May 8, 2014: Ohio Senate Education Committee – H.B. 487

May 8, 2014

Chairwoman Lehner, Vice Chair Hite, Ranking Member Sawyer, and  members  of  the  Senate Education Committee, my name is Mary Ronan and I am Superintendent of  Cincinnati  Public Schools and am here today on behalf of my district and The Ohio 8 Coalition. Thank you for allowing me the opportunity to share  our  feedback  on  HB  487,  the  MBR,  and  provide  some recommendations around the revision of the bill.

The Ohio 8 is a strategic alliance composed of the superintendents and teacher union presidents from Ohio’s eight urban school districts – Akron, Canton, Cincinnati, Cleveland, Columbus, Dayton, Toledo and Youngstown. The Ohio 8 Coalition’s mission is to work with policy makers to improve academic performance, increase graduation rates and close the achievement gap for urban children throughout Ohio. The Coalition carries out  its  mission  by  working  closely  with  legislators, educators, parents, labor and community officials. The Coalition brings a shared administrator-­‐ teacher voice to help shape state education policy.

My testimony will outline a number of areas of concern within HB 487. We look forward to continuing to discuss our recommendations with you and your colleagues and hope to be helpful in any way we can as the MBR process continues in the Senate.

First, Student Career Advising, At-­‐Risk Identification, and Student Success Plans:

Governor Kasich has proposed policies be developed at a school and district level that mandate the adoption of a policy on career advising that specifies how the district will perform related activities. The House has extended the timeline for implementation from the  beginning  of  the  2014-­‐2015 school year to instead, the 2016-­‐2017 school year.

At that time districts will be required to do all of the following:

  1. Identify students who are at risk of dropping out of school  using  a  research-­‐based, locally based method;
  2. Develop a “student success plan” for each of those students outlining the student’s academic pathway to a successful graduation and the role of career-­‐technical education, competency-­‐based education, and experiential learning, as appropriate, in that pathway.
  3. Requires the district or school, prior to developing a student success plan for a student identified as at risk of dropping out of school, to invite the student’s parent, guardian, or custodian to assist in developing the plan
  4. Requires the Department of Education to develop and post on its website, not later than December 1, 2014, model policies on career advising and model student success plans.

The Ohio 8 is Concerned that:

  • While the timeline was extended by the House implementation concerns remain.
  • Additionally, current levels of  staffing and funding are not sufficient   to  support   this mandate.

We encourage you to either allocate funding to support increased staffing OR alter the language to make the provision encouraged but permissive rather than mandatory.

Secondly, State Report Card Modifications related to value-­‐added:

This provision modifies the scope of value-­‐added data used from “up to three years” to “the most recent year” to determine the value-­‐added progress dimension grade for a school district or school on the annual state report cards. .

The Ohio 8 supports this provision for a few reasons:

  1. The Ohio 8 Coalition strongly supports the changes made to the Value-­‐Added portion of the state report card.
  2. The Ohio 8 strongly believes that the value-­‐added dimension is intended to be reflective of the growth of students in a particular year. By evaluating value-­‐added data for a particular group of students within a one school year this goal is accomplished.
  3. The Ohio 8 believes that when the value-­‐added data is gathered and displayed one year at a time it provides a clear and accurate opportunity for year-­‐to-­‐year comparison. When averaged, as they are now, districts that are large in size are either greatly advantaged or disadvantaged resulting in an unclear picture of actual performance.

 The Ohio 8 Recommends that the Senate Maintain the changes made by the House to the Value-­‐ Added dimension of the State Report Card.

The modifications related to the State Report Card Around Student Assessments 

will require the Ohio Department of Education to use only assessment scores of students who have taken assessments in a particular school or district for at least two of the most recent school years when determining the value-­‐added progress dimension grade for a school district or school building on the annual state report cards.

The Ohio 8 Coalition supports the portion of the changes made by the House that would include only the scores of students who have taken assessments within  the  district  for  two  of  the  most recent school years.

The Ohio 8 has a number of concerns related to this modification:

  1. The Ohio 8 is concerned that the House language  is  too  broad  in  that  the  change  would apply to school buildings as well as the district overall. In this situation school buildings that only serve two grade levels may end up with no student assessments being counted, or students who have moved from one school to another but remained in the district not being counted.
  2. Every district in the Ohio 8 Coalition experiences high rates of mobility among their student populations and as a result we are extremely supportive of the change that would count the scores of students who have taken assessments in the school district for the past two years.
  3. The Ohio 8 strongly supports evaluation and assessments that are reflective of a district’s impact  on  their  students.  This  provision  would  serve  to  more  accurately  portray  the accomplishments  of  school  districts  without  penalizing  them  for  high  rates  of  student mobility between districts.

The Ohio 8 recommends that the language be altered to apply district wide rather than individual school  buildings.


The fourth area of interest is related to the State Kindergarten Diagnostic Assessments:

This  provision  will  permit  kindergarten  language  and  reading  diagnostic  assessment  data  to  be included on the annual report cards issued for schools and school districts. The provision further specifies that the results of the language and reading diagnostic assessment must be reported to the Department of Education..


  • The Ohio 8 Coalition supports the reporting of kindergarten diagnostic assessment data for language and reading to the Ohio Department of Education so long as the following recommendations are included in the bill.


  1. The data be included  on the  annual state report cards issued for schools and districts; and
  2. The data must not used to assess school and district performance

The bill suggests modifications related to Alternative State Diagnostic Assessments:

House Bill 487 will permit schools or districts that have received a “A” or “B” for performance index score or for overall value-­‐added progress dimension on the state report card for the prior school year to administer different diagnostic assessments than those prescribed by ODE.

The Ohio 8 Coalition is concerned that by permitting schools and districts to administer different assessments from one another the ability to accurately compare districts may be compromised.

The Ohio 8 Coalition recommends that schools and districts be required to administer the same diagnostic assessments regardless of performance on the report card.

Our sixth area of interest is related to the proposed End Of Course Examination Exemptions:

The House version will permit chartered nonpublic schools to forgo the end-­‐of-­‐course examinations if  the  school  publishes  the  results  of  standardized  assessments.  Additionally,  the  State  Board  of Education  would  be  prohibited  from  imposing  additional  requirements  or  assessments  for  the granting of a high school diploma.

The  Ohio  8  believes  that  all  students  who  receive  state  funding  to  support  their  education, regardless of setting, should be held to the same graduation requirements.

The Ohio 8 Coalition recommends that all chartered nonpublic schools be required to administer end-­‐of-­‐course examinations to students receiving state funding, and report the results to ODE.

The Ohio 8 is concerned about a proposed change to GED testing  approvals.  The  House version of HB 483 specifies that any person who is at least 16 years old (but less than 18) who applies to take the GED must submit written approval from their parent or guardian to ODE. This specification  eliminates  the  current  requirement  that  minors  obtain  approval  from  the  school district superintendent where the person was last enrolled.

 The Ohio 8 is concerned that:

  • This provision would prevent a school district from learning the student is considering the GED and as a result prevent them from discussing alternatives with the student and their family.
  • This provision may result in further decline in graduation rates and an increase in dropout rates in our districts. Even if a student attains their GED they are still  registered  as  a dropout on the state report card.

 The Ohio 8 Recommendations:

  • T Removal of this provision and retention current law.
  • If the provision remains and districts are not provided the opportunity to engage and work with these individuals to identify alternatives the Ohio  8  recommends  that  students  who leave the district to take the GED not be counted as dropouts or against the district graduation rates.

 Additionally, the House has proposed changes to the enrollment of individuals Ages 22-­‐29

The House has included a provision in HB 403 that would permits individuals ages 22-­‐29 that have not  received  a  high  school  diploma  to  enroll  in  a  number  of  settings  (including  public  school districts and community schools that offer drop out and recovery programs) in order to earn their high  school  diploma.  The  majority  of  this  provision  reflects  Representative  Stebelton’s  House  Bill 343 which has received a number of hearings where stakeholders have expressed a great deal of concern around the legislation.


  • The Ohio 8 Coalition is opposed  to  adults  participating  in  a  learning  environment  where they may come in contact with minors. Despite the language in the bill seeking to remedy this concern the Ohio 8 remains skeptical that it is possible to completely isolate the two populations.
  • The Ohio 8 Coalition is concerned that the legislation may not allow districts to opt-­‐out of this expansion. This is of particular concern if the district is not able to provide a setting free from interaction with minors (as required by the  legislation).  This  may  result  in  districts being required to develop entirely separate programming (teachers, staff, classrooms/buildings) for 22-­‐29 year olds who wish to enroll.
  • The Ohio 8 Coalition is concerned that the legislation does not stipulate any eligibility requirements related to the criminal background of the individuals enrolling.


  • The Ohio 8 strongly recommends the removal of this provision.
  • The Ohio 8 suggests that while this provision should be removed, the governor’s proposed Adult Career Opportunity Pilot Program, which provides a similar opportunity and includes career-­‐training component, be maintained within the legislation. This pilot program is to be fully implemented in adult learning environments and as a result eliminates the Ohio 8’s concerns.

Another area of concern for the Ohio 8 relates to the concept of Community School Student Participation in Public School Extracurricular Activities.

The Ohio 8 Coalition stands in opposition to the provision that expanded extracurricular access to home schooled students in House Bill  59  and  further  opposes  the  expansion  to  include  students who have chosen to attend community schools rather than the public school district. We have three primary  concerns:

  1. When a parent is choosing to place their child in a community school rather than the public school district they are making a selection between a set of services that one can provide over the other; the expectation is that those options are not the same. To permit a parent to flee a lower performing school and still take advantage of the benefits that school has to offer is inherently unfair.
  2. Extracurricular activities are not offered to students at no financial cost to the district. Because we value these opportunities for our students we have prioritized funding to support them. Even in a pay to play environment districts are sharing  the  cost  burden related to coaches, field maintenance, uniforms, safety and security  measures, transportation, and facilities.
  3. It is generally understood that schools carry the responsibility (and liability) for enrolled students. Students from homeschool  environments  and  community  schools  are  currently not the responsibility of the public school district. The bill language remains silent on this matter.

The Ohio 8 Coalition strongly encourages you to remove this provision from the legislation as well as remove the expansion made to include home school students in HB 59.


Modifications to the Academic Distress Commission

are concerning to the Ohio 8 Coalition as many of the modifications are related to assessment changes that have not yet been fully defined or implemented. Additionally, the Ohio 8 is concerned that the criteria may move a district under an academic distress commission even as they are improving.

A couple examples of this include:

  1. According to the proposed changes, if 50% of a school district’s buildings were to receive an overall grade of an “F” or “D” for three or more consecutive yys they would qualify for a commission; at this point ODE has not yet calculated any overall grades for  districts  and schools, which prevents districts from understanding where they rank.
  2. Using the same example, if a district were to receive an overall grade of “F” for 50% of it’s schools for two consecutive years and then in the third year 50% of their schools receive an overall grade of a “D” they would qualify for a commission despite showing they are improving.

 The Ohio 8 recommends

  1. that modifications should not be made to the academic  distress  commission criteria  until the new report card has been fully implemented.
  2. and that qualifying criteria target only districts failing to show any improvement.


Finally, the Ohio 8 is concerned  about  Modifications  to  Gifted  Student  Spending Requirements

this provision would require districts to submit  a  report  each  year  to  the Department of Education that details spending on gifted students. The  provision  prohibits  the school district from reporting a gifted student as served if the district has not paid for the service.

The Ohio 8 is extremely concerned that compliance related to this provision will be difficult based on how gifted students are served in different grades and this is not exclusive to Ohio 8 districts.

Specifically students who are identified as gifted may be learning in classrooms alongside students not identified as gifted. As a result, it becomes difficult to identify what parts of  that  classroom spending are going each student. For example, some students in AP courses are identified as gifted while others are not, what portion of that classroom's expenditure should be identified as servicing gifted? The same may apply for students attending a local community college earning high school credit.

The Ohio 8 recommends the removal of this requirement from the legislation.

As you continue the critical work related to the MBR the Ohio 8 would also like to provide you with a number of recommendations related to high school graduation requirements.

1. Number and Topic of End of Course Exam:

The State Board approach would permit districts to choose between administering 10 EOCs and 8 EOCs.

The Ohio 8 Coalition supports a compromised approach between HB 193 and the State Board approach of 7 end of course exams. (House: 5 vs. State Board: 10)


  • The Ohio 8 Coalition experiences high levels of mobility and is concerned that if districts are not all held to the same standard it may result in confusion for districts, teacher and most importantly students. Additionally, the Ohio 8 is concerned this may result in reporting confusion for the districts.


  1. The Ohio 8 Coalition recommends that all districts be required to administer the  same number of EOCs.
  2. The Ohio 8 Coalition recommends the following EOCs be administered and counted.
                 a. English Language Arts (2)
                      i. 11
                      ii. 12
                 b. Mathematics - Administer 3 and Count (2)
                      i. Algebra 1, 2
                      ii. Geometry
                 c. Science - Administer 2 and Count (1)
                      i. Biology
                      ii. Physical Science
                 d. American Government (1)
                 e. American History (1)
                 f. Total: 7

2. End-­‐of-­‐Course Point Requirements

The State Board has proposed that the points students earn on each exam be counted toward the total points needed to qualify for a diploma and the state board has defined a minimum required score for each exam.


Currently the minimum scores do not add up to the total number of points needed for graduation.


  1. The Ohio 8 Coalition recommends that the minimum  number  of  required  points  on  each exam exactly equal the minimum overall points required to qualify for a high school diploma.
  2. The Ohio 8 Coalition recommends that if a student achieves the minimum points required on each exam they should identified as proficient.

3. Exam Retake Opportunities

The State Board would permit retake opportunities for students who have scored a 2 or lower but require the student receive remediation prior to retaking the exam.


  • The State Board approach does not indicate what information will be made  available  to schools and districts regarding the results of the student’s testing. It is important that districts be able to target intervention efforts to the area where the student is struggling.
  • The Ohio 8 is concerned that the remediation mandate may result in an unintended cost burden for school districts in the form of staffing and the purchase or development of remediation  tools.


  1. The Ohio 8 recommends that testing results be shared with the student, parents, and the school district. The results must be designed in a manner that allows teachers to provide targeted support and intervention to the student.
  2. The Ohio 8 recommends that ODE be required  to  develop  online  learning  modules  and other remediation tools accessible by students and teachers at no cost to the  family  or district.

4. Exam Retake Opportunities to Earn More Points

The State Board approach would permit 12th  grade students seeking to earn extra points towards graduation to retake exams at their own cost.


  • The Ohio 8 Coalition is concerned this approach may further increase the achievement gap between affluent districts and those with lower income families as these families are less likely to be able to afford retake examinations.


  • The Ohio 8 strongly urges the committee to permit ONLY students who have not achieved a proficient score to retake exams. Once students have received a proficient score they should not be permitted to retake exams in an effort to increase their overall score.


5. Alternative Demonstrations of Proficiency

The State Board has suggested a number of alternative end of course assessment options  that students can utilize to earn points towards the total needed to earn a diploma. These alternatives include:

  • Demonstration of College Readiness (ACT and/or SAT scores)
  • Demonstration of Career Readiness (Career Field Assessment or Industry Exam
  • Presentation or Application Experiences (ie: student capstone projects)
  • Career Technical Assessments
  • Advanced Performance on EOC Exams


The Ohio 8 Coalition is extremely concerned that  the  State  Board  approach  identifies  the opportunity for subjective measures of achievement such as capstones to be used to award graduation points. The Ohio 8 Coalition strongly believes that student performance must be measured consistently and objectively across the state. Subjective measures of assessment such as capstones should not be permitted.


  • The use of subjective measurement tools (such as capstones) to earn  graduation  points should be prohibited.


6. Endorsements  and  Recognition

The State Board approach would create the Diploma Endorsement Council (DEC) to define future diploma endorsements and recognitions.

The State Board approach outlines  a  number  of  initial  endorsements  and recognitions  that  are to be phased  in  by  2017,  including,  Remediation  Free,  Elite  Academic  Honors,  Honors   Diploma, Bi-­‐ literacy  Seal  Endorsement,  Career  Ready  Endorsement.


  • Diploma Endorsement Council: The composition of the Council is not required to include educators/administrators from Ohio’s school districts (urban, rural, suburban).
  • Remediation Free: Any definition of remediation free should be based upon nationally accepted criteria and even then a number of concerns remain about the ability to define this as colleges and universities across the country have different criteria.
  • Elite Academic Honors: The Ohio 8 is extremely concerned that these honors would redefine existing summa, magna, cum laude and only permit a seemingly random percentage of graduating students to be eligible. The standards will be identified by the DEC.
  • Bi-­‐literacy Seal: The Ohio 8 is deeply concerned that this endorsement fails to recognize English language learning  students who master  the English language  while in Ohio’s schools. Additionally, this seal may further highlight the disparities among high poverty and high wealth school districts that may have the ability to offer additional language courses.


  1. The Ohio 8 recommends that the institution of the Diploma Endorsement Council be prohibited. The Ohio 8 Coalition does not believe that the entity is necessary to accomplish the goals of the State Board nor does it contain the appropriate stakeholders.
  2. Remediation Free: The State should not recognize remediation free designation unless it is based on nationally recognized scoring levels on the ACT and/or SAT.
  3. Elite Academic Honors: The Ohio 8 recommends that the current system for summa, magna, and cum laude recognitions be  maintained.  No  students  should  be  prohibited  from achieving one of these distinctions because too many others also qualified, as such, the percentage requirements should be removed.
  4. Bi-­‐literacy Seal Endorsement: The Ohio 8 recommends that this endorsement not be included on student diplomas.


We appreciate you taking the time to review our recommendations and encourage you to contact us if you have any questions.