Summary of Public Comments and Agency Responses Related to Proposed Amendment to 19 TAC Chapter 97, Planning and Accountability, Subchapter AA, Accountability and Performance Monitoring, §97.1001, Accountability Rating System
Comment: Cypress-Fairbanks Independent School District (ISD) commented that the minimum performance floor to use the Exceptions Provision to "gate up" to Academically Acceptable should be re-set from five percentage points below the standard to ten percentage points below the standard.
Agency Response: The agency disagrees and maintains language as published as proposed for 2011. In 2008, the Exceptions Provision was modified in many ways, including a modification of the minimum performance floor values required for mathematics and science from five percentage points to ten percentage points. This proved to be a one-year change because in 2009 the minimum performance floor returned to five points below the standard for all subjects. Though the removal of the Texas Projection Measure (TPM) feature from the system will likely prevent many districts and campuses from achieving a higher rating, relaxing the performance floor for the Exceptions Provision is not appropriate. The districts and campuses that would benefit from the expanded performance floor are, by definition, more than five percentage points below the accountability standard. Also, these campuses and districts did not show sufficient improvement from the prior year to meet Required Improvement; most, in fact exhibited declines in performance. Lower floors for mathematics and science exceptions increase gaps in accountability standards. Decreasing the exceptions floor by an additional five percentage points will allow districts and campuses with a passing rate of 50% in science or 55% in mathematics to achieve the Academically Acceptable rating. The minimum performance for reading, writing, and social studies is 65%--a difference of fifteen percentage points when compared to the 50% floor requested for science.
Comment: An individual commented that the rating labels be expanded to award an "Exemplary Commended" rating to campuses and districts that achieve the exemplary standard on TAKS and the commended performance indicators, while campuses and districts that achieve the exemplary standard on TAKS but do not achieve the commended performance exemplary standard be awarded the "Exemplary" rating.
Agency Response: The agency disagrees and maintains language as published as proposed for 2011. The rating labels are specified in statute and further disaggregations of existing rating categories are not permitted. Locally, districts can make these distinctions.
Comment: A school principal from Brock ISD commented that the Exceptions Provision and Required Improvement features should be available for the Commended Performance indicators that will be evaluated for the first time for the 2011 state accountability ratings.
Agency Response: The agency disagrees and maintains language as published as proposed for 2011. In anticipation of the more rigorous House Bill 3 requirements, the agency maintains that districts and campuses should demonstrate performance at a higher level than Met Standard in order to achieve the Recognized or Exemplary ratings. Since student performance on the end-of-course and the new Grades 3-8 State of Texas Assessments of Academic Readiness (STAAR) tests are unknown at this time, the best proxy available on the current assessment is the commended performance standard. Therefore, the agency maintains that districts and campuses must meet the absolute standards on the Commended Performance indicator of 15% for Recognized and 25% for Exemplary to encourage campuses and districts to focus on the performance of higher performing students, in addition to those not passing the test.
Comment: The Texas Charter Schools Association (TCSA) commented that the Texas Growth Index (TGI) or a similar longitudinal growth measure be incorporated in the TAKS Progress Indicator for both Grades 10 and 11 for charter districts and alternative education campuses that are evaluated under the 2011 alternative education accountability (AEA) procedures. The TCSA stated that the use of the TGI would allow schools evaluated under the AEA procedures to demonstrate their student's continued progress toward meeting minimum standards.
Agency Response: The agency disagrees and maintains language as published as proposed for 2011. In the April 22, 2011, release of the final decisions for 2011 accountability, the commissioner of education determined that the use of the TPM will be discontinued for 2011 state and federal accountability. This decision removed the TPM results for TAKS and TAKS-M and the TAKS-Alt growth measure from the TAKS indicators evaluated for standard procedures and from the TAKS Progress Indicator used for the AEA procedures. The decision also included the discontinuation of the use of the TGI for Grade 11 in the TAKS Progress Indicator. The agency maintains that the uniform removal of these student growth measures from the 2011 accountability ratings provides a level playing field for all districts and campuses regardless of campus type or grade levels served.
For additional information, email email@example.com.