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To Whom It May Concern:
The Texas Classroom Teachers Association, representing 50,000 classroom teachers and instructional personnel statewide, has the following input regarding Proposed New 19 TAC Chapter 102, Educational Programs, Subchapter EE, Commissioner's Rule Concerning Pilot Programs, §102.1056, Dropout Recovery Pilot Program.
Initially, it should be noted that we are skeptical of the notion that private entities will be able to enter this relatively specialized area of education with good results. Certainly, if nothing else, the charter school experiment has taught us that in most instances private providers that are new to the endeavor tend not to be as effective as the public schools. We have also recently received calls from a number of members regarding credit recovery programs that their districts have subcontracted to private entities, and that seem to be producing credits toward graduation in an implausibly short time frame.
For these reasons, we suggest giving priority in the grant awards process to existing dropout recovery programs by eligible entities in order to maximize the value of the relatively small amount of funds available under this grant program and avoid the sorts of problems we have seen with many charter schools that are new to the endeavor and may not have the expertise needed for success..
The rules need to specify the length of the grant possible, in order to allow interested entities to plan.
We suggest that the process of awarding grants be handled with the names of the applying entities redacted, so that only the merits of the proposals are considered.
Eligibility should be restricted to high school diploma-granting entities only or those with an articulation agreement with an institution of higher education, with the goal being a diploma rather than “college readiness” as defined.
We have a significant concern about the definition of dropout recovery pilot program, Section 102.1056(a)(2), which includes language that the purpose of the program is to provide financial grants to eligible entities to provide students who have dropped out of school services designed to enable them to earn a high school diploma or demonstrate college readiness. We believe the word “or” should be deleted and replaced with the word “and” to clarify that there is an expectation that approved programs would be geared toward earning a high school diploma.
Subsequently, in proposed Section 102.1056(f)(2)(B), the rule provides for completion payments to eligible entities for students who either earn a high school diplomas or demonstrate college readiness, which is defined as obtaining a GED, achieving a passing score on a TSI testing instrument or earning a TSI exemption, and earning either college credit for a college course or advanced technical credit. We have the same concern that was articulated in the previous paragraph, particularly with regard to obtaining a GED as an outcome triggering payment since the state, throughout the rest of our education and accountability system, is moving away from treating or viewing a GED completion as equivalent to high school graduation. Given the consistent findings about the lessened opportunities for postsecondary success by GED recipients relative to high school diploma recipients, we believe that the minimum goal established for these dropout recovery programs should be the earning of a high school diploma.
Additionally, we have significant concerns about Section 102.1056(f)(4) which provides for additional funding for eligible entities other than school districts. We understand that the intent might be to “level the playing field” between school districts, which receive ADA funds in addition to grant funds, and other eligible entities, which do not receive ADA funds. However, given that school districts receive ADA funds as high school diploma-granting institutions, a higher standard than a GED, we aren’t convinced that the playing field between public schools and GED-granting institutions needs to be leveled, and accordingly, we question the need for Section 102.1056(f)(4).
Regarding Section 102.1056(a)(3)(B) and (C): we appreciate the language that ensures that an eligible student is a “true” dropout and not someone who withdraws from public school, enrolls in a private or home school for 30 consecutive days, and then becomes eligible to attend a dropout recovery program.
We are also concerned about the language in Section 102.1056(a)(8) and (b)(2) which states that a nonprofit organization that is not an eligible applicant may participate in a shared service arrangement but may not serve as the fiscal agent. It does not seem prudent to permit nonprofits that have not received the scrutiny successful grant applicants will have, to participate in providing educational services. Allowing nonprofits that have not been reviewed and approved through the grant process sets up an arrangement in which inappropriate subcontractors could be hired through shared service arrangements, which may not be in the best interests of the students or prove to be a wise use of grant funding.
Finally, we support the language in Section 102.1056(3), particularly subsection (3)(A) that an applicant awarded a grant must have been operating as an eligible entity for at least three years prior to the time of the grant application.
Thank you for this opportunity for express our views, and we appreciate your consideration of our perspective.
Texas Classroom Teachers Association
