PRIVATE SCHOOL ADMINISTRATORS: BE CAREFUL! ALL THAT GLITTERS IS NOT GOLD! (A LOOK AT GOALS 2000 AND THE ESEA REAUTHORIZATION)
By Dr. Charles J. O'Malley Ph.D.
In 1993 and 1994 Congress and the Clinton Administration worked together toward the enactment of two major pieces of education legislation, GOALS 2000: The Educate America Act and the Improving America's Schools Act.
More popularly known as GOALS 2000 and the Elementary and Secondary Education Act Reauthorization (known to some as the infamous HR 6), the new laws will have a significant -- and in some instances -- a devastating impact on private and parochial schools.
To better comprehend that impact, keep in mind the composition of the community known as private education. Of the 5.3+ children attending private schools, I would estimate about 4 million attend parochial or church-related schools operated by Catholic, Lutheran, Evangelical Christian, Seventh Day Adventist, Fundamentalist Christian, Friends, Orthodox Jewish, Reform Jewish, Episcopal, Presbyterian, Methodist, Mennonite, Amish, Islamic, Greek Orthodox, Pentecostal and other denominations. I list these so you can visualize the extensive diversity represented within the private education community. Other than Catholic, Lutheran, Christian Reform, Orthodox Jewish and -- to a limited degree -- the Seventh Day Adventist schools, participation in federally funded programs is minimal. Independent school students on occasion would participate in the former Chapter 2 Block Grant Program (Title VI in the recent Reauthorization).
Many independent and Christian school administrators choose not to have their students participate because they fear Federal control of their schools. Evangelical and fundamentalist school administrators consider their teachers ministers and their educational programs integral parts of the churches' ministries. Therefore, any program which might lead to licensing of school/church or teacher/minister was anathema.
However, the impact will be felt by those private schools whose students participate in ESEA Title I and Title II programs, and by those who choose not to participate in any governmental programs -- in different ways.
ESEA REAUTHORIZATION
TITLE I
Since 1965, eligible (low-income, educationally-disadvantaged) students attending private and parochial schools (predominant participation is by students attending Catholic, Orthodox Jewish, Christian Reform and Lutheran Church-Missouri Synod schools) have participated (with varying degrees of equity) in Title I/Chapter 1/Title I. Under the Reauthorization provisions and the U.S. Department of Education's proposed rules (issued for comment May 1), private school leaders anticipate 30-70% reductions in the numbers of their students participating and a dilution of quality of the educational programs. (Public) School wide projects, new requirements for ranking schools, and new data collection requirements are at the root of these problems.
TITLE II
Title II, Part A, the Eisenhower Professional Development Program, may have a much greater impact on a broader spectrum of private education -- although no federal dollars are directed to private schools or to private school students.
If you carefully review the following sections, you will note a definite intent to increase both the numbers of teachers who become state certificated and the numbers of teachers certificated by the National Board For Professional Teaching Standards. (Remember, there is only one private school representative on the 64-member governing board of the National Board for Professional Teaching Standards. There is strong representation of the teachers' unions on the board.)
"Authorized Activities"
SEC.2112. The Secretary shall use funds available to carry our this subpart for activities that help meet the purposes of this part, such as --
...(4) supporting the National Board for Professional Teaching Standards;...
...(6) the development of exemplary methods of assessing teachers, other staff, and administrators for licensure and certification;
...(7) activities that promote the transferability of licensure and certification of teachers and administrators among state and local jurisdictions;
"State Applications"
SEC. 2125 (a) APPLICATIONS REQUIRED. --
...(b) PROFESSIONAL DEVELOPMENT PLAN. --(1) Each application under this section shall include a state plan for professional development that --...
...(E) describe specific steps for the reform of state requirements for licensure of teachers and administrators, including certification and recertification,
"State-Level Activities"
SEC. 2126. Each state may use funds reserved under section 2123(2) to carry our activities referred to in section 2125(b), such as --
.(1) reviewing and reforming state requirements for teacher and administrator licensure, including certification and recertification, to align these requirements with the state's content standards...
...(2) developing performance assessments and peer review procedures, as well as other methods, for licensing teachers and administrators;...
...(4) developing or supporting professional development networks...that provide a forum for interaction among teachers and that allow exchange of information on advances in content and pedagogy;
...(6) providing financial or other incentives for teachers to become certified by the National Board For Professional Teaching Standards;...
"Local Allocation of Funds and Allowable Activities"
SEC. 2129. (a) Local Allocation of Funds --
...(b) Authorized Activities -- Each local educational agency and school that receives funds under this subpart shall use those funds for activities that contribute to the implementation of the local educational agency's professional development plan..., such as --
...(13) developing incentive strategies for rewarding schools where a substantial portion of the teachers achieve certification by the National Board for Professional Teaching Standards.
"Definitions"
SEC. 2132. ...(3) The term 'outcome performance indicators'
...Examples of such indicators include --
(A) the degree to which licensure requirements are tied to state standards;
(B) specific increases in the number of teachers who are certified by the National Board for Professional Teaching Standards;
...(D) specific increases in the number of teachers licensed in each core subject.
Keep in mind that most states do not require private school teachers to hold state teaching certificates. Several states provide private school teachers certification on a voluntary basis. If a state agency is seeking federal money under Title II, and needs to show an increase in the numbers of teachers certificated in order to get that federal money, the only way they can show a significant increase is by requiring private school teachers to seek state certification. (I think it's safe to say the great majority of public school teachers are already certificated.)
GOALS 2000
Let's start by looking at Section 306, STATE IMPROVEMENT PLANS. This section establishes a "broad-based" state panel responsible for developing the state improvement plan.
(D) representatives of teachers' organizations, parents, secondary school students, institutions of higher education, business and labor leaders, community-based organizations of demonstrated effectiveness, organizations serving young children, local boards of education, State and local officials responsible for health, social, and other related services, private schools in which students or teachers participate in Federal education programs, and, as appropriate, Indian tribes and others;
Several questions come to mind: first, why specify representatives of teachers' unions, instead of "teachers"? None of the other constituencies named is organization based. Secondly, the rationale behind the private-school-participation-in-federal-programs restriction concerns me. It's unnecessary -- particularly since ALL children are supposedly to benefit from the GOALS 2000 programs. Is there linkage to identifying parochial schools as benefiting from Federally-funded services, thereby removing the applicability of the long-standing "child benefit" theory which has allowed parochial school children to participate in ESEA programs?
Why are independent schools (many of whom do not participate in any federal programs) or Christian evangelical and fundamentalist schools, or Amish schools, etc. restricted from representation on the state GOALS 2000 panels?
In the same section, under TEACHING, LEARNING, STANDARDS AND ASSESSMENTS, sub-section (c) requires each state educational agency to work with "broad-based classroom teacher input". Note the specificity of the educational group to be included. Would private school teachers be included? Under (E), the state plan addresses strategies for improving the State's system of teacher licensing. How will this requirement affect those private school groups opposed to mandated teacher certification? Remember, many Christian school groups maintain their schools are integral parts of their churches' ministries and are not subject to licensure.
SECTION 308, STATE USE OF FUNDS (I) promotes public magnet schools and public charter schools. Private school choice advocates believing in incrementalism, with public school choice and charter schools becoming the first step to vouchers, may applaud the federal acknowledgment of choice. I don't buy that theory. These choice provisions provide a lip-service type of homage to the parental choice movement while throwing the proverbial wet blanket over full parental choice initiatives by providing legislators and policy makers with an easy alternative. Some may recall the "failed" Alum Rock (California) "voucher" experiment of the 1960's. Private and parochial schools were not included, the project died, and parental choice was a dead issue for 25 years. See! Parental choice won't work!
Let's take the less cynical approach. If GOALS 2000 stimulates parental choice within the public sector only, private school parents may - for a variety of reasons - transfer their
children from private schools to public schools. The potential loss of enrollment could lead to the development of a very interesting competition between public and private schools. The winner? Kids! The loser? Possibly private schools! Parental choice advocates now find themselves placed solidly on the horns of a dilemma.
The composition of the National Education Research Policy and Priorities Board, one of the fourteen new "entities" (national and state boards, commissions, and offices in Federal agencies) established through GOALS 2000, shows private school educators just how much private education is appreciated and where it ranks in the law's "priorities":
SEC.921 Establishment Within Office of Educational Research and Improvement
(i) NOMINATIONS FOR BOARD MEMBERSHIP.- Prior to appointing any member of the Board, the Secretary shall actively solicit and give due consideration to recommendations from organizations such as the National Education Association, the American Federation of Teachers, the National Parent-Teachers Association, the American Library Association, the American Association of School Administrators, the National Association of State Boards of Education, the National Indian School Board Association, the Association of Community Tribal Schools, the National Indian Education Association, and other education-related organizations and interested members of the public.
I would hope that "other education-related organizations and interested members of the public" might perhaps possibly maybe include private school representatives.
Another one of the fourteen entities, the National Institute on Educational Governance, Finance, Policy-making, and Management, was created to address the following:
(A) open enrollment programs, public school choice, magnet schools and other systems through which parents may select the public schools and educational programs in which their children are enrolled;
(J) expanding the role of teachers in policy-making and administration at the school and school district-wide level;
(K) disparity in school financing among States, school districts, schools, and schools funded by the Bureau;
(Q) teacher certification at the State and tribal levels;
The very name of this "institute" is troublesome. T'would appear the institute is provided a "carte blanche" approach to fixing education in the states. The public school choice and teacher certification issues, as previously stated, will impact private education. (If I were a public school administrator or a state legislator, I would be worried about two of the institute's charges, (J) and (K).
Section 971, Office of Comprehensive School Health Education, will seriously impact the congregations of many of the church-related school organizations, because of the "values" being promulgated (or not promulgated, depending on one's moral values).
(a) IN GENERAL.- Subsection (c) of section 4605 of the Elementary and Secondary Education Act of 1965 920 U.S.C. 3155(c)) is amended-
(4) To act as a liaison office for the coordination of the activities undertaken by the Office under this section with related activities of the Department of Health and Human Services and to expand school health education research grant programs under this section.
(b) TRANSITION.-The Secretary shall take all appropriate actions to facilitate the transfer of the Office of Comprehensive School Health Education pursuant to the amendment made by sub-section (a).
SEC. 1018 CONTRACEPTIVE DEVICES
The Department of Health and Human Services and the Department of Education shall ensure that all federally funded programs which provide for the distribution of contraceptive devices to unemancipated minors develop procedures to encourage, to the extent practical, family participation in such programs.
This is unusual language to find in an education bill which has been designed to address national standards and goals. As far as private schools are concerned, will those schools whose children participate in Title 1 or Title 6 (ESEA) be required to comply with these provisions? Another interesting dilemma for Catholic school leaders!
Two other unusual sections of GOALS 2000 (Section 1043, Non-smoking Policy For Children's Services and Part D, Midnight Basketball League Training and Partnership) are of concern. Under the Non-smoking Policy section, school administrators seemingly are now responsible for enforcing a no-smoking policy -- not only in their schools -- but also in facilities leased in certain situations. Does this apply to private schools?
Under the Midnight Basketball League program, we have another federal advisory board established. This one (with representatives of Federal agencies serving on it) will determine the times of basketball games, the numbers of players on each team, and where the games will be played. I'm not sure of this program's impact on private schools, unless a private school is able to rent its gym for the federally-funded program. Will the school will have to employ a "no-smoking monitor" or risk losing the program?
In conclusion, while I would like to see a tightening of education standards nationwide -- not national standards -- I don't believe this is the vehicle by which to accomplish that purpose. The provisions of GOALS 2000 are certainly not private-education friendly. In fact, when tied to provisions of Title 2, the Eisenhower Professional Development Program, ESEA Reauthorization, several of the provisions could endanger the autonomy of private education.
All that glitters is not gold.
Dr. Charles J. O'Malley, of Charles J. O'Malley & Associates, Inc.,
Is the Executive Director of the The National Council for Private School Accreditation.
601 Pennsylvania Avenue, N.W. Suite 900
Washington, D.C. 20004
(410) 349-0139The National Council for Private School Accreditation is dedicated to the accreditation process as a viable and responsible means of establishing witness of school excellence. NCPSA is committed to accreditation based on the concept of voluntary peer recognition; that is, the principle that institutions sharing common purposes and distinctives are better able to assist one another in achieving academic excellence and responsiveness to their respective publics and nation.