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comprehensive analysis of specific district and site strengths and needs. The district, site and external advisors should collaborate to analyze needs and plan interventions that target these identified needs. Flexibility regarding state Education Code requirements should be provided as needed based on identified needs of the district and school.


 The determination of a need for interventions should be based on multiple years of performance data indicating insufficient progress in raising student achievement and closing achievement gaps as well as analysis of local conditions and improvement strategies.


 Incentives and interventions must be evidence-based, sustained over multiple years, and free from political practices and priorities.


Reward and Challenge States, Districts and Schools


Rewarding states, districts and schools that achieve goals set forth in the plan is a step in the right direction, but California’s experience in this effort in the late 1990s found the state did not sustain rewards over time. In fact it was just one year under our Academic Performance Index (API) that rewards were distributed. We urge that if you commit to a rewards model you commit to a long-term balance between support, interventions and rewards; holding all three elements of accountability equal in importance.


In regards to the proposed “Challenge” districts and schools, a focus on the lowest 5 percent has merit; however, the four prescriptive models and the removal of the district superintendent is too limited and in some cases excessively punitive. The models are particularly problematic for collective bargaining states. ACSA proposes allowing districts and states to implement an additional rigorous “fifth option” that can meet the principles of the Blueprint but reflect more accurately the needs of individual school and district communities. This fifth option would be approved on a “case by case” approach at the state level. The fifth option would honor the right of the local district superintendent to determine where they place principal leaders. It’s also important to recognize constraints placed on collective bargaining states. The concept the federal government leverages ESEA to remove district superintendents is not needed, as superintendents are already held accountable by, and can be removed by, local governing boards. In addition district superintendents oversee all aspects of a school district not just one grant program. More detail is necessary to comment on the concept of Challenge schools and districts with persistent achievement gaps.


A theme throughout Challenge schools and districts is the concept of expanded or extended learning time for students. We support this strategy, but remind Congress this requires a significant financial commitment not available to states such as California in severe budget crisis. Extending the day or year takes ongoing sustained funding not offered in the Blueprint.


School Turnaround Grants


The focus in the Blueprint on effective quality review teams is already embedded in California’s accountability system through the School and District Assistance and Intervention Teams (SAIT and DAIT). We have learned many lessons in terms of the importance of community, school and district buy-in and capacity building. Where we differ with the Blueprint is that the four intervention models or “cures” lack confirmed research. We strongly oppose the premise that in all four models the removal of the principal is the silver bullet, or the best approach to school reform.


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