Goodbye, PASS – Hello, Undefined Process
Typically, when any state agency proposes changes to existing administrative rules, it is in response to legislative action or some kind of experience with the impact of the previous version of those rules. Take the A-F Report Cards for example. The implementation was an abject disaster, and for the most part, schools view them as completely irrelevant. Legislators have proposed multiple bills to either change or eliminate the existing rules. The SDE responded to this with several proposed changes, which upon careful reading, seem to make things worse.
That’s why so many people have written to me alarmed at the proposed rule changes on the SDE website for eliminating PASS and replacing them with a process largely to be determined by the state superintendent. There was no legislative mandate for this. There was no system failure that rendered it necessary. And as I’ve responded to several of those who’ve written me, I can’t tell if this is absolutely nothing or something huge. The accompanying impact statement includes the following:
The purpose of the proposed rule at 210:15-1-3 is to establish a procedure for adoption and publication of academic content and process standards by the State Department of Education and the State Board of Education in accordance with the provisions of 70 O.S. § 11-103.6a. Because the academic content and process standards have increased in volume, the Agency believes that discontinuing the use of the rulemaking process to promulgate academic content and process standards as rules in the Oklahoma Administrative Code and replacing the process with a new procedure for submission for Board approval will reduce administrative costs and will afford education stakeholders more opportunity to provide input prior to revisions of the academic content and process standards. The proposed rule provides for implementation of a volunteer advisory council to provide the State Department of Education with recommendations for revision of the academic content and process standards prior to drafting proposed standards. The proposed rule also provides for a process of review and public comment of draft proposed standards by the public prior to submission of the standards to the State Board of Education for approval.
As far as I can tell, this change removes all standards that have been in place for years and replaces them with nothing. In place will be a process that has less interaction and supervision than previous standard-setting efforts. In other words, the SDE will have the option to reinvent the standards with as little or as much input as they want from professional educators.
If this is just the SDE clearing out space for the Common Core State Standards, so be it. I just can’t accept that it’s as simple as that.