Using ESEA/ESSA’s New Flexibility to Purge the
U.S. Department of Education’s Ineffective NCLB Initiatives
Dear Colleagues,
Let’s start here:
* We DO need to help failing schools to
turn-around and improve.
* We DO need to determine WHY academically
struggling students are not succeeding so we can deliver effective, timely,
and successful instructional approaches and interventions to address
their needs.
* We DO need to determine WHY students are
exhibiting social, emotional, and behavioral challenges so we can deliver
effective, timely, and successful interventions to address their needs.
BUT. . . we need to completely retire and
rework the U.S. Department of Education’s (USDoE) school improvement,
Response-to-Intervention (RtI), Positive Behavioral Intervention and Support
(PBIS), and Multi-Tiered Systems of Support (MTSS) frameworks, models,
procedures, and approaches immediately.
This is simply because both research and
practice have consistently demonstrated that the USDoE’s School Improvement mandates,
Response-to-Intervention (RtI) approaches, and (UPPER CASE) Positive
Behavioral Intervention and Support (PBIS) framework - - pushed by their many
incestuously funded National Technical Assistance (TA) Centers- - have not worked
and, to the degree they are continuing, do not work.
What more proof do we need?
_ _ _ _ _ _ _ _ _ _
The School Improvement Track Record
From a research-to-practice perspective,
look at the uneven school improvement results
from the last (especially) eight years under ARRA, the School Improvement Grant
(SIG) program, and NCLB’s required school improvement “interventions.” These results were “anchored” by USDoE’s four
mandated transformation or take-over approaches (Congress later added a more
flexible fifth option)- - three of which involved firing the building
principal.
None of them demonstrated consistent,
predictable, or sustained success.
For example:
look at the latest Education Week article analyzing the SIG
results (November 12, 2015; “New SIG Data Serve Up Same Old Conclusion: Mixed
Results”)
For example:
CLICK ON LINK HERE
In fact- - even at face value- - did anyone
with any sense of how to run a business really believe that these four global
approaches were really going to have consistent and high levels of school
turn-around success?
And even when they were “successful,” it was
not due to the selected transformation or take-over approach. Analyses showed that the success was due to
very specific, targeted, strategic strategies that were embedded in the
particular approach that was chosen.
_ _ _ _ _ _ _ _ _ _
The Multi-Tiered RtI Track Record
From a research-to-practice perspective,
was anyone surprised at the recent federally-sponsored RtI report
demonstrating that first through third grade students receiving literacy
interventions using the U.S. Department
of Education’s multi-tiered RtI intervention model actually made less academic progress when
compared to students experiencing similar literacy gaps who stayed in their
regular education programs?
Critically, this was NOT some idiosyncratic
finding. This outcome was based on approximately
24,000 first through third grade students in 13 states that statistically
compared 146 schools using the U.S. Department of Education’s RtI framework in
literacy for at least three years with 100 randomly-selected comparison schools
NOT using the RtI framework in the same 13 states.
_ _ _ _ _ _ _ _ _ _
The Multi-Tiered School-wide Behavioral/PBIS Track Record
And, finally . . . from a
research-to-practice perspective, is anyone surprised at the continuing
research data demonstrating that the
USDoE Office of Special Education Programs’ (OSEP) Multi-tiered School-wide
Behavioral/PBIS framework has demonstrated very few consistent,
sustained, comprehensive, and causally-based changes in student behavior- -
especially across a significant majority of the 19,000 PBIS schools that the
PBIS National TA Center says exist across the country?
. . . and especially when the behavioral/PBIS
outcomes focus simply on decreasing Office Discipline Referrals (a horribly
unreliable piece of data), and NOT comprehensively on:
* Increasing students’ classroom engagement
and academic success;
* Increasing students’ interpersonal, social
problem-solving, conflict prevention and resolution, and emotional coping
skills;
* Decreasing the disproportionate number of
minority and special education students who are sent to the Principal’s Office
for discipline and/or who are suspended or expelled; and
* Addressing the social, emotional, or
behavioral needs of students with serious and persistent needs- - including
significant mental health needs.
_ _ _ _ _
Indeed, examples of recent qualitative
and quantitative research studies questioning or disproving the efficacy of
PBIS over the years have been published by:
1. The U.S. Department of Education in a
May, 2013 report School-Wide Positive Behavior Support Framework: A Review
of Approaches to Implementing the Framework, Tier I Behavior Support Programs
and Tier II Behavior Intervention Programs that actually was “hidden” from
the public-at-large.
Indeed, rather than receiving wide public
notice and distribution, this Report appeared only as an Appendix to an
RFP that- - amazingly- - is currently funding another $19 million grant
to validate the PBIS framework that the USDoE has been funding since 1997,
and that it continually cites as “evidence-based” (see Appendix A1 on the
middle right-hand side of the page linked to below).
2. A team of Dutch researchers who published
(November, 2014) a meta-analysis involving 54 studies (three-quarters from the
U.S.) of classroom management programs at the elementary school level that
looked at teacher behavior, student behavior, teacher-student relationships, or
students’ social-emotional development.
This study concluded that School-wide
Positive Behavior Supports showed no statistical effects in terms of improving
the outcomes above.
_ _ _ _ _ _ _ _ _ _
The New ESEA/ESSA: Toss the Multi-Tiered RtI and School-wide
Behavioral/PBIS Frameworks
The recently-passed ESEA/ESSA has
transferred much of the responsibility for developing, implementing, and
evaluating effective school and schooling processes to state departments of
education across the country.
And so, as the new ESEA/ESSA has already
“retired” the four mandated strategies for school improvement, so too- - given
the research and results- - state departments of education (and their districts
and schools) should similarly retire (purge) any MTSS Academic and
School-wide Behavioral/PBIS framework and/or approaches that are based on
those initiated by the USDoE.
Indeed, as state departments of education
are now responsible for rethinking the school improvement process for their
least successful schools from the ground up. . .
. . . they should revisit the research
while identifying effective psychometric and psychoeducational practices
(see 10 examples below) and re-design their (lowercase) multi-tiered
systems of support and positive behavioral intervention and support approaches-
- again from the ground up.
If state education departments (or
districts/schools) feel that they need “permission” to do this, know that:
* The term “RtI” or any of its
derivatives never appears in the new
ESEA/ESSA bill.
* The term “multi-tiered system of
supports” appears only five times in the entire law. Moreover, the term is always written in
lower case- - (except where the term is the title for a section of the law),
and the acronym “MTSS” (designating a specific framework or model of
multi-tiered services) NEVER appears.
* The term “positive behavioral interventions
and supports” appears only THREE times in the entire ESEA/ESSA law. Moreover, the term never appears in UPPER CASE, the “PBIS” acronym never appears, and the word
“framework” (as in PBIS framework) NEVER appears in the law.
_ _ _ _ _
Beyond this:
The new ESEA/ESSA defines “multi-tier
system of supports” as “a comprehensive continuum of evidence-based,
systemic practices to support a rapid response to students’ needs, with regular
observation to facilitate data-based instructional decision-making.”
Relative to the five times the term appears
in the law, two appearances are in the definition as above. The other three citations appear in sections
where the law talks about the need for all districts receiving ESEA funds to:
* “(F) (D)evelop programs and activities
that increase the ability of teachers to effectively teach children with
disabilities, including children with significant cognitive disabilities, and
English learners, which may include the use of multi-tier systems of support and
positive behavioral intervention and supports, so that such children with
disabilities and English learners can meet the challenging State academic
standards.”
* “(4) Provid(e) for a multi-tier system of
supports for literacy services.”
* Offer professional development
opportunities that “(xii) are designed to give teachers of children with
disabilities or children with development delays, and other teachers and
instructional staff, the knowledge and skills to provide instruction and
academic support services, to those children, including positive behavioral
interventions and supports, multi-tier system of supports, and use of
accommodations;”
_ _ _ _ _
Meanwhile, the term ”positive behavioral
intervention and supports” is NEVER defined in the new law- - nor is a
previous definition in law referenced.
Given my research and to my knowledge, this term has never been defined
in law or statute.
That aside, two of the three times that this
term appears in the law have been quoted above.
The third appearance of the term is in the “Activities
to Support Safe and Healthy Students” section of the law where Section G
states:
* “(G) implementation of schoolwide positive
behavioral interventions and supports, including through coordination with
similar activities carried out under the Individual with Disabilities Education
Act (20 U.S.C. 1400 et seq.), in order to improve academic outcomes and school
conditions for student learning;”
NOTE that both ESEA and the
Individual with Disabilities Education Act (IDEA) ALWAYS use this term in
the lower case. The term is NEVER capitalized
in either law, nor do they ever use the “PBIS” acronym.
Thus, the USDoE’s PBIS Framework is not
required by either ESEA or IDEA (in contrast to public statements made by
the PBIS TA Center).
_ _ _ _ _ _ _
The New ESEA/ESSA: Scientific Principles to Include in any
Reconceptualized Multi-Tiered System
In 2012, I wrote a technical assistance
paper, National Concerns about RtI and PBIS: A Review of Policy and Practice
Recommendations Not Based on Research or Effective Practice.
CLICK HERE for the TA Paper [Look at the 2nd
Entry on the Page]
In that TA paper, I identified 10
multi-tiered system of supports/positive behavioral intervention and support
practices that either have been ignored by the USDoE frameworks or approaches,
or have been mistakenly adapted and used.
These 10 practices are summarized
below. It is strongly recommended that
these practices be infused throughout any state’s reconceptualization of their
approaches in these areas.
1. Multiple gating procedures
need to be used during all academic or behavioral universal screening activities
so that the screening results are based on (a) reliable and valid data that (b)
factor in false-positive and false-negative student outcomes.
2.
After including false-negative and eliminating false-positive students,
identified students receive additional diagnostic or functional assessments to
determine their strengths, weaknesses, content and skill gaps, and the
underlying reasons for those gaps.
When screening procedures do not exist or
are not accurate, Steps 5 and 6 should occur with all students who are
academically struggling in the classroom or demonstrating social, emotional, or
behavioral concerns in any school setting.
3.
When focusing- - especially at the elementary school level- - on helping
students to learn and master foundational academic skills (e.g., phonemic
awareness, phonetic decoding, numeracy, calculation skills), students should be
taught at their functional, instructional levels- - regardless of their age or
grade level.
When focusing- - at the secondary level- -
on academic content, comprehension, and application skills, teachers need to be
sure that students have mastered the foundational and prerequisite literacy,
math, written expression, and oral expression skills needed to be successful.
4. All
students should be taught- - every year- - social, emotional, and
behavioral skills as part of an explicit Health, Mental Health, and Wellness
preschool through high school curriculum.
These skills should especially be applied to students’ academic
engagement, and their ability to work collaboratively in cooperative and
project-based learning groups.
5.
Before conducting diagnostic or functional assessments, comprehensive
reviews of identified students’ cumulative and other records/history are
conducted, along with (a) student observations; (b) interviews with
parents/guardians and previous teachers/intervention specialists; (c)
assessments investigating the presence of medical, drug, or other
physiologically-based issues; and (d) evaluations of previous interventions.
6. Diagnostic or functional assessments evaluate
students’ instructional settings. These
assessments evaluate the quality of past and present instruction, the integrity
of past and present curricula, and interventions that have already been attempted. This helps determine whether a student’s
difficulties are due to teacher/instruction, curricular, or student-specific
factors (or a combination thereof).
7.
Diagnostic or functional assessments to determine why a student
is not making progress or is exhibiting concerns should occur prior to
any student-directed academic or social, emotional, or behavioral
interventions.
These assessments should occur as soon as
academically struggling or behaviorally challenging students are identified
(i.e., during Tier 1).
These assessments should not be delayed
until Tier III- - otherwise it is likely that the Tier I and II
interventions implemented (in the absence of these assessments) will not be
successful, will make the student more resistant to later interventions, and actually
may change the problem or make the original problem worse.
8. Early
intervention and early intervening services should be provided as soon as needed
by students. Tier III intensive services
should be provided as soon as needed by students. Students should not have to receive or
“fail” in Tier II services in order to qualify for Tier III services.
Early intervention services include- - based
on the diagnostic or functional assessment results- - the use of assistive
supports, skill-gap remediations, instructional setting and process
accommodations, and curricular modifications.
Tier II and III services include strategic
or intensive curricular or skill-targeted strategies or interventions, other
services or support programs, student-tailored compensations (for academic
problems), and crisis-management services (for social, emotional, or behavioral
problems).
9.
When (Tier I, II, or III) interventions do not work, the diagnostic or
functional assessment should be revisited, and it should be determined if (a)
the actual student problem was either accurately identified or has changed; (b)
the assessment results correctly determined the underlying reasons for the problem;
(c) the correct instructional or intervention approaches were selected; (d) the
correct instructional or intervention approaches were implemented with
integrity, and with the intensity needed; and/or (e) the student needs
additional or different services, supports, strategies, or programs.
10.
The “tiers” in a multi-tiered system of supports reflect the
intensity of services, supports, strategies, or programs needed by one or
more students.
The tiers do not reflect the
percentage of students receiving specific intensities or services, nor do they
reflect the organization (i.e., small group or individual), the delivery setting
or place, or the expertise of the primary providers of those services.
Moreover, the services and supports in a
particular tier in a specific school or district are relative and dependent on
the available resources- - including the number, skill, and expertise of the
existing core and support staff.
For example, in a rural, poor school
district, the absence of a Tier I social skills curriculum taught by the
classroom teachers for all students might result in a number of students with
social, emotional, and behavioral gaps that require the involvement of “Tier
III” community mental health referrals and staff- - because the district does
not have the mental health support staff to provide these services.
A larger school district that had a Tier I
primary prevention social skills curriculum would have fewer students with
social, emotional, and behavioral gaps; and these students would receive “Tier
II” supports from the counselors, school psychologists, and/or social workers
employed by the district.
_ _ _ _ _ _ _ _ _ _
Summary
In summary: the School Improvement, RtI, and PBIS
approaches pushed by USDoE during the NCLB years did not worked. . . and they
did not demonstrate consistent, sustained, comprehensive, or causal changes
in student, staff, or student outcomes.
Because of their poor results, the USDoE
actually “rebranded” RtI and PBIS a few years ago using their “Multi-Tiered
System of Supports” (MTSS) designation- - but these frameworks and approaches
(see the studies cited above) have not worked any better. Significantly, the rebranding was done
largely because the USDoE knew that educators had become disenchanted and
frustrated with original RtI and PBIS approaches, and strategically decided to
“reboot the system” so that the limited RtI and PBIS results could be put “into
the past.”
I know that some have been surprised at the
largely inconsequential School Improvement, RtI, PBIS, and MTSS results over
the past number of years. This is
because many believe that the U.S. Department of Education, their state
departments of education, and the national and state experts espousing these
approaches know what they were talking about.
But remember, people only know what they
know. They often don’t know what they
don’t know.
At the same time, let’s not under-estimate
the impact of politics.
Indeed, let’s remember that Diane Ravitch
strongly advocated for high stakes testing when she was working in the USDoE
during the Bush administration, and then completely changed her view after she
left.
Moreover, let’s remember that the $6 billion
Reading First program was discontinued by Congress because the USDoE was
manipulating the grant selection process and funneling money to a selected
number of specific literacy series and intervention programs.
These are some of the very clear reasons
(there are others) why the new ESEA/ESSA has language in it that has
explicitly taken power and responsibility away from the U.S. Department of
Education and its Secretary.
In essence, Congress wanted to ensure that
the USDoE could not continue to establish and dictate its own educational standards
and approaches, or to overstep and abuse its authority- - over and above any legislation
that it passed.
But in limiting the USDoE’s reach, ESEA/ESSA
gives states, districts, and school many wonderful opportunities.
_ _ _ _ _
So. . . let’s end where we began:
* We DO need to help failing schools to
turn-around and improve.
* We DO need to determine WHY academically
struggling students are not succeeding so we can deliver effective, timely,
and successful instructional approaches and interventions to address
their needs.
* We DO need to determine WHY students are
exhibiting social, emotional, and behavioral challenges so we can deliver
effective, timely, and successful interventions to address their needs.
AND. . . with its emphasis on design,
implementation, and evaluation at the state and local levels, ESEA/ESSA gives
these units opportunities to reconceptualize (a) school improvement; (b) school
discipline, classroom management, and student self-management (i.e., lower
case positive behavioral intervention and support systems); and (c) (lower
case) multi-tiered systems of support.
BUT. . . if state departments of
education continue to embrace the past, unsuccessful NCLB RtI, PBIS, and MTSS
approaches, I hope that districts and schools will work together to
influence these departments of education to stop and replace these
practices.
This is NOT about politics or
preferences. This is about our current
and next generations of students, graduates, post-graduates, and employees.
If there is anything that I can do for you
in these areas (as a former department of education federal school improvement
grant director for 13 years), please do not hesitate to contact me.
Best,
Howie
