Reimagining Education

MO No Child Left Behind Waiver Request

The Missouri Department of Elementary and Secondary Education (DESE) is applying for a waiver from the Federal Department of Elementary and Secondary Education that would free it from some of the restrictions of the Federal Elementary and Secondary Education Act, which is better known as No Child Left Behind.

The Federal Department of Education announced this Fall that they would offer waivers to states that were able to  meet several requirements. (Those requirements are outlined here). DESE has put the first draft of its Waiver Request online (you can read the draft here) and is seeking comments from parents, elected officials, educators, concerned citizens, and non-profit leaders.

The Children’s Education Alliance of Missouri submitted its comments, which are copied below, this afternoon. It is important that DESE hear from people across Missouri about the waiver. I hope that you will take some time to read the Waiver request and submit your comments.


December 14, 2011

Commissioner Chris Nicastro
Missouri Department of Elementary and Secondary Education
205 Jefferson St
Jefferson City, MO 65102


Commissioner Nicastro

I would like to thank the Missouri Department of Elementary and Secondary Education for giving the public a chance to comment on DESE’s Elementary and Secondary Education Act Waiver Request. It is commendable that Commissioner Nicastro and the DESE staff invest so much time in listening to the voices of parents, educators, elected officials, and non-profits dedicated to improving education for all Missouri’s children.

The Children’s Education Alliance of Missouri (CEAM) is a non-profit organization whose mission is to support policies that encourage access to high quality educational options for all Missouri students, including those who do not succeed in a traditional academic setting. As such, we appreciate DESE’s willingness, through the request for an Elementary and Secondary Education Act (ESEA) Waiver from the Federal Department of Education, to work with individual school districts to ensure the policies that govern Missouri’s schools are not only flexible enough to meet the needs of districts across our geographically and demographically diverse state, but also maintain high standards and hold teachers, administrators, and school boards accountable for achieving high student outcomes.

While we are pleased that DESE is using the opportunity to apply for an ESEA Waiver to look at its own accountability standards and to alter some of its current practices in an effort to align itself with best practice and research, CEAM has a few concerns about the draft waiver. These concerns are detailed below:

1. Student Growth Model

CEAM appreciates DESE’s willingness to think critically about the best way to include student growth data in the Annual Performance Reports for each of Missouri’s 522 school districts. We have been closely watching as DESE decides between the MU Value Added Growth Model and the Student Growth Percentiles Model.

Our research indicates that the MU Value Added Growth Model (MU Model) is far superior to the Student Growth Percentiles (SGP). The MU Model is much more accurate and gives a more fair and balanced view of what is happening  at both the district and building level. The SGP is untested in other states/districts, and the methodology behind this model has been called into question by many respected academics. As such, CEAM believes DESE will not be able to use the results generated from the SGP to make determinations about the accreditation status of districts, the performance of individual buildings, or the effectiveness of teachers. For the ESEA Waiver to be effective in Missouri, CEAM feels as though DESE has no choice but to ensure the MU Model is the Missouri model for measuring student growth.

2. Subgroup Reporting

While the draft ESEA Waiver Request does mention that there will be subgroup reporting, there is no mention of what subgroups will be monitored and how that information will be used. CEAM feels that DESE needs to ensure districts are still responsible for reporting the achievement levels of all subgroups required under the current ESEA law. Additionally, DESE should state in the Waiver Request that districts will not only be held accountable for all student achievement, but that they also will be held accountable for closing the achievement gap between white and minority students as well as between economically disadvantaged and non-economically disadvantaged students.

3. Last in—First out

The Draft Waiver mentions Missouri’s antiquated Last in—First out policy, which is currently required by the Revised Missouri Statute 168.122. CEAM understands DESE is required to comply with current Missouri law. However, there is plenty of evidence to show that this current law is not good for children. CEAM suggests that DESE add repealing this statute to its legislative priorities for the 2012 session and include this and other legislative priorities in the draft Waiver Request.

Thank you for considering our concerns. If you would like to discuss them further, you can reach me at 314-809-5042 or kcasas@ceamteam.org.



Katherine Casas
State Director
Children’s Education Alliance of Missouri


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