Olivia Fessler

Mrs. Jennifer Sheets
President State Board of Education
65 South Front Street, Room 804
Columbus, Ohio 43215-4183

Dear Jennifer:

When I last wrote to you regarding the new school standards proposed by the State Board of Education, I indicated that successful passage in the legislature would hinge on gaining broad public support. Toward that end, and after carefully considering the standards accepted in principle by the State Board, I have identified a number of concerns that I believe require immediate attention.

Throughout my years as Governor of Ohio, I have repeatedly stressed the fact that our citizens should have greater assurance that they are getting the quality and performance they are paying for. In that regard, I believe Ohioans want specific benchmarks against which to judge the performance of their schools (e.g., graduation rates, attendance rates, proficiency test scores), and the state needs tools of assessment by which to evaluate districts.

As the standard-setting process enters its final phase, I am asking that the State Board give its immediate attention to the following concerns which have been raised:

1. The student competencies are vague and extend too far beyond the skills generally accepted as necessary for lifelong learning. I have reviewed the rationale upon which the Department of Education has based the competencies for the arts, foreign language, vocational education and technology. While there may be merit in developing basic skills in these areas in light of a highly competitive, increasingly technical global economy, it would be helpful to have further explanation about why these disciplines should be required of all students.

This is especially true of vocational education. There are those who strongly object to the vocational education competencies and the development of career plans. They feel that secondary students may be forced into a vocational track and will not receive challenging academic instruction that will best prepare them for life after graduation.

Also, at the same time the new standards clearly "raise the bar" on the basics, they are perceived by many as de-emphasizing the importance of the basics by the inclusion of subject areas that are not viewed as critical to a sound education.

In addition, I understand that it is the Department's view that the adoption of standards must precede the adoption of more specific language on the competencies since it is the standards that will provide the framework and structure for the competencies. Please explain why the development of competencies cannot occur concurrently with the standards.

2. The school performance standards are unrealistic. While the new standards may be reasonable and attainable for the vast majority of districts, it has been suggested that some districts, due to circumstances that are beyond their control (e.g., parental involvement, juvenile crime, economic conditions), will find it extremely difficult to meet the specific performance standards (e.g., graduation rates, proficiency test passage rates) and to show consistent improvement toward those standards.

Whereas current law permits the state to assign a "monitor" to deficient school districts that must authorize local actions based on a corrective action plan, the new standards require an audit to determine whether the district is capable of effectively implementing a corrective action plan. If not, the district will be subject to "direct state control."

Assurances must be given that the intervention recommended by the proposed standards will not erode local control, and that state's direct responsibility for educating students will no; be excessive. As you know, SB 140 authorized the state to identify "educationally excellent" and "educationally deficient" school districts. In my view, this authority has not been used as aggressively as it could have been. We should be identifying such districts in accordance with SB 140 - which allows the state to grant waivers on certain requirements to "excellent" districts as well as "monitor" the state's "deficient" schools - and sharing that information with the public. Either distinction would certainly influence the behavior and performance of a district.

Further, it has been suggested that the new standards relax SB 140, which has never been fully implemented, because (1) it substitutes monitoring for many with direct control of a few, and (2) it allows for districts to be identified as "high improvement" districts, which permits schools that are not quite "excellent" to nonetheless avoid "deficient" status and the oversight that accompanies that distinction. Do the members of the State Board view the new standards and SB 140 as compatible?

3. The reporting requirements will overburden districts. Recent testimony before the Ohio School Funding Task Force suggests that Ohio is a leader among the states with regard to the reliability and depth of data we gather on our school districts. While it may be legally necessary and statistically valuable to extend our efforts further, please provide assurances that the data required by the new standards will not unduly burden districts. I cite, for example, the requirement that data be demographically reported and standards be demographically met.

Also, I understand that a district's performance will be based on three-year averaging, and that a district is not required to establish corrective action for poor performance until it fails to reach any one of the state's new standards based on that average. It is possible, therefore, that a district may be in non-compliance with the new standards for up to two years before the three-year average would reflect it and corrective action would be required. I would recommend that a notice be communicated to a district with the first evidence of its non-compliance together with an offer of assistance. This positive rather than punitive approach may be sufficient to help a district avoid noncompliance and the intervention that would follow.

On a related matter, I noted that each district is to benchmark its performance on the new standards and then to annually report to the public its improvements against those standards. I believe it would be just as instructive to the public for us to collect and then report in a like manner the performance of the state system of education in the aggregate.

4. The manner of instruction is vague. The new standards correctly place the emphasis on student performance and ask students to demonstrate the skill and knowledge that has been identified for each grade. The new standards do not eliminate the use of Carnegie units by local schools, but lifting the requirement for such units from the standards does cause some concern. Students and their parents, educators and administrators, employers and colleges look to the Carnegie units as a reflection of what are collectively viewed as academic priorities. Does the State Board believe districts that chose to retain Carnegie units as the structure of their curriculum should be able to do so in tandem with the new standards?

Finally, it has been argued that the special education standards, which are extensive and complex, deserve a thorough review separate and apart from those standards that have a general application to all students. I understand from the Superintendent that many of these special education standards reflect Federal legislation. Is it possible to put our non-special education standards on a fast track, with these special education standards following?

My purpose for raising these issues is simply to reinforce your awareness and solicit your diligence in answering these concerns.

As always, I am grateful for the cooperation that exists between my office and the State Board, and for the continuing dedication that you and others have shown for improving the state's school system.

Sincerely,

George V. Voinovich (signed)

Governor

GW/ade

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