The Iowa Department of Education and their Director, Brad Buck, released the criteria necessary for receiving a waiver under Iowa Law requiring a start date no earlier than the week where September 1st falls. On December 12, Iowa Governor Terry Branstad director Mr. Buck to no longer automatically grant waivers of the school start date, a common practice in Iowa after the governor originally signed the law in 1983. I have previously blogged about this decision to begin enforcing the law more than 30 years later. To briefly recap, the governor wrote a letter to Director Buck requesting the IDOE stop automatically granting waivers to school districts applying to start school earlier than September 1st. The governor's reasoning was as follows:
Starting in early to mid-August unnecessarily interferes with families' summer plans and seasonal hiring while it does nothing to improve the quality of education. It also results in students missing class to participate in 4-H, FFA, and other Iowa State Fair activities. Meanwhile, a new state law lets schools set a school calendar with the traditional 180 instructional days or 1,080 hours, providing new flexibility.
I added the bold emphasis in this quote because the governor and the IDOE have asked schools to provide scientific evidence demonstrating a "negative and significant" impact on student learning. The burden of proof has been laid at the feet of the Iowa school boards. However, the governor is allowed to make assertions like the one emphasized above without any evidence to back it up. Rather, he cites summer plans, seasonal hiring, and the Iowa State Fair.
Director Buck laid out the guidelines for school start date waivers in a document published on January 21st. In this document, he defines negative educational impact as: "as an adverse effect on student academic achievement and/or student learning environment. To meet the statutory test, the district must provide objective evidence demonstrating the negative educational impact rises to the level of “significant.” Significant is defined as very important or consequential."
The document continues:
A. The director will consider the evidence submitted as a whole. In determining whether an applicant district has met the statutory standard, the director may consider:
- Evidence that students affected by the requesting district’s calendar are adversely affected in a negative and significant manner by starting school as required by the Iowa Code, as demonstrated by valid and reliable measures of local academic achievement and/or learning environment;
- The percentage of the student body negatively affected by starting school as required by Iowa Code;
- The magnitude of the negative effect, as determined by valid and reliable student educational data or other valid and reliable measures of local academic achievement and/or learning environment;
- The durability of the harm and the efforts required to remedy the harm;
- Whether scientifically based research supports the district’s claim;
- Whether other peer-reviewed research supports the district’s claim;
- Whether alternatives to seeking a waiver have been considered and determined impossible or impractical;
- Any other evidence deemed appropriate by the Director.
B. The following will not constitute a significant negative educational impact:*
- Claimed adverse effect based on personal anecdotes, opinion pieces, or advocacy position papers;
- Adverse effect that can be resolved or remedied through means otherwise available in the Code, i.e. hours-based calendar;
- Extracurricular competition or scheduling (This is because the competition schedules will adapt to start dates. See FAQ 7);
- Post-Secondary Enrollment Option (PSEO) or local community college schedules (A student taking a PSEO course from community college or other institutions of higher education is not prohibited from attending college classes prior to the start of the district’s calendar. See FAQs 4 and 6);
- Completion of first semester before winter break (An hours-based calendar allows districts flexibility to accomplish this.);
- Professional development of teachers (The law currently allows schools to offer professional development before the start of the instructional calendar. Iowa Code § 279.10(1). The Code allows professional development prior to the start of instruction.);
- Snow days (An hours-based calendar offers sufficient flexibility, and no amount of early start will reduce the need to make up missed instruction due to predictably unpredictable Iowa winters.);
- Bus scheduling (Bus schedules and contracts may be revised to account for adjusted start dates.);
- Other rationales not related to academic achievement, instruction and/or learning environment.
*This is not an all-inclusive list, but rather an attempt to provide guidance to school districts.
Here are the FAQs he references in his guidelines:
Question 4: How will schools deal with Post-Secondary Enrollment Option (PSEO) and concurrent enrollment courses?
Answer 4: Many sections of concurrent enrollment courses are delivered solely at high school locations with sufficient contact time to start later than on-campus sections. It is possible that adjustments can be made to start dates of regional center or concurrent enrollment-only sections as well.
Question 6: May a high school student enrolled in a concurrent enrollment course at a college begin that class before regular classes start at the high school?
Answer 6: Yes, a high school student who is concurrently enrolled may begin to attend the course at the college or university prior to the beginning of the school year for the public, nonpublic, or independently accredited school.
Question 7: Can we play games for athletics before the start of school?
Answer 7: Athletic practices and games are governed by the Iowa High School Athletic Association. Please see Iowa Administrative Code §281—36.14(5).
I want to draw attention to a few points. First, Director Buck states they will not accept "claimed adverse effect based on personal anecdotes, opinion pieces, or advocacy position papers." How did the Governor come to the conclusion that earlier start dates interfered with families' summer plans, seasonal hiring, and the Iowa State Fair? Is their scientific evidence supporting this conclusion? What is the magnitude of this supposed interference?
Second, Director Buck claims "the competition schedules will adapt to start dates." His FAQ then states that athletics are governed by the IHSAA and the IGHSAU. Does Director Buck realize that these two organizations contract with facilities across Iowa for the state championship events throughout the school year? I would be willing to bet that because the IHSAA has a projected unified calendar out until the 2018-2019 school year, that they have contracts extending out that far. How are these organizations going to adapt? Even if they can reschedule these contracts, are we going to push the football state championships back even farther? This would put them on top of Thanksgiving, interfering with family plans. Are we going to push the basketball state championships back even farther? This would put them on top of many schools Spring Breaks, interfering with family plans.
Third, Director Buck expresses the wish that students enrolled in post-secondary educational opportunities while in high school should begin attending these courses prior to the start of their high school classes. Won't these too interfere with families' summer plans? Seasonal hiring? The Iowa State Fair?
Fourth, look at his final FAQ:
Question 8: How will the change in start date affect testing windows for universal screening, placement tests for AP courses, and other assessments?
Answer 8: Statewide windows for universal screening will be adjusted to accommodate district start dates. It is recommended that local assessment windows also be adjusted to allow adequate time for instruction to occur if this is a necessary component of the assessment process.
He does not address the Advanced Placement exams issue at all. Those are nationally set dates. Students in Iowa schools will be losing days and even weeks of instructional time to prepare for the Advanced Placement exams.
Luckily, the Iowa legislature is responding. The Des Moines Register wrote today that on January 15, the Iowa House would allow local school boards to set their school start date, eliminating start date waivers entirely. The Iowa Senate introduced a bill on January 20th, establishing August 15 as the earliest possible start date and June 15 as the latest possible end date. Schools that move outside of those dates would see a reduction in state funding.
Unfortunately, many of us are worried that the governor is just using the school start date issue as a red herring for the issues arising with school funding. When push comes to shove, the governor can ease up on the school start date, distracting from the fact that he has proposed to poorly fund education in Iowa. More on that later.
A colleague, Pat Kearney, recently published a post on advocacy. Now is the time to advocate in Iowa, folks. Our governor is crippling education in our state. Speak up to your state legislators. Let them know we don't want Iowa schools to look like they did in the 80s under Governor Branstad's last term.