April 4, 2025

Dear Members of the Board of Elementary and Secondary Education:

The Associated Industries of Massachusetts (AIM) is the state’s largest business association. We serve the needs of more than 3,400 businesses across 150 different industries, representing more than 650,000 Massachusetts employees and residents of Massachusetts. Every day we work to help businesses unlock their full potential. We advocate for positive public policy that creates economic opportunity and ensures our business community can grow and thrive in the Commonwealth.

It is in that vein that we offer public comment regarding the proposed new set of regulations following the passage of ballot question number two from last year’s statewide election which affected the state’s Competency Determination. On behalf of our members, we write to encourage you, as you continue to grapple with the unenviable task of trying to finalize regulations that ensure all students have equal access to high-quality education, to prevent the possibility of severe graduation standards variation in school districts that would lead to inequity amongst the Commonwealth’s students.

We believe you have correctly focused 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. We believe the department should allow for the continued use of the 10th grade MCAS exam as a way students and districts can demonstrate students have achieved mastery and successfully completed required coursework.

We support the idea of allowing ALL students, not just those identified in the limited categories of students contemplated in the proposed regulations as those whose late arrival to a school or district makes it impossible to meet the course requirements, 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 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.