The Virginia Department of Education has proposed revising the regulations governing textbook selection and funding. You can read the proposed changes here.
While I believe these changes are an improvement over the previous version of the regulations, I believe the intent of the regulations and responsibilities of the VA DOE and BOE for enforcing the new regulations need to be clarified.
The changes in the regulations streamline and clarify the process by which textbooks are adopted. The VA DOE will consolidate the two regulations for local school district adoption of textbooks into one procedure. The new procedure local school district will be expected to follow when selecting textbooks is:
B. Selection of textbooks by local school boards
Local school boards shall adopt procedures for the selection of textbooks. These procedures shall include, at a minimum, the following:
1. Appointment of an evaluation committee by the local school board to review and evaluate textbooks in one or more of the subject areas.
2. Notice to parents that textbooks under consideration for approval will be listed on the school division’s Web site and made available at designated locations for review by any interested citizens. Provisions shall be made for those reviewing such textbooks to present their comments and observations, if any, to the school board through locally approved procedures. Actions which are necessary to assure appropriate consideration of citizen comments and observations shall be taken and adequate time for such consideration shall be allowed.
3. Use of selection criteria that has been approved by the local school board.
The Board of Education will be holding Town Hall Meetings on June 3rd and 10th for citizens to provide comments on the proposed changes. The closest meeting to us will be at TC Williams in Alexandria on June 10 at 7PM. Citizens can also submit questions or comments in writing to the Board of Education through July 26.
I believe two points need to be clarified :
(1) when and how frequently do the textbook evaluation criteria need to be approved by the local school board; and,
(2) what happens if a school district fails to follow the regulations?
Why is it important to clarify whether point # 3 of the regulation requires local school districts to present the criteria they will be using to select a textbook each time they select textbooks or whether the regulation permits a one time approval of a generic set of guidelines?
Because the criteria used by local school district to select a textbook define the instructional approach the district will be following. Presenting the criteria each time requires the local school district to justify its chosen instructional approach for each subject to district residents while adopting generic guidelines one time keeps citizens in the dark about how their children will be taught various subjects.
Under the new regulation, a local school board could adopt a generic set of criteria calling for alignment with the SOLs and freedom from bias, one time in 2004, and claim that those are the district’s textbook evaluation criteria. In 2012, when the district is considering Science textbooks, there would be no presentation to the public or local school board of what characteristics the district considers important in a Science textbook because the evaluation criteria (alignment with the SOLs and freedom from bias) were approved in 2004. The same would happen when textbooks are considered for Math, English, Foreign Languages, History, and Social Studies. The specific criteria used to select textbooks for any subject would never be presented to the public or approved by the local school board because the local school board approved “the criteria” one time in 2004.
Alternately, the local school district would have to present the specific criteria it developed to select textbooks for a given subject to the public and local school board each time they consider textbooks for that subject. Therefore, in 2012 when the local school district is considering Science textbooks, the school district would present the characteristics they consider important in a Science textbook to the public and obtain the approval of the school board of those characteristics. The same process would happen when textbooks are considered for Math, English, Foreign Languages, History, and Social Studies. The specific criteria used to select textbooks for any subject would always be presented to the public and approved by the local school board each time textbooks are considered for that subject.
So that school districts don’t have to purchase new textbooks for every subject in one year, textbooks are reviewed and selected on a rotating basis by topic. History / Social studies textbooks will be / were selected by local school districts in 2010 ; Math textbooks will be selected by local school districts in 2011; and, English and Science textbooks will be selected in 2012. The next effect is that textbook are reviewed and selected by local school districts almost each year. They are for different subjects each year, but the process occurs almost annually. Knowing when the criteria the district will be using to select a textbook must be presented to the public and approved by the school board is vital to ensuring that this process is conducted in as consistently and accurately as possible.
Why is it important to know what will happen if a local school district fails to follow the procedure?
Prince William County schools claims that a regulation approved by the PWC school board in 2005 contains the district’s official textbook evaluation criteria (alignment with the SOLs and freedom from bias). The net effect being that in 2006 the school district radically changed the way Math is taught to our children and adopted a textbook which was not recommended by the VA DOE without notifying parents or the school board that the textbook was rejected by the VA DOE because it failed to adequately meet state standards of learning.
PWCS claims that it is in compliance with state regulations because it approved the “criteria” when the PWC school board approved the generic regulation in 2005. Parents, including contributors to this blog, have contested PWCS’ assertion to the PWC SB, and the VA Attorney General, Board of Education, and Department of Education. The PWC SB did nothing. The AG issued his opinion that school district must follow VA BOE issued regulations but that the authority for enforcing compliance with and investigating failures to follow those regulations lies with the VA BOE and DOE.
According to representative of the VA BOE and DOE, the only step districts need to take to demonstrate that they followed state regulations is certify to the state that they did so. PWC certified to the state that they followed BOE regulations. As far as the VA DOE and BOE are concerned, that certification effectively closed the issue. The VA BOE and DOE have refused to investigate further citing lack of resources and inadequate guidance from the VA General Assembly regarding enforcement.
This does not change with the revised regulation. Local school districts simply need to certify that they followed state regulations to be in compliance. Investigations into charges of non-compliance by the VA DOE or BOE are not and will not happen.
To reduce confusion and ensure that all parties know the proper process, the VA Board of Education needs to clarify these points.