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ESEA FLEXIBILITY

Amendment Submission Template & Extension Request from the CORE Districts

Dear Assistant Secretary:


We are writing on behalf of the CORE districts to request approval to amend the CORE districts approved ESEA flexibility request
and to renew the CORE Waiver for the next three school years. The districts requesting an additional three-year extension of the
waiver are: Fresno Unified, Long Beach Unified, Los Angeles Unified, Oakland Unified, San Francisco Unified, and Santa Ana
Unified.1
The relevant information, outlined in the ESEA Flexibility Amendment Submission Process document, is provided in the table below.
These amendments are informed by stakeholder consultation, and collective decision-making by CORE district staff and the CORE
Board. Per USED renewal guidance, our amended request also includes updates to Principle 1, the stakeholder consultation sections
of the CORE Waiver, and the waivers and assurances. Where appropriate, we have also updated requester information, the
introductory section, and select sections of the appendix with more current information.
Per our recent conversations, at the same time that the CORE districts submit our updated and comprehensive educator effectiveness
guidelines this Spring, we will also include an outline of both criteria for and a process for inviting other California districts to join the
CORE Waiver for the 2016-17 school year.

1
TheU.S.DepartmentofEducationgrantedtheoriginaloneyearwaivertoeightCOREdistrictsinAugust2013.In2014,sevenoftheoriginal
eightdistrictsrequestedandweregrantedaoneyearwaiverextension.WhilealltenCOREdistrictscontributedtothedevelopmentofthe
SchoolQualityImprovementSystem,theeightdistrictsthatappliedforandreceivedtheNCLBwaiverinAugust2013areFresno,LongBeach,
LosAngeles,Oakland,Sacramento,SanFrancisco,Sanger,andSantaAnaUnifiedSchoolDistricts.SacramentoCityUnifiedSchoolDistrictdidnot
jointhejointwaiverextensionrequestin2014,andSangerUnifiedSchoolDistrictisnotparticipatinginthejointwaiverextensionrequestthis
year.BothSangerUnifiedandSacramentoUnifiedcontinuetoparticipateintheCOREconsortium.

According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless such collection
displays a valid OMB control number. The valid OMB control number for this information collection is 1810-0581.

Further, specific to the Los Angeles Unified School District (LAUSD) and per the letter addressed to Secretary Duncan by
Superintendent Cortines dated March 12, 2015, at the time of the submission of this extension request, LAUSD has not been able to
reach agreement with their bargaining partners at the United Teachers Los Angeles (UTLA) to include three levels in their teacher
evaluation system. LAUSD understands that this is a requirement of the CORE Waiver and will continue to work with UTLA through
the mediation and bargaining processes to include at least three levels of performance in the teacher evaluation system.
Amendment requests
#
Flexibility
Brief Description of
Element(s)
Element as Originally
Affected by Approved
the
Amendment
44

2A, 91

Currently, schools
testing less than 90%
of students are to be
identified as Focus
schools.

Brief Description of
Requested
Amendment

Rationale

Process for Consulting


with Stakeholders,
Summary of Comments,
and Changes Made as a
Result

If a school tests less


than 95% of students
in the all students
group or any subgroup
included in CORE
Waiver accountability,
that school will not
have met their AMO
(rather than tying
testing below 90% of
students to automatic
Focus status).
Additionally, the
CORE districts intend
to study and
potentially propose
alternative criteria in
cases where there are
fewer than 100
students in a subgroup

Tying under-testing
to AMO status is
more aligned to
USED guidance, and
a better fit for the
CORE districts.

This amendment request is


similar to a request made in
May 2014 (Amendment
Request #2). District staff
and the CORE Board
vetted/developed the
amendment last Spring, and
reconsidered the concept in
Winter 2015. This specific
amendment request was
made available for public
comment in February 2015
with requests for public
comment posted both on the
CORE districts website and
circulated within each of the
CORE districts.

Flexibility
Brief Description of
Element(s)
Element as Originally
Affected by Approved
the
Amendment

Brief Description of
Requested
Amendment

Rationale

Process for Consulting


with Stakeholders,
Summary of Comments,
and Changes Made as a
Result

This amendment request is


similar to a request made in
May 2014 (Amendment
Request #13). District staff
and the CORE Board
vetted/developed the
amendment last Spring, and
reconsidered the concept in
Winter 2015. This specific
amendment request was
made available for public
comment in February 2015
with requests for public
comment posted both on the
CORE districts website and
circulated within each of the
CORE districts.
This specific amendment
request was made available
for public comment in
February 2015 with requests
for public comment posted
both on the CORE districts
website and circulated within

with respect to this


participation criterion.
45

2C, 142 to
143

The approved request


includes Reward
designation criteria, but
those criteria do not
consider the School
Quality Improvement
Index (hereafter, the
Index) as a whole, nor
do they consider the
implications of the
testing transition.

Updated reward
criteria are included
that incorporate the
Index and consider the
changing availability
of assessment data
over time.

These updated
reward criteria have
been designed to
meet USED guidance
and to incorporate the
School Quality
Improvement Index.
Note that the criteria
evolve over time as
we have additional
years of Index data to
look at performance
and growth over
multiple years.

46

2C, 145

The approved request


does not clarify the
circumstances under
which a pairing will be
dissolved with respect
to changes in the
performance of

Priority/Focus schools
will remain paired
with the same
collaborative partner
school year after year
while Priority/Focus
schools remain in their

Significant
investment is made
by paired schools to
build relationships,
identify areas of
focus and engage in

Flexibility
Brief Description of
Element(s)
Element as Originally
Affected by Approved
the
Amendment
collaborative partner
schools.

Brief Description of
Requested
Amendment

Rationale

Process for Consulting


with Stakeholders,
Summary of Comments,
and Changes Made as a
Result

respective designations
unless the following
occurs:
a) The
collaborative
partner school
becomes a
priority, focus
or other
support
school, AND
b) Their LEA
determines that
continuing in
the pairing
would be
detrimental to
the
collaborative
partner school,

productive shared
learning experiences.
In general, it is the
position of the CORE
districts that as such,
schools should
remain in pairing
unless the
aforementioned
criteria are met.

each of the CORE districts.


Note that this request grew
out of stakeholder questions
and concerns about
dissolving pairings during
the support experience (e.g.,
from school staff
participating in pairing).

OR

c) The LEA(s)
involved

Flexibility
Brief Description of
Element(s)
Element as Originally
Affected by Approved
the
Amendment

47

2D, 150

The CORE Waiver


does not articulate
criteria for updating
Priority lists in future
years.

20 (reproposed)

2D, 148

The waiver includes a


set of schools that are

Brief Description of
Requested
Amendment

determine that
the
Priority/Focus
school in
question would
benefit from a
different
partner.
Criteria for updating
Priority school lists
that incorporate the
Index and USED
guidelines have been
proposed.

We request the
addition of transitional

Rationale

Process for Consulting


with Stakeholders,
Summary of Comments,
and Changes Made as a
Result

These updated
Priority criteria have
been designed to
meet USED guidance
and to incorporate
and emphasize the
School Quality
Improvement Index.
Note that the criteria
evolve over time as
we have additional
years of Index data to
look at performance
and growth over
multiple years.

This amendment request is


similar to a request made in
May 2014 (Amendment
#21). District staff and the
CORE Board
vetted/developed the
amendment last Spring, and
reconsidered the concept in
Winter 2015. This specific
amendment request was
made available for public
comment in February 2015
with requests for public
comment posted both on the
CORE districts website and
circulated within each of the
CORE districts.
This amendment request is
the same as the request made

Such schools, similar


to the other excluded

Flexibility
Brief Description of
Element(s)
Element as Originally
Affected by Approved
the
Amendment

Brief Description of
Requested
Amendment

Rationale

Process for Consulting


with Stakeholders,
Summary of Comments,
and Changes Made as a
Result

2E, 168

schools for incoming


English Learners (e.g.,
newcomers schools)
to the list schools
excluded from Priority
and Focus school lists.

schools, are designed


to meet the needs of a
special population of
students typically
those that enter US
schools as English
Learners after the
early elementary
grade levels.
Students spend a
brief period of time
there in order to help
them acquire English
language and
academic skills
before entering a
comprehensive
school environment.
For these students,
accountability is with
the school that
receives them after
spending a brief
period of time in the
newcomer school
environment.

in May 2014 (Amendment


#21). District staff and the
CORE Board
vetted/developed the
amendment last Spring, and
reconsidered the concept in
Winter 2015. This specific
amendment request was
made available for public
comment in March 2015
with requests for public
comment posted both on the
CORE districts website and
circulated within each of the
CORE districts.

not included in the


Priority and Focus
school analysis (e.g.,
credit recovery
programs, independent
study schools).

We are re-proposing this


amendment in part due to
concerns from stakeholders
that the designation criteria
do not apply appropriately to
newcomer schools.

48

Flexibility
Brief Description of
Element(s)
Element as Originally
Affected by Approved
the
Amendment

2D, 149-150

The approved request


does not articulate the
medium and long-term
timing by which we
will update Priority
lists.

Brief Description of
Requested
Amendment

Rationale

Whats more, due to


the fact that many
newcomers do not
participate in testing
in their first year,
there are some years
with an insufficient
number of students to
generate metric
results, making it
possible that such
schools will not be
able to meet exit
criteria.
When a district enters Summer/fall 2016
the CORE Waiver for will be the first time
the first time, then
we will have the full
applicable Title I
set of Index measures
schools should be
involved in
considered for
examining school
identification as a
performance. It also
Priority school during gives schools the
the year of entry.
opportunity to have
two sets of SBAC
Otherwise, the CORE results, allowing
districts will look at all some learning from
schools against the
the first years results

Process for Consulting


with Stakeholders,
Summary of Comments,
and Changes Made as a
Result

This amendment request is


similar to part of a request
made in May 2014
(Amendment #21). District
staff and the CORE Board
vetted/developed the
amendment last Spring, and
reconsidered the concept in
Winter 2015. This specific
amendment request was
made available for public
comment in February 2015
with requests for public

49

Flexibility
Brief Description of
Element(s)
Element as Originally
Affected by Approved
the
Amendment

2E, 170

The CORE Waiver


does not articulate
criteria for updating
Focus lists in future
years.

Brief Description of
Requested
Amendment

Rationale

Process for Consulting


with Stakeholders,
Summary of Comments,
and Changes Made as a
Result

Priority criteria next in


summer/fall 2016 with
interventions
beginning in SY 201617, and every three
years thereafter.

before schools are


designated based in
large part on these
new assessments.

comment posted both on the


CORE districts website and
circulated within each of the
CORE districts.

Updating the list


every three years will
allow LEAs to
maximize their
emphasis on
supporting the active
set of Priority
schools.
These updated Focus
criteria have been
designed to meet
USED guidance and
to incorporate and
emphasize the School
Quality Improvement
Index. Note that the
criteria evolve over
time as we have
additional years of
Index data to look at
performance and
growth over multiple

This amendment request is


similar to a request made in
May 2014 (Amendment
#25). District staff and the
CORE Board
vetted/developed the
amendment last Spring, and
reconsidered the concept in
Winter 2015. This specific
amendment request was
made available for public
comment in February 2015
with requests for public
comment posted both on the

Criteria for updating


Focus school lists that
incorporate the Index
and USED guidelines
have been proposed.

Flexibility
Brief Description of
Element(s)
Element as Originally
Affected by Approved
the
Amendment

Brief Description of
Requested
Amendment

Rationale

years.

50

2E, 170

The approved request


does not articulate the
medium and long-term
timing by which we
will update Focus lists.

Process for Consulting


with Stakeholders,
Summary of Comments,
and Changes Made as a
Result

CORE districts website and


circulated within each of the
CORE districts.
This amendment request is
When a district enters Summer/fall 2016
similar to part of a request
the CORE Waiver for will be the first time
we will have the full made in May 2014
the first time, then
applicable Title I
set of Index measures (Amendment #25). District
staff and the CORE Board
schools should be
involved in
vetted/developed the
considered for
examining school
amendment last Spring, and
performance. It also
identification as a
reconsidered the concept in
gives schools the
Focus school during
Winter 2015. This specific
the year of entry.
opportunity to have
amendment request was
two sets of SBAC
made available for public
Otherwise, the CORE results, allowing
comment in February 2015
districts will look at all some learning from
schools against the
the first years results with requests for public
comment posted both on the
before schools are
Focus criteria next in
CORE districts website and
summer/fall 2016 with designated based in
circulated within each of the
interventions
large part on these
CORE districts.
beginning in SY 2016- new assessments.
17, and every three
Updating the list
years thereafter.
every three years will
allow LEAs to
maximize their
emphasis on
supporting the active

51

Flexibility
Brief Description of
Element(s)
Element as Originally
Affected by Approved
the
Amendment

2E, 172

Brief Description of
Requested
Amendment

Rationale

set of Focus schools.


It may not be
Currently, the CORE
For Focus schools
beneficial to escalate
Waiver says that
identified in the first
to pairing a school
schools that do not exit year of implementing
Focus status after two
the CORE Waiver (SY instead of involving
years are to be required 2013-14), we request a them in a Community
of Practice. Further,
to pair in year 3.
one year extension to
with the transition in
the escalation
requiring pairing while standards and
CORE districts assess assessments from the
the appropriateness of California State
this escalation concept Standards to the
Common Core State
after a review of the
Standards, we seek
Community of
an additional year to
Practice and Pairing
Program work date. A work with current
Focus schools before
determination as to
escalating
whether to proceed
interventions.
with this escalation
approach will be made
during SY 2015-16
with an amended
request, if appropriate
(e.g., to make the
Pairing escalation
requirement optional).

Process for Consulting


with Stakeholders,
Summary of Comments,
and Changes Made as a
Result

As district staff considered


implications of intervention
escalation, there were
concerns raised about this
particular escalation
requirement. This request
also generally follows from
concerns raised by
stakeholders in Spring 2014
about allowing SY 2014-15
to be more of a transitional
year to the new assessments,
and this approach allows for
that transition time. Similar
to other requests included
here, this request was made
available for public comment
before its inclusion in this set
of proposed amendments.

Flexibility
Brief Description of
Element(s)
Element as Originally
Affected by Approved
the
Amendment

Brief Description of
Requested
Amendment

Rationale

Process for Consulting


with Stakeholders,
Summary of Comments,
and Changes Made as a
Result

52

2F, 209-211

In general, after 2
years of missing the
CORE, schools will be
required to join and
participate in a
Community of
Practice. That said,
for schools that missed
the AMO for the first
time based upon the
summer/fall 2014
analysis and then miss
the AMO again based
upon the summer/fall
2015 analysis, the
CORE districts will
wait until the
summer/fall 2016
analysis is complete to
add the school to a
Community of
Practice. In other
words, we will not be
adding schools to
Communities of
Practice until the SY
2015-16 results are

Summer/fall 2016
will be the first time
we will have the full
set of Index measures
involved in
examining school
performance. It also
gives schools the
opportunity to have
two sets of SBAC
results, allowing
some learning from
the first years results
before schools are
assigned to
intervention based in
large part on these
new assessments.

This request generally


follows from concerns raised
by stakeholders in Spring
2014 about allowing SY
2014-15 to be more of a
transitional year to the new
assessments, and this
approach allows for that
transition time. Similar to
other requests included here,
this request was made
available for public comment
before its inclusion in this set
of proposed amendments.

After two years of not


meeting the CORE
AMO, other title I
schools enter the
Communities of
Practice intervention.

Further, this
approach is
consistent with
messaging to
stakeholders in
California about the
first set of SBAC
results in SY 2014-

Further, there has been an


active, California-wide
discourse amongst
stakeholders about limiting
the use of SY 2014-15
SBAC results in
accountability, including,
most recently the State
Board decision about
California-wide
accountability at their
March, public board

Flexibility
Brief Description of
Element(s)
Element as Originally
Affected by Approved
the
Amendment

Brief Description of
Requested
Amendment

Rationale

Process for Consulting


with Stakeholders,
Summary of Comments,
and Changes Made as a
Result

released.

15, as well as the


State Boards
decision about the
use of SBAC in midMarch.

meeting.

We look forward to working with USED in continued partnership to dramatically increase college and career readiness, while
eliminating disparity and disproportionality. Please reach out to Noah Bookman at noah@caedpartners.org with any questions or
other follow up.
Sincerely,
Rick Miller
Executive Director
On behalf of the CORE Districts