The United States Education Department turned to the public to field comments on how it should go about implementing the new standards of the Every Student Succeeds Act; it received over 200 responses containing suggestions on how it should act--or should not.

Responses included a wide-range of comments on different aspects of the new education legislation.

The American Educational Research Association, for example, discussed doing a better job at defining “scientifically valid research” than No Child Left Behind did. The AERA urges the USED in its comments to ensure that the definition of valid research holds its integrity under the new legislation. 

"A meaningful and useful definition is an important step forward. Effective implementation of mandated requirements also depends on the capacity of Local Education Agencies (LEAs) and State Education Agencies (SEAs) to differentiate between reliable research and not-so reliable research. Such expertise would presumably vary widely across state agencies. It is here that the U.S. Department of Education’s Institute of Education Sciences (IES) has the capacity, commitment, and expertise to help,” the AERA said.

Other comments varied greatly in what they see the role of the USED as being in regulating ESSA.

According to the Missouri Association of School Administrators, that role should be very minimal and the majority of interpretation and enforcement should be left up to local and state authorities:

As regulations for ESSA are crafted, we encourage USED to grant state and local education agencies in Missouri the broad flexibility to meet the unique needs of their students. The nation’s public school system is a collection of 14,000 smaller systems, and as such, any regulations, guidance or technical assistance issued by USED must remember that one size does not fit all, and that when it comes to federal policy—whether related to assessment, accountability, standards, a specific student subgroup, teachers, or another factor—one size does NOT fit all, and there is not one ‘best’ system or model that will serve all students and all schools. That is, the policy and program that work in Illinois may not work here in Missouri.

Other organizations focused on more specific goals for implementation, as was the case with the National Association for the Education of Young Children.

For NAEYC, it believes the USED has a responsibility in ensuring that states are using their Title I funds to correctly fund early childhood education.

“Specifically, we encourage the Department to develop regulations that clarify states’ responsibilities to support LEA's use of Title I dollars for early education. These regulations should also encourage LEAs to use Title I funds for early learning programs and the regulations and guidance should demonstrate how LEAs can incorporate developmentally-appropriate practice and prioritize equity and mixed-delivery systems in their implementation,” NAEYC said.

It also focuses on the federal government helping states ensure they are doing their job in promoting literacy development in children early on.

"While state flexibility is supported in the context of the law, regulations from the Department that reiterate the expectation and opportunity to promote literacy development beginning at birth will be welcome, as will information that clarifies the meaning of evidence- based programming and evaluations, particularly as it concerns the early years and the racial and ethnic diversity of children, families and communities.” 

The NAACP also asked for federal regulation when it comes to the implementation of certain sections of the law. 

“Part D of Title I addresses prevention and intervention programs for children and youth who are neglected, delinquent, or at-risk. Federal regulations are necessary to adequately implement this section. Such regulations should be based on the joint DOJ-Dept. of Education Guidelines on Correctional Education in Juvenile Justice Facilities 2; the joint DOJ-Department of Education Guidelines on School Climate and School Discipline 3; and the HHS-Department of Education Policy Statement on Pre-K Suspensions and Expulsions 4. Federal guidelines under Part D could be helpful in addressing a problem such as in Maryland where the State's juvenile detention education is failing to provide the necessary education for detainees 5,” the NAACP said on addressing the school-to-prison pipeline.

But for more the most part, state organizations, unions and the like have one major message to USED: stay back.

Says the California Federation of Teachers, which represents 120,000 members:

"…we strongly encourage the U.S. Department of Education to refrain from heavily regulating this law. Parents, communities, and California educators are not interested in having highly-prescriptive rules and mandates around preK-12 education from the federal government.”

See the full list of comments here.

Article by Nicole Gorman, Education World Contributor

1/25/2016