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(Note – The Florida
Catholic Conference is neither a proponent nor opponent of the bill but
is closely monitoring the legislation and raising concerns for
informational purposes.)
Good afternoon Chairman Gaetz and Committee Members. In
the interest of time, I will be brief.
As a representative of the Florida Catholic School
Community and stakeholder in the private sector, I believe that there
are many of us who understand that early learning is so vital to
children in their overall educational process.
We know from brain research that up to 40 percent of
children have a developmental delay, including language and other
processing related issues. What the brain research indicates is
developmental delays will not be effectively addressed without early
intervention.
I realize that there are varying thoughts as to whether
early childhood teachers should be degreed. I do not want to delve into
that discussion at this time. However, it is clear that a sophistication
and competency are essential qualifications for teachers to tailor their
instruction to individual learners, for them to have the ability to
identify children who are in need of intervention services and then to
understand how to initiate the referral process for the students to
receive the services they need.
But it is unfair to require higher standards without the
funding to do so. We are concerned that to move forward with a Quality
Care Rating System without the needed appropriations will lead to an
unfounded mandate passed along to private sector programs.
We are also concerned that the Quality Rating System
would in effect create a state system of accreditation. This may have
the unintended consequence of high performing nationally accreditation
programs to also come under a state rating system of standardization.
There are many nationally accredited programs, including Catholic
programs, that do not participate in Voluntary Pre-K. If we do not
comport the Quality Rating System with the standards of national
accrediting associations such as the National Council Private School
Association, the Quality Rating System would serve as a deterrent for
nationally accredited programs to participate in Voluntary Pre-K. This
would be unfortunate at a time when the state is desirous of attracting
the highest quality programs to participate in Voluntary Pre-K.
Thank you.
Larry Keough, Associate Director for
Education
April 19, 2007
Questions from committee members:
Sen. Bullard asked whether the bill is intended to
address only those providers participating in VPK, or child care
providers in general.
Sen. Gaetz asked that the bill sponsor, Sen. Rich, answer
the question in lieu of Larry Keough.
Sen. Rich answered that the bill is not relevant to VPK,
but for child care providers.
Sen. Bullard asked whether family day care homes would be
impacted by the bill through a Quality Rating system?
Sen. Rich stated that no child care program is required
to participate in the Quality Rating System. She added that only those
programs that volunteer would participate in a pilot program to
implement the Quality Rating System in eight Florida counties.
Chairman Gaetz asked Larry Keough whether Catholic school
enrollment is declining in areas in which high peforming public schools
are located?
L. Keough responded by stating that our concerns are not
relevant to market shares of students per se. Our concern is that the
Quality Rating System would have a chilling effect on nationally
accredited programs participating in VPK because they would be required
to comply with a state system of accreditation in addition to meeting
high quality standards through a national accrediting association, such
as the National Council for Private School Accreditation. These programs
in all likelihood would not be willing to meet a different set of
standards that do not comport with their national accreditation
standards in order to participate in VPK.
Chairman Gaetz asked again whether Catholic school
enrollment has declined in areas in which high performing public schools
are in close proximity.
Larry Keough answered “No.”
Note
-- After reflecting on Sen. Gaetz question of me, it is
my opinion that he was attempting to manifest that our concerns in
respect to the quality rating system have more to do with our fear to
compete with other EC programs that may meet a high quality rating
system. Obviously, this is not our concern and our history to advocate
for accountability in both UPK and in the voucher movement indicate that
our primary concern is for the children and overall programs, not
competing against schools or programs that also may a high benchmark for
accountability. If we operated from a paradigm of fear in respect to
competition, we would have opposed educational choices such as charter
schools, virtual online programs etc. – Larry Keough
Chairman Gaetz then asked the bill sponsor, Sen. Rich,
the following questions:
Is the bill voluntary?
Sen. Rich answered “yes.”
Does the legislation force all daycare, family daycare
and mom and pop providers to participate?
Sen. Rich answered “no.”
Does the bill require degreed teachers?
Sen. Rich answered “no.”
Are there unfunded mandates?
Sen. Rich answered “no.”
Quality Rating System is defeated in the final weeks of
07 session.
Editor’s note – The Agency for Workforce Development
commissioned a study to determine the level of standardization and
quality for early childhood programs in Florida. Because programs are
accredited by a variety of accrediting associations at the state,
regional and national levels, as well as other programs licensed by the
state, SB 2226 and HB 1107 were filed to create a state accountability
system that arguably would translate to state accreditation. The
following is a series of questions and answers about the legislation
and policy intent:
Is the bill voluntary?
Answer
– The legislative intent of SB 2226 is to create a uniform system of
accountability in Florida’s private-child care sector. The bill would
establish a 2-year pilot program to implement a Quality Rating System in
eight Florida counties on a tier scale from one to five. After the
two-year pilot program is completed, the Agency for Workforce
Development would present a report to the Legislature as to the
groundwork laid for a uniform system of accountability in the eight
county area. It then follows that the Legislature will be exhorted to
expand the pilot into a statewide program for early childhood programs
in the state, except family day care homes. In the senate bill analysis,
there is confusion as to whether early childhood programs that are an
integral part of a school would also be exempt from the bill. However,
the legislation clearly states that the bill applies to providers
participating in Voluntary Pre-K programs. Private schools are
participating in the VPK program. In addition, the state, through AWI,
and the bill sponsors have justifiably complained that state licensure,
religious exemption under F.S. 402.3016, Gold Seal for programs that are
nationally accredited, and those programs recognized or accredited by
in-state associations, have created a different accountability system
for various providers. Because uniformity is driving this legislation,
it only makes sense that the intent is for private schools eventually to
be required to comply with the Quality Rating System.
As with most pilot programs, this too is voluntary. But
legislative intent is a better indicator as to the likely result of the
pilot program. And, that is to create a system in which virtually all
early childhood providers operate under a single type of rating system.
Does the bill force all daycare, family daycare and mom
and pop providers to participate?
Answer –
As stated in the above
answer, family day care homes, including large family child care homes,
are exempt from the legislation. Providers/facilities participating in
VPK can and will participate in the Quality Rating System. The Senate
analysis questions whether a facility is a child care provider or a
private school, However, as mentioned above, the legislative intent is
to include private schools.
Does the bill require degreed teachers?
Answer
– The Quality Rating System has not been formulated. The Senate bill
analysis states that the Quality Rating System is to be based on a
provider’s learning environment, curricula, screening, assessment, staff
qualifications, professional development, business practices and family
involvement. It is reasonable to assume that during the two-year pilot
program the Agency for Workforce Development will recommend specific
qualifications and professional development for teachers. As I indicated
in my public testimony, some of which is based discussions concerning
qualifications for Catholic pre-k 4 teachers, competency and
sophistication are essential if our programs are to place each student
on a pathway to literacy. However, research is unclear as to whether
rising student achievement correlates with a degreed teacher.
Are there unfunded mandates?
Answer – The short answer is “no.” However, there is no
appropriation/funding tied to SB 2226 and to the House bill, 1107. Our
concern is a pilot program will be implemented in which specific
recommendations will be presented for Catholic and other private sector
programs without the funding in place. This can lead to unfunded
mandates. The VPK scholarship only pays for a portion of a child’s
daylong program, when factoring teacher salaries, teacher assistant
salaries, instructional materials, and capital outlay. The state has
demonstrated a disturbing proclivity to implement a state program – VPK
– on the backs of the private sector without adequately funding it. The
funding issue could be exacerbated by implementing the pilot without the
appropriations.
Note
– The variance in answers to the above-stated questions is based on
answering in the present time and envisioning the legislative intent for
the Quality Rating System to be implemented. The first response is the
program is voluntary and there are no requirements/mandates at the
present time. The second approach is to look past the present to
understand the legislative intent of the bill, which is to create a
uniform system of accountability on the early childhood programming in
Florida.
What is at stake
– Autonomy and independence of private/faith based programs. The Quality
Rating system is to establish provisions for religious/faith based
curricula. This could lead to entanglement issues between government
and religion. Presently, the state through licensure defines a
standardization of quality for programs that are not accredited.
However, accreditation continues to be the methodology as to how many
private schools and stand-alone programs define their accountability.
There is concern that the Quality Rating System will in effect become a
state accredited system, resulting in private-sector accreditation
becoming irrelevant.
As stated above, funding also is a concern. The state has
yet to demonstrate that is willing to fund a higher threshold of
accountability in VPK and in general, early childhood in Florida. Each
year since the VPK program was established, additional requirements have
been adopted for private sector programs without additional funding. The
Legislature, through laws, the State Board of Education in its
rule-making authority, and the FDOE through its technical assistance,
has created lawyers of compliance procedures. For example, earlier this
year, the state released a document indicating that all VPK programs
receiving state funds would be required to comply with 504 of the Civil
Rights Rehabilitation Act if said programs receive federal funds. This
in effect translates to the early childhood program that is under the
auspices of a school receiving Title I funds would be required to meet
civil rights laws/disabilities under 504 even if said early childhood
program was not receiving federal funds to accommodate those with
disabilities.
With the above stated,
the Quality Rating System, if addressing funding and comporting its
standards with national accrediting agencies to create a parallel
structure, has the potential to create a uniformity of standards and in
doing so, provide to parents a rating system or consumer index so they
can make the best decisions on where to place their pre-school children.
And finally, much of the brain research indicates that
education from pre-k 4 through third grade is the most important to
address developmental delays through intervention. If a truly viable
pre-k system were to be established in the state, there is little doubt
that illiteracy would be alleviated and the number of children who are
staffed as special education in elementary and middle school would be
reduced as a result of early intervention.
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