Dear Member of the Board of Elementary and Secondary Education,

We are writing regarding your effort to draft proposed regulations to implement the new statute created with the passage of ballot question two from last year’s statewide election which affected the state’s Competency Determination. The organizations listed here are writing to encourage you, as you continue to grapple with the unenviable task of trying to make the statutory language changes brought about by this initiative petition workable, to prioritize your constitutional responsibility to ensure that all students are receiving a high-quality education.

You have correctly focused, on your deliberations to date, on that part of the statute which has been maintained; that students must still “demonstrate mastery.” Your role in ensuring that happens is hampered by the statutory change in language that proposes moving the Commonwealth toward a curriculum-based approach without a common assessment to assure students have demonstrated mastery and, thus, have been adequately prepared for future success with an opportunity to fully and equitably participate in our economy and society.

While you seek to define what coursework students should have delivered to them and how we can assess if they have “successfully completed” that coursework, we ask you to consider ways in which the 10th grade MCAS exam can be used as a continued, conditional tool to assess student performance and allow for greater options for students and districts.

We support the idea of allowing ALL students, not just those identified in the limited categories of students contemplated in the “substituted equivalent” proposal presented to the Board, to achieve their state Competency Determination by passing the 10th grade MCAS exam. We would further suggest students be allowed to do so at the current score for passage with an increase to the “meeting expectations” level in years beginning with the Class of 2029.

We also urge the Board to allow, by regulation, each local school district to continue, at their option, to require a passing score on the 10th grade MCAS exam for their students to meet the state’s competency determination for a period of at least the next two to three years as they work to review and re-align their coursework to ensure they are fully aligned with the state curriculum frameworks. It should not be assumed that the courses the department would require for meeting the CD currently contain the rigorous standards contained in the state frameworks in every school and district. The temporary continued use of the MCAS alternative would also allow the proposed Statewide Graduation Council time to explore reasonable alternatives. We believe that there is nothing in statute, past or present, that prevents the department from allowing this MCAS alternative as a way of students and districts demonstrating student mastery and successful completion of coursework. Just as you have decided that the use of the 10th grade MCAS to determine the competency determination for certain students without transcripts or who are late arrivals should be allowed, the same legal standard can be applied to broader categories of students whose schools and districts are not yet prepared to demonstrate their curriculum is aligned with the state’s curriculum frameworks or that their students have achieved mastery through untested grading policies.

We hope that if further time is needed to explore these recommendations or to include them in your proposed draft regulations, you will delay action at next Tuesday’s meeting until such time as you have fully engaged with these concepts and given them due consideration.

Thank you for your time and consideration.

Associated Industries of Massachusetts
Education Trust Massachusetts
National Parents Union