On March 30th, 2012 the Dignity in Schools Campaign submitted comments on the U.S. Department of Education's Teacher Incentive Fund, a part of the Obama administration's educational platform which would provide funds for implementing teacher incentive programs in states and districts with “high need schools.”

While the DSC agrees that teachers and administrators are the most important in-school factors impacting the quality of a student’s education and that teachers should be encouraged and supported, the DSC disagrees with the proposal that hiring, firing and bonus decisions should be based significantly on student growth measured through standardized tests. Relying on standardized test scores to determine which teachers get raises and which teachers will lose their jobs creates a whole new form of “high-stakes” testing, and can only result in even more "test-score" based curricula.  This approach creates new incentives for pushing out low-scoring students.

There is very limited research on the effectiveness of performance-based compensation, far too little to introduce it on a national scale.  Sadly, some of the strongest research on teacher evaluation warns against tying student test scores to teacher pay, as such practices promote cheating and “teaching to the test.”  We have urged the Department of Education to discontinue the Teacher Incentive Fund until it has conducted research on how performance-based compensation impacts school pushout.  We have also urged the Department to consider other ways to measure student and teacher performance, including monitoring school disciplinary rates.  Our students and teachers deserve better than to let a standardized test determine who gets to stay in the classroom.
 
In the comments submitted by the DSC offered the following responses to the Notice of Proposed Priorities:
 
1. ED should reduce reliance upon student scores on standardized tests and place greater emphasis on other indicators of student learning, such as student portfolios and parent and student surveys, in evaluating teachers.
 
To avoid the harms of “teaching to the test” and to ensure that students are fully prepared for college and careers with 21st century skills, ED must promote student learning and growth across multiple dimensions in a manner that does not narrowly rely on students’ standardized test results. We support ED’s proposed requirement that teachers be observed at least twice per year. In evaluating both teachers and administrators, ED should also require LEAs to review student5 and parent surveys, including the types of school climate surveys encouraged under ED’s Safe Schools Healthy Students grants.

Specific recommendation: First, ED should revise Proposed Priority 3 to require applicants to develop evaluation rubrics that include the results of parent and student surveys. Second, ED should revise the proposed definition of student growth to include: “(c) for all grades and subjects, a student’s performance on rigorous assessments, such as student portfolios and project-based coursework, that better measure critical thinking, problem-solving, and other skills for the 21st century workplace.”
 
2. ED should require Teacher Incentive Fund grantees to include classroom management, conflict prevention and resolution practices, and culturally responsive practices among the “key competencies” for evaluating teachers.
 
School safety, student discipline policy and academic achievement are inextricably linked. Students cannot learn unless they are safe. At the same time, emerging research demonstrates that some discipline policies implemented in the name of safety and order actually undermine student achievement. Yet, there are also evidence-based, positive, preventative approaches to classroom management and school discipline that result in improved attendance, achievement, and teacher safety and morale. Any list of key competencies for teachers and administrators must include competencies that reflect these best practices while enhancing teacher effectiveness, including positive classroom management practices and culturally responsive practices.

Specific recommendation: ED should revise its definition of vision of instructional improvement to read, “A vision of instructional improvement is a summary of the key competencies and behaviors of effective teaching that an LEA views as necessary to produce high levels of student achievement, as well as how educators acquire or improve these competencies and behaviors. This summary must include competencies that promote effective instruction, such as restorative practices, positive behavior supports, social and emotional learning, and culturally responsive pedagogy.
 
3. ED should require grantees to annually collect and report the disciplinary indicators included in the Civil Rights Data Collection and show improvement in each category over the duration of the Teacher Incentive Fund grant.
 
To demonstrate the effectiveness of Teacher Incentive Fund grants and best address pushout, ED should require Teacher Incentive Fund grantees to monitor and show improvement in school disciplinary indicators throughout the grant period.

Specific recommendation: ED should add an eighth Proposed Requirement for the Teacher Incentive Fund and require any grant applicant to both a) annually collect and report, at the school and district levels, the disciplinary indicators included in the Civil Rights Data Collection and b) demonstrate meaningful improvement at the school and district levels under each disciplinary indicator during the duration of the Teacher Incentive Fund grant. If a school or district fails to reduce its disciplinary rates in the first year of the grant, then it should be required to allocate 15% of its remaining TIF funds per year for quality professional development in evidence-based approaches to school discipline, akin to the Early Intervening Services provision of the Individuals with Disabilities Education Act (20 USC §1418(d)(2)).