics in grades K-12 and examine the feasibility of national standards in other subjects. We also urge the Department of Education to evaluate the progress being made by states on a regular basis and issue progress reports.

As a condition for receiving Title I funding, the administration’s blueprint would require states to adopt college- and career-ready standards in English language arts and math either by working with their own institutions of higher education to raise standards or by participating in the CCSSI. While we remain committed to raising academic standards, NASSP does not believe that Title I funding should be used as a negotiating chip for state adoption of these standards. We urge Congress to instead create an incentive pool of funds that would entice states to adopt high standards.

But raising academic standards alone is not enough to ensure that all students, especially low-income and minority students, will graduate from high school and succeed in postsecondary education and the workforce. Supports must be in place to help schools ensure that all students achieve this goal.

NASSP recommends that the federal government should offer incentives for states and districts to develop graduation requirements that allow students to choose from multiple pathways to graduation, including career and technical education courses that are aligned with higher standards, Advanced Placement and International Baccalaureate programs, dual-enrollment programs, and early college high schools. The federal government should also ensure that students have access to academic supports that will help them stay on track toward graduation. These supports could include counseling services that provide information and assistance about the requirements for high school graduation, college admission, and career success; targeted and tiered interventions for middle level and high school students who are falling behind; online learning opportunities; extended learning; job shadowing, internships, and community service; and in-school and community-based social supports, such as counselors, social workers, and mental health services.

School Leadership

The renewed emphasis on school-level outcomes and student achievement places the school leader at the center of all school reform efforts. Today’s principals and assistant principals are expected to be visionary leaders, instructional experts, building managers, assessment specialists, disciplinarians, community builders, and more; they are also the ones ultimately held responsible for student achievement. The Wallace Foundation finds that leadership is second only to classroom instruction among all school-related factors that contribute to student learning, especially in high-need schools. Yet, federal funding priorities have ignored the vital role of the principal in influencing student success.

If principals and assistant principals are to meet the growing, ever-changing expectations of this demanding position, they require continual professional development personalized to meet their individual needs. This is true for all school leaders, regardless of their initial preparation or their length of service. Today’s educational environment of standards-based education and high accountability demand that principals are knowledgeable and skilled in instructional leadership, organizational development, community relations, and change management. Ongoing, job-embedded professional development is the key to developing this capacity in all school leaders.

NASSP supports the proposed $3.9 billion investment in teachers and school leaders that was included in the administration’s FY 2011 budget request. The proposal includes a new $170 million dedicated funding stream for the recruitment, preparation, and retention of effective principals and school leadership teams for the purposes of increasing student achievement in low-performing schools.

In the event that ESEA is not reauthorized this year, NASSP also supports the proposed $50 million increase for the School Leadership program; however, $79.2 million is insufficient to meet the professional development needs of principals and assistant principals serving in high-need schools. The School Leadership program is the only federal program that focuses solely on recruiting, mentoring, and training school leaders. Grantees can use the program funds to provide financial incentives to aspiring new principals, provide stipends to principals who mentor new principals, and carry out professional development programs in instructional leadership and management.

Although recruiting, training, and retaining school leaders is an allowable use of funding under Title II of ESEA, the National Staff Development Council reports that only 4% of the funds are being used by states for this purpose. NASSP encourages the administration to make these activities a mandatory use of funding under Title II with a minimum annual appropriation of $200 million. In addition, we recommend that school improvement plans include the development and implementation of programs that provide induction and support for principals and assistant principals during at least their first 3 years of employment.

Many of our recommendations are incorporated into the School Principal Recruitment and Training Act (H.R. 4354/S. 2896). The bill would authorize a grant program to recruit, select, train, and support aspiring or current principals with track records of transforming student learning and outcomes, and prepare these principals to lead high-need schools. Selected aspiring principals would be provided with a pre-service residency that lasts for at least 1 year, combined with focused coursework on instructional leadership, organizational management, and the use of data to inform instruction, as well as ongoing support and professional development for at least 2 years after the aspiring principals complete the residency and commence work as a school leaders. Grant funds would also be used to provide mentoring and professional development to strengthen current principals’ capacity in the areas of instruction, supervision, evaluation, and development of teachers and highly effective school organizations.

NASSP also supports the Instructional Leadership Act (H.R. 5172). This bill would authorize $100 million for a new grant program to develop innovative programs that train principals in instructional leadership skills, and to help states incorporate standards of instructional leadership into their principal certification or licensure requirements. The bill would also authorize funds for high-need districts and district partnerships with nonprofit education organizations or institutes of higher education to develop state-of-the art principal induction programs. Additionally, the bill requires the Department of Education to develop a definition for highly qualified principal (HQP). Building upon a position statement approved by the NASSP Board of Directors in July 2009 (www.principals.org/hepstatement), the HQP definition should take into consideration the need for principals to:

♣Demonstrate the knowledge, skills, and attitudes needed to effectively lead teaching and learning in schools;

♣Engage in continual professional development, using a combination of academic study, developmental simulation exercises, self-reflection, mentorship, and internship; and

♣Demonstrate the capacity to lead the establishment and maintenance of a professional learning community that effectively uses real time student performance data, including state academic assessments that inform instruction, focus review, and target remediation for the purposes of ensuring standards and course content mastery and personalized instruction for every student..

In the position statement on highly effective principals, we recommend that school districts examine quantitative and qualitative data pertaining to both academic and nonacademic indicators in their evaluation of principals. The following measurements, in addition to student indicators, are recommended for assessing principal performance: self assessments; supervisor site visits; school documentation of classroom observations and faculty meeting agendas; climate surveys; teacher, other school staff, parent, and student evaluations; teacher retention and transfer rates; and opportunities for student engagement through co-curricular and extracurricular activities and rates of participation.

In the Senate, the Teacher and Principal Improvement Act (S. 3242) would identify the needs of teachers and principals to provide targeted professional development, support, and training to increase their skills and drive student achievement. To accomplish this, the bill would authorize $1 billion in grants to states and districts to develop and implement high-quality effective support coaching and professional development for principals and other school leaders that would include an induction program for at least 2 years after a principal begins full-time employment at a school. The professional development component would focus on planning and articulating a shared and clear schoolwide direction, vision, and strategy for achieving high standards of student performance; managing and supporting a collaborative culture of ongoing learning; ensuring quality evidence of classroom practice; communicating and engaging parents, families, local communities and organizations, and institutions of higher education to ensure the vertical alignment of student learning outcomes; and collecting, analyzing, and utilizing data and other tangible evidence of student learning and classroom practice.

The Teacher and Principal Improvement Act would also require school districts to develop and implement rigorous, transparent, and equitable principal evaluation systems. These systems would provide formative, individualized feedback to principals on areas for improvement and target support and interventions to these areas. The evaluation systems would be based on multiple measures of student learning and leadership skills, including planning and articulating a shared and coherent schoolwide direction and policy for achieving high standards of student performance; identifying and implementing a rigorous curriculum; supporting a culture of learning and professional behavior; communicating with and engaging parents and families; and collecting, analyzing, and utilizing data for continuous improvement in student learning and classroom practice.

In measuring a principal’s performance based on student indicators, NASSP recommends that states should use multiple assessments that are aligned with common standards, include performance-based measures, and measure individual student growth from year to year. NASSP suggests the following student indicators: state assessments; portfolios, performance tasks, and other examples of a student’s accomplishments; traditional quizzes and tests; interviews, questionnaires, and conferences; end-of-course exams; comprehensive personal academic or graduation plans; assessments aligned with high school and college entrance requirements; and senior projects.

NASSP is currently working with the National Board for Professional Teaching Standards to develop a voluntary national certification for successful, experienced principals, assistant principals, and teacher leaders known as National Board Certification for Educational Leaders (NBCEL). Having a set of standards that define best practices allows the development of professional education that is targeted for the continuum of practice. As school leaders engage and reflect on their level of practice and for those who hold the responsibility for preparing leaders, the standards continuum offers the profession a much clearer view of the requirements of successful practice. As school districts seek to select and develop principals, assistant principals, and teacher leaders that can lead the transformation of schools, the existence of a continuum of standards to assist and identify accomplished practice is hugely beneficial in the selection, training, and development of aspiring and practicing principals, assistant principals, and teacher leaders.

NASSP plans to create and deliver a well recognized and comprehensive professional development program leading to improved practice and to achievement of the NBCEL advanced certification.  The program will consist of products and services that will engage practicing principals in substantive developmental experiences. The federal government should support this effort by offering grants to states, districts, and nonprofit organizations to assist in the development of the NBCEL standards; provide a comprehensive professional development program aligned to the NCBEL standards; and promote outreach, recruitment, subsidies and support programs for candidates.

Literacy

Literacy development is an ongoing process, beginning in early childhood and continuing through elementary and secondary school. Even before the beginning of formal schooling, children from low-income families are less likely than students from higher-income families to recognize letters and understand the relationship between letters and sounds. Without intervention, disparities in educational outcomes persist throughout elementary school and beyond. According to the National Assessment of Educational Progress, more than two thirds of all fourth and eighth graders are not proficient readers, and these students are disproportionately poor and minority. Further, researchers at ACT have found that, absent strong intervention, eighth-grade academic achievement is highly predictive of college and career readiness at graduation.

The FY 2011 budget proposed $450 million for a new birth through grade 12 literacy program. While we are pleased that the administration has chosen to focus on literacy as a key path for increasing student achievement, we are concerned that the proposal would eliminates funding for a number of unique programs such as the National Writing Project, Even Start, Literacy through School Libraries and Reading is Fundamental. These national initiatives compliment literacy instruction nationally through separate, yet related activities, such as sustained, high-quality professional development, family outreach and book distributions for low-income children.

We strongly feel that the creation of a new comprehensive, literacy program that spans the grade levels and is integrated across the curriculum is vital, and that this new program should be created through the Literacy Education for All, Results for the Nation (LEARN) Act (H.R. 4127/S. 2740). The bill would authorize comprehensive state and local literacy initiatives and build on the best components of the federal Early Reading First, Reading First, and Striving Readers programs. Districts would support schoolwide literacy initiatives that include professional development for principals and teachers to incorporate literacy across the curriculum and targeted interventions for struggling students. Districts could also use grant funding to hire literacy coaches or to implement a multi-tier system of supports.

The goals of the LEARN Act are very much in line with Creating a Culture of Literacy: a Guide for Middle and High School Principals, which NASSP released in 2005. This guide was written for principals to use as they team with staff members to improve their students’ literacy skills by assessing student strengths and weaknesses, identifying professional development needs, employing effective literacy strategies across all content areas, and establishing intervention programs for struggling students.

School Turnaround

Under the administration’s blueprint, the lowest-performing 5% of schools in a State would be identified as “Challenge Schools” and would be required to implement one of the four turnaround models that all require the principal’s replacement as a condition for receiving school improvement funds. NASSP opposes the misguided models for school reform and urges Congress to instead embrace meaningful middle level and high school reform strategies.

When the School Improvement Grants (SIG) guidance was first released in August 2009, we urged ED officials to reconsider the four proposed models that all require the principal’s replacement as a condition for receiving SIG funds. We believed that the Transformation Model provided the greatest hope for promoting genuine school improvement as it was built around the continuous use of data to inform instruction, developing teacher and leader effectiveness through high-quality professional development, reforming instructional strategies, and extending learning time. It also contained provisions that would give the school flexibility and support to implement reform efforts.

But we had a major concern that this model also called for replacing the principal before beginning these efforts. NASSP strives for excellence in middle level and high school leadership, and anything less compromises the whole profession. We are not interested in defending substandard principals, and it might be true that the principal in some of these lowest-performing schools is the agent of stagnation that has to go before real progress can commence. But there are many other factors that affect student learning and low performance.

We encouraged the Department to first urge school districts to conduct a comprehensive evaluation of the principal’s performance to determine his or her capacity and will to address his or her own professional development needs as they relate to student learning. We also reiterated our long-standing support for a dedicated funding stream of $100 million in Title II of ESEA to recruit, train, and mentor principals and assistant principals.

NASSP has spent the past decade identifying and examining schools that succeed despite challenging circumstances. The common lessons have been condensed down to a framework called Breaking Ranks, which includes a set of recommendations to be considered in each school’s unique context. This comprehensive framework for middle and high schools encourages principals to foster collaborative leadership and ongoing professional development that continually improves curriculum, instruction, and assessment in an environment that is personalized for each student.

The Breaking Ranks framework has been repeatedly validated by diverse, high-poverty schools that share a commitment to student achievement and have seen growth over time in such measures as graduation rates, state assessment scores, and literacy and numeracy achievement. And each Breakthrough School that implements this framework reminds us all that turning around a school takes at least three-to-five years of time-consuming, resource-intensive, hard work.

As Congress works to reauthorize ESEA, we encourage you to support proposals that would strengthen current law by providing the support necessary to turn around our nation’s lowest-performing middle and high schools and give our struggling students the help they need from preschool through graduation.

High School Reform

NASSP is a national leader in high school reform and in 2004, created a framework upon which to improve our nation’s high schools called Breaking Ranks II: Strategies for Leading High School Reform. The handbook offers successful research-based practices, real-life examples of high schools at various stages of reform, a step-by-step approach to lead change, obstacles to avoid, and resources from which to draw. NASSP offers Breaking Ranks for all high school principals, regardless of school size, geographical location, or where they are in the school improvement process.

High schools have historically been the forgotten stepchild of school reform efforts and, for far too long, have not received an adequate share of funding and other resources from the federal government. But successful high school reform requires real strategies and significant resources for implementing systemic improvement and raising individual student and schoolwide performance levels. This is why NASSP supports the Graduation Promise Act (H.R. 4181/S. 1698), which would support the development of statewide systems of differentiated high school improvement that focuses research and evidence-based intervention on the lowest performing high schools, and improves the capacity of the high schools to decrease dropout rates and increase student achievement. The bill would also provide competitive grants to states to identify statewide obstacles hindering students from graduating, and provide incentives for states to increase graduation rates.

Middle Level Reform

Although much attention has been focused on high school reform, NASSP urges the administration to also address the more than 2,000 middle level schools that feed into the nation’s “dropout factories”—those high schools graduating fewer than 60% of their students. High school reform will never succeed in a vacuum, and many of these middle level schools are in need of the same comprehensive whole-school reform that is offered to high schools under the Graduation Promise Act.

The future success of ESEA rests largely on the shoulders of middle level leaders, teachers, and students. Students in grades 5 through 8 represent 57% (14 million) of the nation’s annual test takers under ESEA, but middle level schools are not receiving adequate federal funding and support to help these students succeed. We recognize that the majority of districts choose to funnel their Title I funds into early childhood and elementary programs, and while we fully support continuing the drive to help students succeed in these grades, the needs of struggling students in our lowest-performing middle schools must not be ignored. If Title I funds were distributed on the basis of student populations, middle level schools (representing 23% of the nation’s student population) would receive approximately $2.92 billion of the current Title I allocation. Yet, of the $12.7 billion appropriated in FY 2005 for Title I, only 10% is allocated to middle schools.

Therefore, I strongly urge the administration to support the Success in the Middle Act (H.R. 3006/S. 1362), which was introduced in the last Congress by President Obama. Under the bill, states are required to implement a middle school improvement plan that describes what students are required to know and do to successfully complete the middle grades and make the transition to succeed in an academically rigorous high school. School districts would receive grants to help them invest in proven intervention strategies, including professional development and coaching for school leaders, teachers, and other school personnel; and student supports such as personal academic plans, intensive reading and math interventions, and extended learning time.

NASSP believes the comprehensive middle level policy articulated in the Success in the Middle Act is necessary to address the realities that only 11% of eighth-grade students are on track to succeed in first-year college English, algebra, biology and social science courses (ACT, 2007), fewer than one-third can read and write proficiently, and only 30% perform at the proficient level in math (NAEP, 2005). Enacting the Success in the Middle Act hand-in-hand with the Graduation Promise Act would strengthen ESEA by providing the support necessary to turn around our nation’s lowest-performing middle and high schools and give our struggling students the help they need from preschool through graduation.

Graduation Rates

NASSP supported the final Title I regulation that requires States to use a uniform and accurate method of calculating graduation rates consistent with the definition adopted by the National Governors Association in 2005. We have long advocated for such a formula to counter the confusion and inconsistencies in current graduation-rate calculations that make it impossible to compare state performance and blur any views of a nationwide graduation rate.

However, NASSP does have concerns with defining the graduation rate as the “four-year adjusted cohort graduation rate.” Because not all students enter the ninth grade reading and writing at grade level, we have long recommended that the graduation rate be extended to within at least five years of entering high school. NASSP supported language in the 2007 Miller-McKeon discussion draft on ESEA reauthorization that would have allowed an extra-year adjusted cohort rate. Under the proposal, a high school could make adequate yearly progress (AYP) if the graduation rate increased an average of 2.5% per year for the four-year adjusted cohort rate or 3% per year for the extra-year adjusted cohort rate.

State should be required to use, as a supplement to the four-year adjusted cohort graduation rate, extended adjusted cohort graduation rates that are approved by the Secretary. In addition, identified special-needs students who complete high school with a state-approved exit document should have until age 21, inclusive, to be counted as graduates as defined by the Individuals with Disabilities Act. The Miller-McKeon Discussion Draft would have allowed a student who has significant cognitive disabilities to be counted as a graduate upon receipt of a regular high school diploma or State-defined alternate diploma aligned with the completion of the student’s entitlement under the Individuals with Disabilities Education Act (IDEA) and consistent with state law. NASSP supported this proposal.

Designating a four-year timeframe within which students must exit and graduate from high school goes against what we know about student learning, especially for English language learners, and timelines designated by IDEA. In fact, we should be moving in the opposite direction by allowing students additional time to graduate if they require it without penalizing the school, or less time if they have reached proficiency.

Student performance should be measured by mastery of subject competency rather than by seat time. States that have implemented end-of-course assessments are on the right track and should be encouraged to continue these efforts. And federal law should reward students who graduate in fewer than four years—which could encourage excellence—rather than simply acknowledge minimum proficiency, and the recognition of high-performing students could help schools that are nearing the target of 100% proficiency.

Growth Models

States should be allowed to measure AYP for each student subgroup on the basis of state-developed growth formulas that calculate growth in individual student achievement from year to year.

Using a single score to measure whether a student is making progress ignores many issues, primarily the academic growth of the individual student. Yet current law requires that schools focus on grade-level growth as opposed to individual student growth by requiring schools and districts to compare performance for different groups of students each year. Under NCLB, schools must measure growth of this year’s seventh-grade students against the scores of the past year’s seventh-grade students. Such systems do not take into account differences in the groups of students and do not tell us whether our instruction has resulted in individual student growth.

In addition, focusing on a cut score may encourage a school to concentrate only on students who are close to meeting that goal and not on the education of those students who may have the greatest need. Individual student growth, reported over time from year to year, gives teachers and administrators the best possible data about whether the instructional needs of every student are being met.

NASSP has been very pleased with the expansion of the growth model pilot program, and we hope that growth models will have a permanent place in a newly reauthorized ESEA.

Multiple Measures of Student Performance

States should be allowed to use multiple measures of student performance in determining AYP, including state assessments in subjects beyond reading and language arts, mathematics, and science; portfolios, performance tasks, and other examples of a student’s accomplishments; traditional quizzes and tests; interviews, questionnaires, and conferences; end-of-course exams; comprehensive personal academic or graduation plans; assessments aligned with high school and college entrance requirements; and senior projects. Student assessment given on a regular, consistent basis allows schools to analyze what students have or have not learned. And teachers can then develop effective strategies that address individual students’ academic weaknesses and build upon student strengths diagnosed by the assessments.

To view standardized test results as a measurement of a school’s success or failure, as the law currently does, misses the broader point. The purpose of assessment should be to inform instruction and improve learning. Assessments that produce diagnostic data, and not just a “score,” give educators a direction for increasing student success—individually, student by student. Hold educators accountable, but ensure that they have the resources, the preparation, the training, a strong curriculum, and useful assessment data to get the job done. If we can do that, then all our students will achieve, and our schools will have truly passed the test.