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August 25, 2004 The Honorable Jeb Bush PL 05, The Capitol 400 South Monroe Street Tallahassee, FL 32399-0001 Re: Accountability in Scholarship Programs Dear Governor Bush: We anticipate that soon the question of “scholarship accountability” will be back before our policy makers. Recalling the discussion with the Bishops last March on this topic, and our promise to keep communication channels open on this and other issues, we are sharing some key elements of accountability that we see as essential for sound scholarship programs. Allow us to first commend your vision and leadership resulting in Florida becoming the first state in the nation to enact a statewide school-choice program. Now we have three, with a VUPK program in the wings. These accomplishments are exceptional and would not have occurred without your personal determination and commitment. It is our experience that almost without exception the parents whose children are attending a Catholic school on a statewide scholarship are satisfied with their educational-choice decisions. We fully agree with you that accountability begins with strong parental rights for them to select the schools that are in the best interest of their children. Accreditation In the coming legislative session we will again be advocating for accreditation as a requirement for all schools participating in scholarship programs. Our position on accreditation created neuralgia on many fronts last session, including within the EOG. We considered it anew over the summer and even more strongly today find the case for requiring accreditation to be compelling. We are following with interest the Senate Interim Project to determine whether accreditation is an effective accountability tool to use with private schools involved in scholarship programs. In our judgment, a sound accreditation program, with third party oversight, will establish a minimal baseline of quality to ensure that scholarship children enrolled in private schools can be provided a safe, secure and enriched learning environment. We believe such a requirement should be phased in and our recommendation includes a reasonable time line of three years from the date of obtaining candidate status to the initial accreditation visit. The school would then receive a two-year grace period following the initial accreditation visit, if needed, to correct any standard violations. In all, this amounts to a five-year period before accreditation being required by the participating school. The Opportunity Scholarship already contains requirements for accreditation and requiring it in the other scholarship programs will reassure parents and facilitate needed protections for children. Very importantly, it will also minimize unnecessary and intrusive regulation by the State. In weighing whether students in scholarship programs will be well served by the requirement, consider that accreditation is an essential accountability element within virtually every facet of education from early childhood programs through graduate school. At the pre-K level the State’s Advisory Council recommended that programs participating in VUPK must be nationally accredited and Gold Seal approved. Other precedents for accreditation include the Florida Resident Access Grant, the Private Student Assistant Grant, Access to Better Learning and Education Grant program, and Title IV Pell Grants. Moreover, law school graduates cannot participate in the Florida Bar exam unless they graduate from an accredited school. In addition, accreditation, as a baseline to ensure quality, is not limited to education. Quality care in hospitals is regularly tied to accreditation status. Accreditation of Florida’s correctional facilities is leading the nation under your leadership. Norm Referenced Testing After careful consideration we have come to the belief that longitudinal data based on learning gains in core subject areas will provide assurance to the State that its public dollars allowing parents to enroll their children in choice programs are serving these students well. For this reason, we recommend that private schools be required to administer the SAT 9, SAT 10, ITBS or some other nationally norm referenced test to scholarship students and report results to parents. Moreover, we propose that aggregated test scores should be publicly disclosed to the Florida Department of Education when there are 10 or more voucher students per grade with a participating private school. Requiring schools with 10 or more voucher students would help to provide an adequate sample size in which analyses could be drawn upon and comply with the Federal Educational Rights of Privacy Act. Providing such data would need to occur in such a manner that participating private schools would not be placed in an unfair position and the confidentiality of students’ records would have to be protected. Because almost all participating private schools administer standardized testing in the fall or winter, public disclosure of aggregated test scores would not be required until after the students had been in attendance at the schools for one full year. This is a reasonable transition time for the children and the schools. Another advantage offered by making public aggregated test scores of voucher students (within specific circumstances) is that a longitudinal database would be established to record academic performance from elementary through high school. The database would be a resource to address with empirical evidence misconceptions as to whether scholarship children are learning a year’s worth of knowledge each school year. The data could also serve as a consumer index for parents. The longitudinal data would also create a baseline to begin drawing comparative analyses of aggregated norm referenced test scores of scholarship students with that of aggregated Florida Comprehensive Assessment Test results. Obviously, in order for fair comparisons to be drawn, students of similar academic levels, based on grade level, socio-economic status, geographical location of the student’s residence and school, and whether they are developmentally delayed and/or have been diagnosed with a disability, would have to be qualitatively measured. Additional Accountability Recommendations Our other proposed accountability recommendations include: 1) parents annually signing off as to whether they believe their child is achieving academically; 2) requiring core-subject teachers who instruct scholarship students to possess a bachelor’s degree, teach in-field and attend one to two professional workshops annually; 3) documenting that scholarship dollars are expended on scholarship students; and 4) requiring new schools to provide evidence of fiscal soundness. Larry Keough, our Associate for Education will be handling the lobbying chore on scholarship accountability proposals. During the interim, he and I together will look forward to shedding more light on these recommendations with your staff, especially in the light of the experience gained last session. We hope to arrange a meeting on this very soon. Respectfully yours, D. Michael McCarron Executive Director DMMc:mt cc: Patricia Levesque John Winn Bishop Gerald Barbarito, Episcopal Moderator for Education Larry Keough, Florida Catholic Conference, Associate for Education |