In a four-page letter to the state Public Education Department, Brooks wrote that he supports the department’s efforts to reform teacher evaluations but believes there are major flaws in the draft rule.
Twice, state education chief Hanna Skandera and Gov. Susana Martinez have unsuccessfully pushed for the Legislature to overturn the state’s current three-tier licensure system and replace it with a system that ties teacher evaluations to student improvement on standardized tests.
After such legislation failed, Skandera began changing the teacher evaluation process through administrative rule.
A public hearing on the rule will be held today in Santa Fe. The New Mexico chapter of the American Federation of Teachers and other unions are planning a protest at the hearing.
The three-tier system is still the law of the land. Three-tier gives teachers pay increases based on experience, education, and dossiers that show evidence of teaching quality.
Brooks’ letter asks the PED to explain how its proposal would jell with the three-tiers, which sets minimum salaries for teachers in each tier. The draft rule would rate teachers on a five-level scale that ranges from “exemplary” to “ineffective.” The rule does not say if teachers would receive extra pay for getting the highest ratings, but says teachers with the lowest ratings would be put on improvement plans, and low-rated teachers with less than three years of teaching experience would “have no reasonable expectation” of having their contracts renewed.
The proposed system would rely on “student achievement” to determine half of a teacher’s rating. For teachers in grades and subjects measured by the Standards-Based Assessment, 35 percent would be based on how much students improved over their past test scores. The SBA tests reading and math, and is taken in grades three through eight, 10 and 11.
For teachers in nontested subjects, districts would need to develop assessments that show whether students are improving over time.
The evaluation system is set to be used in pilot schools during the coming school year, and statewide starting in fall 2013. Brooks said that is too soon to develop high-quality assessments in each subject.
“The industry standard for development time of content area assessments is about two to three years. Yet, these district-level assessments would have to be developed in a few months and will then be used in a high stakes manner,” Brooks wrote. “I believe this timeline is putting districts in an indefensible position.”
APS has run its own pilot program that relies on improved test scores as part of teacher evaluations, and Brooks emphasized he does not object to this premise. But he said over-reliance on standardized tests is bad for learning.
“Many fear that the use of standardized testing does not promote good teaching or good learners. It relegates both teachers and students to ‘teach and learn to the test,’ ” he wrote.
— This article appeared on page C1 of the Albuquerque Journal