TCTA was among only a handful of statewide teacher groups in the nation submitting comments (see Final Comments below), expressing concerns about the proposal to give significant weight to student growth based on standardized tests in making teacher compensation decisions.

Although the Teacher Incentive Fund (TIF) existed before the American Recovery and Reinvestment Act (ARRA), it received only limited funding ($97 million per fiscal year). However, under the Obama Administration, funding was drastically increased to $300 million in FY 2009, and $400 million in FY 2010.

The law with the FY 2010 appropriation authorizes the U.S. Department of Education to use TIF funds to make competitive grants to eligible entities to develop and implement in high-need schools Performance Based Compensation Systems (PBCSs) that “--(a) Consider gains in student academic achievement as well as classroom evaluations conducted multiple times during each school year among other factors, and (b) Provide educators with incentives to take on additional responsibilities and leadership roles.”

However, in its proposed rules for the grant, the Department chose to place almost all of its emphasis on the first-stated purpose and not the second. For example, it proposed that in determining teacher and principal effectiveness as part of the PBCS, the local school district “must give significant weight to student growth based on objective data on student performance; and may include other measures such as evidence of leadership roles that increase the effectiveness of other teachers in the school or LEA (local education agency (school district.))”

In further explanation of this requirement, the Department made clear that it expected student growth to be measured, in significant part, by student standardized test scores. In doing so, the Department sounded a recurring theme that it has advanced in all of its recent education reform grant proposals (such as Race to the Top).

TCTA objected to this proposal due to the fact that the state of the research does not support giving significant weight to student growth based on objective data in making teacher compensation decisions, nor does it support using student test performance to predict teachers’ future performance. We also objected to the fact that the Department contradicted the statute by proposing to make the second statutory purpose of TIF (to provide educators with incentive to take on additional responsibilities and leadership roles) discretionary rather than mandatory. 

TCTA also objected to the Department’s proposal to give competitive preference to applicants using of value-added measures of teacher and principal effectiveness, when there’s a good deal of consensus among researchers about the lack of accuracy, reliability and validity in using value-added models to produce estimates of individual teacher impact on student performance.

After considering public comments, the Department will issue final regulations for the grant. TCTA will continue to keep members posted on developments.


Microsoft Office document icon Final Comments58 KB