9.3.. WWW"... .0... Ziasufi. Eti. ‘ x , y, ..‘..mw.éi..n .2 ‘ . ‘ , m , V. , . 3. m. 1.3.6.“. . , V ‘ \L 3 1.. . a . x (.1; . ‘ . . .. J a e 3.9% 3.32.”, . . , , . , -z. .m .34.. , .iv 3 I 2.. 3... u .3 SA V 3.. . m WI: 3 LIBRARY Michigan State University This is to certify that the dissertation entitled RESPONSE OF K—12 DISTRICTS TO POLICY MANDATES INTRODUCED THROUGH FEDERAL AND STATE LEGISLATION presented by Kellie Terry has been accepted towards fulfillment of the requirements for the Ph.D. degree in Educational Administration //2‘/ 775) (27 & ”7 J7 Date MSU is an afiinnative—action, equal-opportunity employer PLACE IN RETURN BOX to remove this checkout from your record. TO AVOID FINES return on or before date due. MAY BE RECALLED with earlier due date if requested. DATE DUE DATE DUE DATE DUE 6/07 p:/C|RC/DateDue.indd-p.1 RESPONSE OF K-12 DISTRICTS TO POLICY MANDATES INTRODUCED THROUGH FEDERAL AND STATE LEGISLATION By Kellie Terry A DISSERTATION Submitted to Michigan State University in partial fulfillment of the requirements For the degree of DOCTOR OF PHILOSOPHY Department of Educational Administration 2007 “i" "‘S :Ll u-u.‘\-- r . _ .A- 7" u _ ‘ 1 . “5.... l T ." Affil‘ .. tl ”M.“ to l -‘.,u T . uh,‘, H" “J ~'*.-‘l w ~—._\v 1 A ‘ J‘ 4“.\ ‘Izrlr ”s “ . \IIIEK ABSTRACT RESPONSE OF K-12 DISTRICTS TO POLICY MANDATES INTRODUCED THROUGH FEDERAL AND STATE LEGISLATION By Kellie Terry The purpose of this study was to describe and explain the response by K-lZ districts to policy mandates introduced through federal and state legislation. To inform the study, I reviewed the literature regarding educational purposes in the United States; relationships between the economic, political and educational systems and their influence on the educational system; society’s attempts to resolve perceived social and economic problems in its schools; and theoretical concepts that predict how K-12 districts might respond to legislative mandates. This literature provided the foundation for a conceptual framework, exploratory questions, and the methodology guiding this study. In addition, information on the two legislative mandates included in this study, the federal No Child Left Behind Act of 2002, and Michigan’s Compiled Laws 165-166 on Human Immunodeficiency Virus and Sexually Transmitted Diseases and sex education, was outlined. Interview data and documents from each category of the conceptual framework, including External Partners from the Michigan Department of Education and two Intermediate School Districts; and two K-12 districts were analyzed. Research in the K- 12 districts was conducted through pilot and case studies. Following within-case and cross-case analyses of the data, I developed conclusions to describe and explain how K- 12 districts respond to legislative mandates. ,3 V" .f ‘ I Li- _J\ J,:\ r'" 0‘ m p I..l IL“ 0 I 2““ ‘ Wit» _ .. o .‘IW’I' \‘ ”v5 “‘ - 'I I H J tub .b'x- YI'.‘ may f _.n a \.!"I ‘ll') — '*‘~-\ Study evidence and arguments were presented to support the conclusions, based on the underlying thesis, which is that legislative policy mandates pose K-12 districts with an interesting paradox: while the educational bureaucracy appears to be well- equipped to satisfy concrete compliance requirements, bureaucratic action does not appear sufficient to produce the deeper changes in practice needed to fulfill the spirit of the law. Thus, districts appear to be struggling to apply bureaucratic solutions to change that may require a response outside the realm of bureaucratic control. Further explication of K-12 districts’ responses to legislative policy mandates resulted in an abstract model entitled, “Stages of K-12 Districts’ Compliance with Legislative Mandate.” Thus, this study contributes to the discourse regarding the connections between policy, practice, and organizational change. Additional research was suggested to elaborate greater understanding of the conditions and actions in districts that are successful in realizing deep changes in educational practice. Copyl'ight by KELLIE TERRY 2007 This dissertation is dedicated to the loves of my life: my wonderful husband Mark, our amazing son and daughter, Andrew and Marisa, and our extended family. Their support has been invaluable. n c . .3 y‘ 'I'-“\ u s .,.5_ . W 7 ”I‘.’ :‘L I— n. . "a 7." 19 ~.,.‘ {ii ‘-I ‘3‘ b.‘\! ACKNOWLEDGMENTS Completing a research study and dissertation requires a surprising amount of faith. I found myself fumbling through the fog at times. Had it not been for the belief expressed in me by a handful of Significant people, I’m not sure I would have attempted it, nor persevered to completion. Their belief sustained me. Dr. Philip Cusick, my advisor, was a wise and patient guide throughout this process. While he is widely recognized for his contributions as a researcher and writer, he is an outstanding person—kind, curious, funny, and someone who cares deeply about others. I was very fortunate to have him as my advisor. The other members of my committee also offered constructive assistance. To Dr. BetsAnn Smith, Dr. Steve Weiland, and Dr. Suzanne Wilson, I offer thanks. As researchers deeply interested in education, they helped to stretch my thinking, both in and out of class. I appreciated their generosity in sharing their time, insights, and encouragement. I’m also tremendously grateful to the participants in my study, including those from the Michigan Department of Education, two intermediate school districts, and three K—12 districts. The interview time I spent with them flew by, punctuated by moments of Shared insight and laughter. I walked away from each interview feeling I’d learned something important and worthwhile. They are good people, dedicated to their work, and impressive in so many ways. Finally, to my first teacher, my mother, Jean Richards Simpson TenEyck, I owe a great deal, not the least of which my passion for teaching and learning. She was a gifted teacher who continues to love learning. vi ..\ .. TABLE OF CONTENTS LIST OF TABLES ................................................................................. v CHAPTER I THE PROBLEM .................................................................................... 1 Introduction and Purpose of the Study ....................................................... 1 REVIEW OF LITERATURE ...................................................................... 3 Introduction ...................................................................................... 3 History of Educational Purpose and Values ................................................ 4 Relationship between the Educational System and Economic and Political Forces 5 Weber and His Economic Theory of Bureaucracy .................................... 6 Democratic Political Structures and Their Influence on the Educational System .............................................................. 11 Economic and Political Structures’ Influence on Educational Mandates . .. 15 Contributions of Other Positivists ........................................................... 16 Thompson and Behavior of Complex Organizations ................................. 16 Meyer and Rowan: Institutional Theory .............................................. 21 Increased Public Demands for K-12 Education ........................................... 23 Schools as a Panacea for Social Problems ............................................. 24 The Economic Narrative of Schools ................................................... 26 Purpose and Nature of External Mandates ................................................ 29 Historical Perspective ......................................................................... 30 Current Context ............................................................................... 34 Increased Mandates: 19808 to Present ................................................ 34 Summary: Theoretical Explanations for Organizational Response to Mandates . . .. 36 Theoretical Gaps and Exploratory Research Questions .................................. 37 Summary ....................................................................................... 39 CHAPTER II RESEARCH METHODOLOGY ................................................................ 40 Introduction ..................................................................................... 40 Exploratory Questions and General Case Study Methodology ......................... 41 Exploratory Questions ................................................................... 41 Case Study Methodology and Defining the Case .................................... 41 Issues of “Fit” and Establishing a “Chain of Evidence” ............................. 42 Preliminary Conceptual Framework ........................................................ 42 Sampling ....................................................................................... 46 Sampling Strategies ...................................................................... 47 Pilot Study and Case Study Parameters ................................................ 47 Case Sampling ............................................................................. 50 vii PTIICCI ...... . . iu nu II . It.» VX .H. I.» II a\ L It... Dun T . a O _ I‘tu 3 IL mL at ‘4 y» III F Instruments/Measures ........................................................................ 50 Semi-structured Interviews .............................................................. 51 Review of Documents .................................................................... 51 Procedures ...................................................................................... 52 Preparation for Fieldwork ............................................................... 52 Data Collection ........................................................................... 54 Data Analysis .............................................................................. 57 Validity, Reliability, and Study Limitations ............................................... 58 Validity .................................................................................... 59 Reliability ................................................................................. 60 Study Limitations ......................................................................... 60 Summary ....................................................................................... 61 CHAPTER III THE EXTERNAL CONTEXT: LEGISLATIVE POLICIES ................................ 62 Introduction ...................................................................................... 62 Federal No Child Left Behind Act of 2002 ................................................ 63 Historical Antecedents of NCLB ....................................................... 63 Significant Components of NCLB ...................................................... 64 Channels of Communication and Technical Assistance ............................. 68 Questions Regarding K-12 Districts’ Response to NCLB ........................... 69 Research Evidence on the National Impact of NCLB ............................... 70 Research Evidence on Michigan’s Responses to NCLB ............................ 74 Status of Scheduled 2007 Reauthorization of NCLB ................................ 75 Summary ................................................................................... 77 Michigan Compiled Laws (MCL) Public Acts 165 and 166 ............................ 78 Michigan Compiled Laws (MCL) Affected by PA 165 and 166 ................... 78 Overview of Michigan’s Sex Education Laws under PA 165 and 166 .. . . . . 79 Teacher Qualifications for HIV/STDS Instruction and Sex Education ............ 82 State Board of Education Policy to Promote Health and Prevent Disease and Pregnancy .......................................... 83 Channels of Communication and Technical Assistance ............................ 84 Questions Regarding K-12 Districts’ Response to PA 165-166 ................... 85 Summary of Legislative Mandates ......................................................... 86 CHAPTER IV PRESENTATION AND ANALYSIS OF THE DATA ...................................... 89 Introduction .................................................................................... 89 Conceptual Framework and Research Procedures ........................................ 9O Conceptual Framework .................................................................. 90 Research Procedures ..................................................................... 91 viii External Partners .............................................................................. 93 Michigan Department of Education .................................................... 93 Intermediate School Districts ......................................................... 108 Summary ................................................................................. 124 Settings ........................................................................................ 125 The Pilot Study: F airview Community Schools .................................... 127 The Case Study: Steele Public Schools ............................................. 128 The Pilot Study: F airview’s Responses to Federal and State Legislative Mandates .......................................................... 129 Local Factors Contributing to Fairview’s Responses to Legislative Mandates .......................................................... 129 Fairview’s Response to NCLB ........................................................ 137 Fairview’s Response to PA 165-166 ................................................. 152 Summary of Themes in Fairview’s Responses to Legislative Mandates ......................................................................... 163 The Case Study: Steele’s Responses to Federal and State Legislative Mandates ........................................................................ 164 Local Factors Contributing to Steele’s Responses to Legislative Mandates 165 Steele’s Response to NCLB ............................................................ 174 Steele’s Response to PA 165-166 ..................................................... 202 Summary of Themes in Steele’s Responses to Legislative Mandates ............ 210 Comparison of Patterns and Themes from Fairview and Steele ....................... 212 Different Local Contexts and Contributing Factors ................................ 213 Fairview’s and Steele’s Responses to No Child Left Behind ..................... 216 F airview’s and Steele’s Responses to PA 165-166 ................................. 219 Summary of Patterns and Themes in Response to Legislative Mandates ............ 222 Observed Bureaucratic Processes in Response to Legislative Mandates ........ 223 Problems with Implementation and Monitoring .................................... 223 Differences in Intentionality in Response to Legislative Mandates .............. 224 Exercise of Administrative Discretion ............................................... 225 CHAPTER V CONCLUSIONS ................................................................................. 226 Introduction ......................................................... . .......................... 226 Exploratory Research Questions and Preliminary Conceptual Framework ......... 227 Stages of Compliance Model ............................................................... 229 Stage 1: Building Awareness and Understanding ................................. 231 Stage II: Focusing on Internal Management Issues ................................. 235 Stage III: Confronting District Barriers to Change ................................. 238 Stage IV: Institutionalizing New Practices Relative to Mandates ................ 242 ix (OT. Conclusion and Reflections ............................................................... 244 How do K-12 administrators learn about and assess mandate requirements? ........................................................ 244 How do K-12 administrators respond to mandates and monitor district implementation? ....................................................... 246 What administrative challenges and district conflicts are created by these mandates? ................................................................ 249 Summary of findings ................................................................... 254 Reflections ............................................................................... 256 Alternative Explanations .................................................................... 258 Recommendations for Additional Research ............................................. 260 Significance of the Study ................................................................... 261 APPENDICES .................................................................................... 263 Appendix A: Preliminary Conceptual Framework ..................................... 264 Appendix B: Semi-structured Interview Protocol ....................................... 265 Appendix C: IRB Voluntary Consent Form ............................................. 268 Appendix D: Fairview Community Schools Strategic Plan, 2007-2011 ............ 271 Appendix E: Steele Public Schools Focused Monitoring Report, 2007 ............. 276 Appendix F: Conceptual Framework of the Educational System ..................... 288 Appendix G: Stages of K-12 Districts’ Compliance with Legislative Mandates .......................................................... 289 Appendix H: Additional Reflections in Response to the Dissertation Defense 292 REFERENCES ................................................................................... 296 P... \. LIST OF TABLES . Persons Interviewed at Each Site by Title and Length of Service in Position ......... 94 . Characteristics of Fairview Community Schools and Steele Public Schools 126 . Changes in F airview’s district administrator positions and responsibilities, 1999-2007 ..................................................................................... 131 . Changes in Steele’s administrative positions and responsibilities, late 19905-2007 .............................................................................. 167 . Comparison of contributing local factors to Fairview’s and Steele’s responses to legislative mandates .......................................................................... 214 xi an!- x ‘ LL..IL'..I.A VJ ‘!nT- 7, lb. v.r. Ml r‘ I - Ln .~-o. I —\'U\~‘Au.'-.. “.‘c I C' v “M“ \ - -s ~. I II‘WV.‘.‘. .. s ‘1 ~.\ 1.7""; }‘;n CHAPTER I THE PROBLEM Introduction and Purpose of the Study Public schools in the United States are riddled with mandated changes in curriculum, instruction, and assessment spawned by federal and state legislation. While reform demands are not new, as many researchers have noted, they have increased in number and power over the last several decades starting with the National Defense Education Act of 1957 and culminating in the No Child Left Behind Act of 2002 and beyond. This is a Significant concern for educators nationwide, as reform mandates and pressures at the federal, state, and local levels increase demands on districts to improve and produce evidence of change through external accountability measures. The purpose of this study was to describe and explain the response by K-12 districts to policy mandates introduced through federal and state legislation. Much public attention has focused on mandate requirements. District performance expectations are outlined in detail, disseminated by state educational agencies, and reported in the mass media. This has led to equally public reports, boiling down complicated questions of school and district performance to a nearly singular focus on whether or not districts “make the grade.” However, in this accountability-driven system, it is far less clear what districts do in response to mandates. Do districts respond to a given mandate in Similar ways, or is there significant variation? Do different mandates provoke the same response by a district? What contributes to differing '7... .‘\ 0 Q's '4 :V 3 ..L-'Uu‘¥ , . cum" 12.5.. A' I 3.. \ ‘4' h\,.‘ .a.‘ responses within and across districts? What are the implications for district organization and performance? External demands for change induce uncertainty and conflict within districts. Hence, the purpose of this study was to find out how K-1 2 districts respond to policy mandates introduced through federal and state legislation. In articulating the initial logic underpinning the study, I began with a literature review and developed related exploratory questions. .,._.l d. 5.1» \CJM '1' 3' ”“1. “'1' Us. I 3 '3w --‘ \krns, . 41. [TREK \ II“ 5‘? LI '4‘» ‘3‘, REVIEW OF LITERATURE Introduction This review describes the relationship between economic and political forces and the educational system in the United States, outlining the evolving purposes of education over time and their reflection in external mandates. It is important to recognize that external mandates are not new, nor are organizational challenges. Indeed, Ogawa, Crowson, and Goldring identified ongoing challenges inherent in school organizations, including “dilemmas of external relations” between schools and their environments (I 999, p. 285). These dilemmas center on issues of “persistence” of educational purposes, structures, and reforms, “organizational boundaries,” or the relationship between organizations and their environments, and “compliance,” or adaptation of organizations to environmental demands (1999, pp. 285-290). While external mandates pose challenges for K-12 districts, they also offer a litmus test for prevailing organizational theory by measuring how well it predicts the response of K-12 districts. This review explores organizational theories for their contributions and limitations in predicting the organizational responses of K-12 districts. In building the rationale for further research on the response of K-12 districts to external mandates, the following issues will be examined for their contributions to this topic: 1) The history of educational purpose and values in the United States, particularly as it has informed development of external imperatives and mandates for K-12 districts; . yr M-....-- ‘ - J‘x'J". shuns.» . - -. Va, 7 1 -‘ tin-Abs“; nu 5.4035. I r‘ '53? “lb “Is“ \‘L‘a ._ kho.‘_ ”l .45; ‘ “-u L ' t. 71.3 a“ u 2) The relationship between the economic, political, and educational systems, highlighting the influence of capitalism and democracy on schools and the intended outcomes for educating our youth; 3) The increasing public demands for K-12 education in response to perceived social and economic problems; 4) The purpose and nature of external mandates in curriculum, instruction, and assessment in response to these perceived problems; and 5) Theoretical explanations for K-12 districts’ responses to mandates, exposing shortcomings of existing organizational theory to explain how schools respond to mandates. Insights and deficits revealed through the literature review are then utilized to pose exploratory research questions. History of Educational Purpose and Values Public debate and action regarding the purposes and quality of education is not new. Tyack and Cuban (1995) documented the evolution of schooling in the United States from Horace Mann in the 18403, who preached social salvation via the common school, to the presidential commission responsible for A Nation at Risk, noting, “For over a century and a half, Americans have translated their cultural anxieties and hopes into dramatic demands for educational reform” (p. 1). Even as early twentieth century educators disagreed about the optimal focus, content, and outcomes of a high school education, the nation scrambled to create a mass system to educate its youth in response to rapidly rising enrollments (Cohen, 1985). In the first several decades of the century, the government’s commitment to education was thus to ensure that all students had an opportunity to fulfill their differing abilities and interests in life (Tyack & Cuban, 1995). However, Sputnik (1957) and the publication of A Nation at Risk (1 983) raised concerns about the quality of the American educational 4"“. Q 33‘. ‘- T’IP 3' ~V. ‘hgt. u ‘JI system relative to other nations, particularly in the areas of math and science education, which in turn made US. citizens uneasy about the specter of economic decline. In response, over the last two decades of the twentieth century, federal and state educational policies implemented standards-based assessments to increase accountability for schools. The No Child Left Behind legislation solidified the federal policy shift from provision of educational Opportunities for all students, to ensuring that all students achieve minimum proficiency standards. NCLB and other federal and state policies represent the government’s attempt to communicate, legislate, and enact its purpose and vision for the educational system, and to manifest its promises to the American public. Therefore, the implicit and explicit promises made to the American public through the educational system have evolved. The basic value set of universal education and egalitarianism highlighted by Cusick in 1992 has expanded to include the value of universal proficiency. Thus, it is essential to note that the basic value set has not been trimmed or necessarily even prioritized, but has been added to, a distinction that reflects the system’s unwillingness to reject any perceived legitimate purpose in educating its youth (Cohen, 1985). Relationship between the Educational System and Economic and Political Forces Educational purpose and values stem from the infrastructure of our society. The United States’ educational system has not developed in isolation, but has been fimdamentally shaped by the economic and political forces that form the fabric of our daily lives. Thus, the educational system is intertwined with these systems, which are in turn based on capitalism and democratic values and practices. Needless to say, these institutions have significant implications for the educational system; an exploration of 3(- ‘I‘ O» .. -n - 1 34“...” " J :‘HIIIU ‘7’ 3"“ h. ' s. \ n u, Lin...“ ‘ ~ 9 . . thugutl . ' I.) V": --\.5 9. ’lg, ”"53 how our economic and political forces contribute to the structure and function of our educational system is critical to understanding both how educational systems have evolved, as well as how they respond to external mandates. Weber and His Economic Theory of Bureaucracy As Weber’s economic theory of bureaucracy (1947) helps to illustrate, the educational system is itself an economic structure. Following Weber’s reasoning, the financial needs of the educational system are primarily met through taxation, and schools are accountable to their communities for spending tax dollars wisely. In order to meet the diverse needs of students and programs, schools organize themselves according to bureaucratic principles.1 In return, taxpayers feel justified in making demands on the educational system to make good on its promises of educational equity and universal proficiency, and frequently seek Special treatment for their children or pet interests. While Weber’s ideas are complex, careful analysis reveals the impact of economic forces on the educational system, which leads to further understanding of how K-12 districts respond to external mandates. Given his systematic treatment of social phenomena and his abstraction of generalized theoretical categories of economic action, organizations, and leadership, it may be said that Weber’s conceptualizations follow tenets of the structural-functional approach. This consideration of Weber’s work will examine his ideas about the nature of economic action, its relationship to bureaucratic ' In Michigan and other key states, school bureaucracies attempt to squeeze the most out of funding funneled to districts from the state’s tax coffers, especially as state legislation such as Michigan’s Proposal A has resulted in slowed growth of total available revenues to the public schools, with two years of actual decline in the real value of the foundation allowance. In addition, Proposal A removed the ability of local districts to generate additional revenue beyond the foundation allowance by passing school millages via the election process. Districts with declining enrollments have experienced particular financial strains, as district budgets are based on total student enrollment (Arsen and Plank, 2003). 6 in: 71:32]." 7“ nit. II “I ,. organizations, the role of rational-legal authority within the organization, and the problem of change within bureaucratic organizations. The Nature of Economic Action Weber (1947) was carefiil to insist that he was not positing an economic theory per se, but instead dedicated himself to describing the social and institutional structure of economic activity and its variations. His typology of four types of social action began with a consideration of whether the action was rational or oriented toward a clear goal, with the means chosen to ensure goal attainment. The two “rational-ideal types” of action that he described included Wertrationalitc'it, where “the choice of means is oriented to the realization of a single absolute value without reference to considerations of cost,” and Zweckrationalitc'it, which is “oriented to a plurality of values in such a way that devotion to any one is limited by the possibility of entailing excessive cost in the form of sacrifice to others” (Parsons, p. 14). The latter type describes the action most common in a capitalist, democratic society with a plurality of values. Additionally, Weber believed “the spirit of capitalism” underlying modern social and economic structures placed equal value on rationality, via a clearcut path fi'om means to ends, as well as “acquisitiveness” (Parsons, p. 33). The application of the concepts of Zweckrationalitdt and the spirit of capitalism and acquisitiveness to educational organizations illustrates a couple of critical points that explain why schools function as they do. First, Weber stressed that rational organizations are oriented toward maximizing their economic advantages in a system of market relationships. Thus, some Michigan districts seek economic “booty” (Parsons, p. 51) by acquiring increasing numbers of students and their corresponding foundation allowances. '36! ‘bb.~ l\ ‘ . —. ._ V O I R, . ‘1 5 K. . I». 51‘ .' I'- I. ’I I‘«. I.'»:§‘ 1. . .\:~_ "H Rational action dedicated toward this goal includes advertising for students by emphasizing desirable facilities and successful programs with demonstrable results (i.e., strong MEAP scores). Further, districts aim to retain students through customer service designed to satisfy the needs and whims of parents and students. In addition, acquisitiveness of school districts also pertains to amassing booty through heightened reputation and prestige. Therefore, districts seek recognition in the educational marketplace for highly competitive rankings on standardized tests, garnering and publicizing prestigious honors and awards for its faculty, students, and programs. In Michigan, schools can earn public recognition by simply earning an “A” grade from Education Yes!, the state’s accreditation system based on MEAP scores and school improvement data. Secondly, Weber noted that market relations in a capitalist economy are primarily open. Thus, public school districts have been increasingly forced through the choice and charter movement to compete for students. Consequently, they are compelled to respond to reformers, Special interest groups, and parental demands. And in addition, reform pressures exerted by external mandates cannot simply be ignored. AS explained by Mommsen, Weber’s view is that social processes of change are ruled by unbending institutional structures; thus, school districts have “their life conduct largely determined by them, if only because their economic interests point towards adaptation and conformity with the given social order” (1989, p. 151). An extrapolation of Weber’s ideas to the current context of increasing external mandates would indicate that K-12 districts would be forced to adapt and comply with new regulations through increased bureaucratization. p .l_'7 r" L'L;«s“"' rutuflt‘. ‘1‘. r .. V“ [um ‘ I M” "‘“u. ‘ Relationship between Economic Action and Bureaucracy The need to compete in a market system and respond to diverse demands has implications for educational organizations. According to Weber, formation of bureaucratic organizations is a nearly inescapable response to the demands of modern, complex economic and political structures. Diverse demands impinging on the organization call for specialization of departments, task functions, and lines of authority. Weber viewed bureaucratic structures and responses in an organization devoted to rational goals as inevitable, such that “When those subject to bureaucratic control seek to escape the influence of the existing bureaucratic apparatus, this is normally possible only by creating an organization of their own which is equally subject to the process of bureaucratization” (p. 338). And increased bureaucratization has implications for organizational leadership. Bureaucratic Leadership Applied to management of schools, his concept of individuals occupying roles to fulfill a “combination of functions . . . which are qualitatively different, and thus Specialized” (Weber, p. 226) explains the complexity of public schools with people performing functions related to finance, transportation, food service, human resources, curriculum, etc. In modern societies that have moved away from traditional forms of leadership to “rational-legal” authority, those holding offices have specifically delimited areas of responsibility, subject to bureaucratic regulations. This explains the role of district administrators, each of whom possesses technical competence particular to his/her role, and who are responsible for enacting bureaucratic mandates and regulations. Bureaucratic administration means fundamentally the exercise of control on the basis of knowledge. This is the feature of it which makes it 9 I p. . I_,_‘*_\ II] specifically rational. This consists on the one hand in technical knowledge, which, by itself, is sufficient to ensure it a position of extraordinary power. But in addition to this, bureaucratic organizations, or the holders of power who make use of them, have the tendency to increase their power still further by the knowledge growing out of experience in the service. For they acquire through the conduct of office a special knowledge of facts and have available a store of documentary material peculiar to themselves. (Weber, p. 339) Hence, in Weber’s view, societies based on a capitalist economic structure create an “urgent need for stable, strict, intensive, and calculable administration” (p. 338) which is fulfilled through bureaucratic functions and leadership. Public school administrators provide stability within a changing educational system by using acquired knowledge to coordinate organizational responses to policy mandates. The Problem of Change Unfortunately, the very characteristics of bureaucracies that serve organizations well can constrain effective operations. A common limitation ascribed to school bureaucracies is their resistance to change. New demands introduced through legislative mandates pose challenges to bureaucratic organizations; their rules-based orientation makes change difficult, as the organization attempts to modify and regulate its fimctions to adapt to mandates. This helps to explain why schools have been so resistant to deep change (Tyack & Cuban, 1995). Overall, bureaucratic structures are set up to promote stability rather than innovation. Complicating the implementation of change is the relationship between the external environment and the organization itself. AS observed by Parsons, one of the fundamental assumptions underlying Weber’s thinking is the “inherent instability of social structures. . . . The situation of human action and the character of humanly possible responses to that Situation, are Shot through with deep-seated tensions which make the 10 all “,2 'T' LIL-Lilli.) .E"‘n r1 I‘h‘aii‘ ~ xxuog‘ . bk u.» \; Dr IH‘. — ‘I “3*.- H“ 4‘: 41..er G's-TIM? “can QT-w . _\\.'--"'*‘ .|_~_ ‘59-... H... I... 41'7“”- B. maintenance of any given state of affairs precarious” (p. 32). Weber’s exposition of Open and closed relationships helps to explain how participants in a bureaucracy make decisions about responding to demands for change. If participants within the organization “expect that the admission of others will lead to an improvement of their situation . . . their interest will be in keeping the relationship open” (p. 140). In a competitive system, relationships are usually at least partially open to allow for improved outcomes, not the least of which is increased economic advantage. However, as will be demonstrated later in this review, Weber’s ideas fall short of explaining the full range of organizational responses of K-12 districts to policy mandates in the current educational context. Democratic Political Structures and Their Influence on the Educational System The purpose of this review is to explore how K—12 districts to policy mandates introduced through federal and state legislation. Our democratic political structure also influences districts’ responses. As noted earlier, our educational system reflects democratic principles such as freedom of speech, equality, respect for diversity, and civic participation. Cusick (1992) uses the concepts of the formal organization and the educational system to illustrate the ways in which individuals and groups in our democratic society participate and gain access to schools. The formal organization is composed of groups within the organization, including students, teachers, administrators, school board members, and government officials. The educational system includes the aforementioned groups, plus those outside the organization who participate in the workings of the school, including parents and community members, legislators, unions, and various interest 11 ’- v (I. r "t, -..l-§\. 317g?” \.\L‘..‘; groups, thus making the educational system extremely large and complex. Cusick employs sociological and organizational theory to describe and explain why people in formal organizations and within the educational system behave as they do, asserting his thesis that “public education has a stable but dynamic system that makes predictable adaptations to variations on recurring themes” (p. 9). His concepts illustrate the response of K-12 districts to policy mandates as he describes the workings of the educational system through collective action, illuminates tensions between the educational system and the formal organization, explains adaptive changes in the organization to accommodate diverse needs, and clarifies district administrators’ responsibilities relative to mandated change. Collective Action within the Educational System Cusick’s ideas demonstrate the predictability of organizational responses to external mandates. He asserts, “The actual business of education is carried on by small, more or less cooperative associations of people who-arrange themselves around roles and issues” (p. 4). Thus, the predictability of the system derives from the democratic actions and interactions of people within groups. The importance of the action of small groups within the system is highlighted by Simmel (in Wolff, 1950). Simmel’s ideas help to explain why collective action tends to take place in small rather than large groups. He observed that “large masses can always be animated or guided only by simple ideas [because] what is common to many must be accessible even to the lowest and most primitive among them” (p. 93). Thus, in Simmel’s view, broad values such as equality and universal proficiency would motivate large groups of people because few would argue with or fail to understand these ideals. 12 .- 51; - Fat. I“|‘ “‘ia. This helps to clarify why the educational system has tasked schools with fulfilling broad civic goals such as improving the economic and social welfare of its citizens. And it further explains the origin of broad mandates such as No Child Lefi Behind. In contrast, small groups are ripe for diverging from centralized goals and authority, providing fertile ground for the cultivation and promotion of special interests. Hence, smaller groups find it easier to preserve their identity and ideas, demonstrate cohesiveness and devotion to their aims, and harness the resources of their members. The cohesiveness of the small group is a lever for action, while the large group “creates organs which channel and mediate the interactions of its members and thus operate as the vehicles of a societal unity which no longer results from the direct relations among its elements” (Simmel, 1950, in Wolff, p. 96). Thus, large groups promote broad social goals, while smaller groups tend to advocate for specific, often private interests. This helps to provide context for an educational system characterized by broad, ambitious reforms, as well as those promoted by Special interest groups. Hence, external mandates stem from the large, diverse educational system, while the formal organization of schools is in the position of responding both to mandates and Special interests. This often creates discontinuity between the educational system and the formal organization. Tensions between the Educational System and the Formal Organization The differences between large and small groups thus generates a fundamental tension within the educational system, as described by Cusick: Special interest groups in the educational system advocate for their members, and the formal organization, which is charged with enacting broad social goals, protects the interests of the least advantaged students. Therefore, while the purpose of the formal organization is to address the 13 . . l , l } Al I ‘ \ph ' - Q."l_~,'_)c \l" 1....r‘. I"-l."‘1’ luv-g. l\ 5 4 . $.15 TIL 4' '4' um .7“ i"”,;. rh— IAIL\_ \ \ Bil-c \‘L . ’ .‘u problems of educating and controlling large groups of students, the system appears to focus on accommodating the values, needs, and wishes of small interest groups. As Cusick observes, this tension is never fully resolved. Small groups promote their ideologies and solutions to perceived problems, and then another group comes along with different views and priorities. The task of the formal organization is to make sense of the storm of external mandates and to respond to them while attempting to preserve its integrity. Adaptive Changes in the Organization Along with other proponents of the political-conflict school of thought, Cusick does not locate the primary impetus for change within the formal organization, but describes the reform efforts as stemming from federal and state policies and special interest groups. Reforms may bring new energy to the formal organization, but can pose problems for it as well. However, the formal organization is not without power; reform efforts are ofien modified as they are passed down the vertical channels of the system to local districts and players. In addition, special interest groups are another way that change may be introduced, exerting pressure on schools to reflect their values, needs, and wishes. This can create conflict between special interest groups advocating for change, and the bureaucracy, which tries to institutionalize egalitarian ideals and promote rationality through consistent practices. Cusick asserts that the conservative means of dealing with change at the organizational level is through specialization. Create a position or department to handle the change, and the bureaucracy achieves a secondary gain by focusing attention on the organization rather than the classroom, thus buffering the soft technology of instructional l4 373:5. sates I SKI; u- hw— L. A..- - -I“\. A It... .'- ' .. IF.” ‘3‘. I :k '-.{~h practice from outside influences. However, in the current context in Michigan and other states where the growth of real revenues has slowed (Odden and Picus, 2004), specialization of positions or departments may be difficult to achieve. Economic and Political Structures ’ Influence on Educational Mandates The educational system is influenced by our economic and political forces, which in turn are reflected in K-12 schools. Labaree (1997) has written of the competing demands on schools arising “from a fundamental source of strain at the core of any liberal democratic society, the tension between democratic politics (public rights) and capitalist markets (private rights), between majority control and individual liberty, between political equality and social inequality” (p. 41). The end result of economic and political factors on the educational system is that individuals and groups expect to have a say in school matters. Given the multitude of access points to the system and the diverse needs, values, and beliefs of its participants, the proliferation of federal and state mandates is not surprising. Individuals and groups introduce ideas into the educational system, which overlap, accelerate, and gain in power over time. Combined with other policy mandates and ideas swirling around, the pressure for reform fulminates and spirals throughout the system. Historical evidence demonstrates that one way schools have responded to the pressures of special interest groups and policy mandates alike is to spin off new curricula and programs for students and assign staff to special projects. This is amply illustrated in The Shopping Mall High School: Winners and Losers in the Educational Marketplace (Powell, Farrar, & Cohen, 1985), which explores the accommodations that high schools make as they attempt to fulfill the educational mission of public high schools while 15 ~ rat. 5 ‘1 .{' x... . 5? U .u 1,, , an: M55 ' ,-.--, a ' - ku‘h, rm; -_ g 4Q“. addressing diverse student needs. However, under school finance legislation in states such as Michigan, in which some districts’ budgets undergo Significant, repeated cuts on an annual basis, it is unclear whether the historical pattern of specialization continues to be a widespread response to change. Contributions of Other Positivists The purpose of this study is to describe and explain the response by K-12 districts to policy mandates introduced through federal and state legislation. While an explicit analysis of the social structures of a capitalist economy and democratic politics provides a foundation, it is important to consider contributions of other positivist theorists in explaining the relationship between organizations and their environments. In particular, Thompson (1967) and Meyer and Rowan (1977, 1978), and Rowan and Miskel (1999), add new insights to explain how K-12 districts respond to external mandates. Thompson and Behavior of Complex Organizations In many ways, Thompson (1967) picked up where Weber left off in his description of general “ideal types” of organization and administration. Thompson’s goal as a theorist was to explain the variability of organizations based on their technology and environments. In exploring his theoretical contributions, it is important to consider the nature of organizations and their adherence to norms of rationality, the organizational rationality of schools and its impact on structure and fimction, the effect of a heterogeneous, dynamic “task environment” on organizations, and the role of admmistrators in providing coordination and enacting responses to changes in the task environment. 16 .u s 1"" ’ A4, Lb. L. -.. . r. .... .t . . I .1: ..i u 3 .JL . . I . . 1 . .l . ,3 9|. onlu Kain: .1 Fr\t ..WH .u s m ._ a a rd. m . x.“ h ..m . s. i K. It AM 3.. FM ..m u I. owns» HUM. . Want“. f. y ..n . I . Flam... Bil... 1N -.‘. e The Nature of Organizations under Norms of Rationality Thompson unified rational and natural system concepts in his theory, positing that organizations are both “rational” in their attempts to meet predetermined goals, and open to their environment as they evolve to meet changing demands. The chief task of the organization is thus to reduce uncertainty in achieving its goals, Specifically “by creating certain parts . . . to deal with it [while] Specializing other parts in operating under conditions of certainty or near certainty” (p. 13). And according to his framework, the tighter the norms of rationality (i.e., the more certainty is desired in achieving its goals), the more energy the organization will devote to ensuring certainty. In K-1 2 education, it appears that norms of rationality may have tightened through the standards movement and external mandates. In response, it has been widely observed that K-l2 districts, as open systems that respond to their environment, focus increasing energy and resources to meet proficiency goals; in addition, schools have created a variety of Specialized structures to ensure goals are met. The Organizational Rationality of Schools Thompson further posited that organizational rationality is derived from its inputs, technical activities, and outputs. Given the instructional domain, students are the inputs, teachers’ implementation of curricula to facilitate learning and students’ efforts to learn constitutes the technical activities, and the outputs are the students themselves, along with indicators of their achievement and readiness for life after graduation. Thus, the instrumental rationality of an organization is judged by the extent to which technical activities produce the desired outcomes. It is apparent that there is greater uncertainty in schools given “softer” inputs (diversity of students’ experiences prior to entering the 17 ' i fir). ‘ ‘ Tilt.u'\ be “it 1.24.. (In r ‘/ l. ,7. :""1_ Fl' 1. l r -’ . _- — fi—*-—— system, for example) and a “soft” technology (stemming from quality of educational materials used, differences between teachers, etc.). This complicates the task of explaining how K-12 districts respond to external mandates. Thompson proposed that the technology utilized by an organization shaped its organizational structure and actions. Schools are complex organizations because their structures create all three possible types of interdependence between its parts: pooled interdependence, in which each part of the organization contributes to and is supported by the whole (i.e. all third grades, which affect school and district annual yearly progress, or AYP, all fourth grades, all fifth grades, and so on); sequential interdependence (i.e., success of each grade level is dependent on appropriate instruction and learning in earlier grades); and reciprocal interdependence, in which the output of a given department becomes the input for another and vice versa. The interaction of organizational technology, structure, and administrative coordination is critically important. Thompson posited that the more complex the interdependencies within the organization, the higher demand it poses on administrators for coordination. With each step higher in the type of interdependence, the heavier the burden becomes for communication and decisionmaking. When all three types of interdependence are present in an organization, or within the purview of an administrator, the costs of coordination increase. Furthermore, the nature and location of the various types of interdependency influence the groupings within the organization. Finally, it may be said that there are interdependencies that exist external to school districts, through partnerships, professional associations that disseminate information, etc. These interdependencies I8 have an inevitable impact as K-12 districts attempt to respond to external mandates stemming from the environment. Eflects of a Heterogeneous, Dynamic Task Environment on the Organization Thompson meticulously outlined possible responses of the organization to its environment. He started with Dill’s definition of the task environment, which denotes “those parts of the environment which are ‘relevant or potentially relevant to goal setting and goal attainment’” (1967, p. 27). Schools have a wide-ranging task environment, including community members, professional associations, federal and state agencies, etc. AS described by Thompson, the task environment poses both constraints and contingencies for schools. He classified task environments based on their placement on the “homogeneous-heterogeneous continuum,” which refers to the degree of diversity in the task environment, and the “stable-shifting continuum” (p. 72), which describes the amount of change in the task environment. He asserted, “The more heterogeneous the task environment, the greater the constraints presented to the organization” (p. 73). Thus, the pressure from a variety of Special interest groups introduced through various channels limits the freedom of schools to decide how to use its resources. Money Spent on new band uniforms may limit transportation for athletic teams. Similarly, “The more dynamic the task environment, the greater the contingencies presented to the organization” (p. 73). Increasing mandates from the task environment may require districts to gain additional knowledge, prepare for more possibilities, and expend greater efforts to coordinate the organizational response. 19 9‘ ,. Wu, H . . I‘l‘l I". di". '.'H a. ‘ ‘lk Role of Administrators in Providing Coordination and Enacting Change In Thompson’s view, administrators coordinate the organizational response to change. AS discussed earlier, norms of rationality, as well as technology, structures, and interdependencies, affect organizational communication and coordination. In addition, Thompson describes discretionary judgment exercised by administrators, illustrating actions dependent on the individual’s knowledge base, relative position of power, and uncertainty in the task environment. Of particular Significance, he proposes the following: The more sources of uncertainty or contingency for the organization, the more bases there are for power and the larger the number of political positions in the organization. . . . [And] the more dynamic the technology and task environment, the more rapid the political processes in the organization and the more frequent the changes in organizational goals. (p. 129) Thompson’s theory predicts organizational coordination of change requires administrators to form effective coalitions with other people in power, monitor the task environment relative to mandates, and participate in developing and communicating goals. Given the number of complex mandates and initiatives in a heterogeneous, dynamic task environment, district administrators may spend a Significant amount of time devoted to meeting with others. This is where they gather knowledge and information relative to new demands, monitor contingencies, work out conflicts between competing interests, identify tasks for the organization and its constituent parts, and solicit practical and political support. While Thompson’s theory is helpful in many ways, his conceptualization of the organization as an open system leaves unresolved issues. He indicates that organizational action is aimed at reducing uncertainties, in large part by buffering and sealing off the 20 Fm ' .‘.~ Y". .ftt'-.. 5 arm “I" ‘n' Inflat. — '1‘. -l EXIST .\.I l 0'15" Vbili .137 organization’s core technologies and Operations from the task environment. However, in its strict analysis of the intersection between open systems and rational actions, it fails to recognize that organizations may at times subvert rational goals to survive in a highly demanding task environment. AS such, it does not fully explain how complex organizations respond to external mandates. Meyer and Rowan: Institutional Theory Meyer and Rowan (1977, 1978) and Rowan (1982) venture beyond Thompson (1967) by demonstrating how organizations sacrifice norms of rationality in response to external mandates. Their work focuses on ways organizations incorporate new structures as reflections of rules (mandates) originating from the institutional environment. They define these institutional rules as “myths which organizations incorporate, gaining legitimacy, resources, stability, and enhanced survival prospects” (1977, p. 340). While adoption of institutional myths as formal organizational structures may conflict with the efficiency of the organization, institutional theory posits that efficient coordination and control of organizations does not provide assurance of their survival. Strictly speaking, adherence to rational outcomes based on high technical rationality may narrowly prescribe organizational action and does not consider important institutional rules pertaining to professions, programs, technology, and policy. As new institutional myths are promulgated, “formal organizations form and expand by incorporating these rules as structural elements” (1977, p. 345). Hence, more advanced societies elaborate institutionalized myths in a variety of domains. Meyer and Rowan note that “organizations are structured by phenomena in their environments and tend to become isomorphic with them” (1977, p. 346). This lends 21 f I" L- 6‘3? I .r' ’2 F i. J ”,1- Out. View -|-LIL IQ.- . K.“ C1: 5"... greater legitimacy to the organization that incorporates elements deemed appropriate and valued. Thus, the organization is buffered from failure by adopting structures that are externally validated. According to Meyer and Rowan, schools “survive precisely because they are matched with—and almost absorbed by—their institutional environments” (1977, p. 352). To innovate in ways that depart from institutionalized myths is to risk loss of legitimacy and ultimately, failure. Certainly, tenets of institutional theory help to explain how districts respond to external mandates by demonstrating conformity to institutional “myths” (i.e., by assuring that all teachers meet “highly qualified” requirements). However, there are also apparent conflicts. Institutional theory (Meyer and Rowan, 1977, 1978; Rowan and Miskel, 1999) posits that isomorphism with the institutionalized environment allows for decoupling of structural subunits from one another as they become separated by constraints of daily work and the need for efficient operations. Thus, ritual conformity with institutionalized myths and projections of confidence and legitimacy outside of the organization demand higher levels of effort, while daily coordination and maintenance of internal relationships are sacrificed. However, Meyer and Rowan assert that while highly institutionalized organizations maintain legitimacy through displays of competency and good faith, they tend to resist internal and external inspection and evaluation. This is in contrast to Current educational policy mandates such as NCLB, which demand both internal and external assessment, paired with public reports of organizational performance, an apparent discrepancy with the goals of both the organization and its institutional environment. 22 ‘l O';\i (13...» vl-«q ; ! Urr.t - . IIIIL’SIL T34 . s .59 . 30 '\I L k vi! let u s -‘ xiv-— ' ’ A...\. p . h l .. 7- "r K 5 Lain _, l l h q . - v. ‘ . EN" .-,. 03' '1' Hit?) -L 5...: ' glut 1 ”F4 lu‘ ~ ‘15. L4_‘ F urtherrnore, research completed by Rowan in 1982 presents another paradox for districts responding to recent mandates for improved student achievement. In a study of thirty school districts in California spanning the years from 1930 to 1970, Rowan investigated the differentiation of administrative positions. As a frame for the study, he cited research findings indicating “increased levels of state and federal funding that follow from regulation promote local administrative expansion” (p. 45). In an analysis of job titles of district administrators published annually by the state, Rowan discovered that administrative positions in curriculum and instruction were differentiated far less frequently than those “managing non-instructional ftmctions such as personnel and business or child services. In addition, the ability of districts to sustain these positions, once differentiated, was very low. Instruction and curriculum [positions] had the lowest rates of survival” (p. 56). He explained the findings based on the tenets of institutional theory, noting increased state regulations in the areas of educational finance, personnel, and student services during this time period. He also posited possible reluctance of districts to add administrative positions in curriculum and instruction given that “instruction is a highly uncertain technology. . . . and [there was] a decreased emphasis on instructional management as a result of the position of schools in society” during the study period (p. 44). While there has been an increased emphasis on instructional leadership since the completion of this study, state and federal firnding has not increased Significantly to implement new mandates. Increased Public Demands for K-12 Education Despite the educational system’s efforts to respond to changing educational Purposes and a variety of reforms, public demands have escalated over the past twenty 23 years. In part, it appears that schools have staggered under the burden of meeting broader social goals, including correcting racial prejudices and inequities, providing a safe haven from community violence, building students’ characters and enhancing their ability to work cooperatively with others, preventing teen pregnancy and sexually transmitted diseases, etc. And over time, society has also looked to schools to prepare students for the workforce, respond to changes in the marketplace, and compete in the global economy. Both of these factors have fomented additional pressures for K-12 schools and have been used as a rationale for sweeping reforms. Given the purpose of this review, understanding the evolution of social and economic pressures provides essential context for the origin of external educational mandates, as well as the response of K-12 districts to these mandates. Schools as a Panacea for Social Problems External mandates ofien have their origin in perceived social problems. In their painstaking documentation of educational reform over the past century, Tyack and Cuban (1995) demonstrate a pervasive tendency in the United States for reformers to construct educational solutions to both social and economic problems. This phenomenon follows a typical pattern of labeling a problem, devising a course to educate students about it, and expecting that education alone can provide the solution. However, using schools to address social problems has created new conflicts. Overpromising has ofien led to disillusionment and to blaming the schools for not solving problems beyond their reach. More important, the utopian tradition of social reform through schooling has often diverted attention from more costly, politically controversial, and difficult societal reforms. (P- 3) 24 Furthermore, reforms aimed at curing social ills often take a generation or more to produce significant results. When the public becomes impatient with the slow pace of change, “Schools can easily shift from panacea to scapegoat” (Tyack & Cuban, 1995, p. 14). In addition, social purposes for schooling have changed. Cohen (1985) traced the history of public education over a century and a half, separating historical periods in the United States from the late nineteenth century to the 19808. Several of these historical periods produced new purposes for education in response to pressures and changes in the social order. Burgeoning high school enrollments in the early 1900S reflected the public’s belief that advanced education would improve one’s social standing. And by the onset of World War II, with increased economic prosperity and expansion of the welfare system, jobs were often not available to adolescents. Hollingshead’s classic study of high school youth (in Cohen, 1985), revealed that outside of school, there were few agencies to socialize adolescents, thus making schools increasingly important as “social centers for otherwise unoccupied adolescents” (p. 237). Furthermore, Hollingshead’s findings demonstrated that schools replicated the social order while training youth for opportunities deemed suitable given their social standing. Thus, as asserted by Cohen, by 1940, schools strived to meet a panoply of needs, from ensuring students’ psychic well- being, addressing an array of educational goals from the practical to the academic, as ‘well as the social demands of adolescence. In the 19605, the Civil Rights Movement created a groundswell of support for equal opportunity for diverse students, including racial minorities and students with disabilities. Cohen noted that while the 19503 reforms focused on improving academics, in the 19603, “Legislation aimed at ending racial 25 discrimination in public life and eradicating its accumulated effects through massive federal education and training programs had set new national priorities,” thus turning attention away from improving educational quality (p. 292). However, the pendulum has swung back to examining educational quality, and significantly, the educational outcomes of majority and minority students. In a recent analysis of the “black-white achievement gap,” now widely recognized as a pressing social problem, Rothstein (2004) thoroughly probes findings of schools and instructional practices that have reportedly succeeded in reducing achievement gaps. His meticulous scrutiny of the findings reveals flawed methodology either because of selective sampling, misinterpreted test scores, or confounding variables, thus debunking the validity of the findings. While Rothstein is a passionate advocate for educational equity, he wryly notes, “In seeking to close the achievement gap for low-income and minority students, policy makers focus inordinate attention on the improvement of instruction because they apparently believe that social class differences are immutable and that only schools can improve the destinies of lower-class children” (2004, p. 9). He contends that remedying the achievement gap, which he traces to deep social and economic inequalities, requires integrated reform efforts in multiple systems including health care, early childhood education, and stable housing, in addition to K-12 reform. He believes placing the burden for resolving the achievement gap solely on schools confounds the work that schools can reasonably accomplish. The Economic Narrative of Schools External mandates have also been rooted in the economic narrative of our society, reflected in shifts of educational purpose over time. Borrowing from Weber’s economic 26 theory of sociology (1947), individuals seek every opportunity to improve their competitive advantage in the marketplace. Americans have long nourished the belief that short-term sacrifices to keep youth in school will net long-term gains for both individuals and society as they realize the goals of economic advancement (Cohen, 1985). Labaree advanced three conflicting purposes for education, including “democratic equality, social efficiency, and social mobility” (1997, p. 41). His review clearly illustrates the conflicts between democratic equality, reflected in an educational goal of preparing good citizens, and the economic goals of efficiency (ensuring that students are trained to be competent and productive workers) and mobility (ensuring opportunities for advancement in a competitive market). These competing values and beliefs have often resulted in a strain for primacy between social and economic ends for education, as noted by Tyack and Cuban (1995): Cycles of reform talk and action result . . . from the conflicts of values and interests that are intrinsic to public schooling. The rhetoric of reform has reflected the tensions between democratic politics, with its insistence on access and equality, and the structtuing of Opportunity in a competitive market economy. (p. 59) While the overarching economic purpose for education has been economic survival and advancement, the seesaw of tension between social and economic goals has been played out in various ways. By 1940, when jobs formerly filled by youth were occupied by adults, schools provided a safe place for youth with little else to do. Thus, schools were restructured to shift their educational purpose away from academic rigor to accommodate increasing enrollments of students not previously served in secondary schools. Schools became places to “train students for the right jobs, [placing] school leaders . . . at the heart of the industrial enterprise, making key decision about who would 27 0'34” 5‘5”) work where, and how well” (Cohen, 1985). However, with the advent of the 1957 Soviet Sputnik, perceptions of America’s national defense, declining scientific world supremacy, and economic fitness for global competition, led to a new economic purpose for education in the United States: to improve educational rigor in math, science, and languages. AS noted, the renewed academic focus did not last long, as the Civil Rights Movement shifted attention from improved quality of education to increasing equality of educational opporttmities (Cohen, 1985). And in recent times, cultural awareness of the poor achievement of minority groups, heightened by NCLB, has erupted into growing anxiety about general educational outcomes of American students. This view that has been widely promulgated by writers such as Friedman (2005), whose bestseller The World is Flat trumpeted alarm over the outsourcing of American engineering and technology jobs to other countries. The underlying economic narrative of education has been attacked by critical theorists, including Foster (1986, 1989). Foster suggests that the shortcomings of many reforms is that “they neglect the moral dimensions of the endeavors—moral not in the sense of being moralistic but in the sense of accounting for the deeper cultural and social aspects of individuals placed together in some sort of social structure” (1986, p. 118). His belief is that district administrators should promote democratic values and social justice and be responsive to the people served by the organization. In his view, the organization should “elevate [leaders] to new levels of morality. . . . and raise the level of followers’ moral consciousness regarding their received Situation” (1989, p. 55). Using Foster’s conceptual criteria for critical leadership, educators would practice critical assessment of social conditions, act to transform these conditions, educate others through 28 shared analysis and envisionment, and demonstrate ethical commitment (l 989, pp. 50- 55). Given the diverse beliefs and values reflected in public criticism of K-12 education, it is no wonder that reforms become “swamped by contrary waves of criticism” (Cohen, 1985, p. 280). Reflecting on failed secondary education reforms as a case in point, Cohen notes American schoolpeople have been singularly unable to think of an educational purpose that they should not embrace. As a result, they never have made much effort to figure out what high schools could do well, what high schools should do, and how they could best do it. Secondary educators have tried to solve the problem of competing purposes by accepting all of them, and by building an institution that would accommodate the result. Unfortunately, the flip side of the belief that all directions are correct is the belief that no direction is incorrect—which is a sort of intellectual bankruptcy. (1985, pp. 305-306) In Cohen’s view, this leads to certain failure. As stated by Labaree, “Grounded in this contradictory social context, the history of American education has been a tale of ambivalent goals and muddled outcomes” (1997, p. 41). Hence, public criticism over perceived failures of the educational system, followed by new waves of reforms, continues to cycle (Tyack and Cuban, 1995). This helps explain how social and economic purposes spawn external mandates for K-12 districts; the next section will examine the purpose of external mandates in curriculum, instruction, and assessment. Purpose and Nature of External Mandates in Curriculum, Instruction, and Assessment The preceding sections describe and explain the relationship between economic and political forces and the educational system in the United States. The interactions of these systems, and the actors within them, led to the development of reform mandates in 29 *— " .F. shag... curriculum, instruction and assessment. A brief review of external educational mandates and how K-l2 districts respond to mandates is needed to provide a frame for this study. Historical Perspective It is necessary to define the difference between educational imperatives and mandates. In this context, an educational imperative is a demand exerted on K-12 public schools by the general public, interest groups, and other agencies, influencing districts to respond to perceived social and economic problems or needs. While an educational imperative still bears the onus of economic and political burdens, districts have discretion in responding to it. An educational mandate is a legislative requirement imposed by state and federal authorities; local discretion in responding to mandates is significantly constrained by the legislation. In the early twentieth century, mandates were few, but social and economic pressures translated into educational imperatives, with the expectation that institutionalizededucation would respond to perceived needs. Thus, early reformers participated in debate about the purposes of education, what schools should teach, and how they ought to be structured. Around the end of the nineteenth century, reformers were debating the expansion of a classical curriculum to include more modern offerings, as public high schools sought to increase their enrollments (Cohen, 1985). The proliferation of high school curricula concerned some, who believed in the importance of a core curriculum while maintaining some flexibility of study. However, rapidly increasing enrollments, including students who would not formerly have enrolled in high school, appeared to increase interest in adapting the curriculum to the needs and interests of students, rather than helping students accommodate to the rigors of academic subjects. 30 I f,_. Not‘ " " I -3- _ )Lsx.‘ *Co? .1 f I r By 1930, the curriculum was differentiated into various courses of study, from college prep and home economics, to vocational education for students thought to be destined for skilled jobs. This differentiation separated students into discrete “tracks” matched to their perceived ability, interests, and future careers. Thus, the notion of a core curriculum Shifted significantly; students who were not being groomed for college were routed into survey courses light on academic content. And as the majority of students were not expected to go to college, most courses became less demanding. Significantly, there was little early alarm about the decreased rigor and low expectations for the majority of students, perhaps because Americans embraced “the notion that the reform of secondary education was a great democratic crusade, a sort of academic populism” (Cohen, 1985, p. 255). And over time, colleges sought to increase their enrollments, relaxing admissions standards to attract more students. This appeared to change perceptions of what it meant to be college ready (Cohen, 1985). However, the advent of Sputnik renewed reformers’ interest in improving the curriculum, though they had divergent aims. As noted by Cohen (1985), the impact on schools was limited, save the introduction of improved curriculum materials. The reformers made little effort to tailor recommendations to classroom conditions or teacher needs. In addition, it appears the Civil Rights Movement and concern with opportunities of underserved students overshadowed this tide of reform. The Civil Rights Movement “broke open the ‘closed system’ of [school] governance” (Tyack and Cuban, 1995, p. 26). This model of social activism influenced future reforms. Thus, the federal government legislated a new mandate for education through Title I of the Elementary and Secondary Education Act of 1965. Title I was spawned to increase opportunities for 31 31130? I it)“ '3 minority and low-income students; in response, schools developed programs to serve low-achieving students, including “functional education,” or courses of an experiential, “practical” nature (Cohen, 1985, p. 287). In the meantime, the “upper tracks” also received increased attention through the development Of advanced preparation for college. This “compromise” between those deemed more or less capable resulted in a program of “selective excellence,” typically for privileged students (p. 288). Overall, the evidence indicates that the standard response to mandated reforms in curriculum, instruction, and assessment in the past has been the proliferation of new programs and curricula, dubbed by Farrar (1985) as “Specialty shops” (Cohen, 1985; Farrar, 1985; Cusick, 1992; Tyack and Cuban, 1995). A slightly different slant on the organizational response to educational imperatives and mandates is provided in a study by Rowan (1982). Based on an historical reconstruction of K-12 districts in California from 1930 to 1970, Rowan analyzed the “natural histories of institution building, diffusion, and stabilization in the areas of school health, school psychology, and school curriculum” (p. 263). Piecing together information from the state school code and legislative history with district directories containing organizational charts, Rowan hoped to discover patterns in districts’ structural responses to state legislation. He hypothesized that when institutional environments of schools are characterized by “balanced positive evaluations and harmonious working relations in a given domain, the structures supported by such efforts are likely to be adopted at the local level” (p. 263). In other words, he posited that congruence between state legislation and public support in a stable, coordinated Institutional environment would lead local districts to add administrative positions to 32 QUIT ,- a his 1 D i ,- . .I'”. Z1 in: 4, End.“ E I‘ ‘ "1'. “at u 1 an M. Ll “come into isomorphism with prevailing norms, values, and technical lore in the institutional environment” (p. 259). His findings revealed that districts did indeed adopt and retain new administrative positions under conditions of institutional balance, while they tended to drop such positions under conditions of institutional imbalance. In the domain of curriculum, he found three significant periods of diffusion of curriculum personnel in districts, “each roughly corresponding to institution building” (p. 271). The first period of diffusion between 1935 and 1940 followed the release of state curriculum guidelines and certification requirements for curriculum supervisors; the second period of diffusion emerged between 1945 and 1950, as state math and social studies curricula were revised; and the third period, fi'om 1955 to 1965, paralleled the 1958 passage of the National Defense Education Act, which aimed to improve math, science, and foreign language instruction. F urtherrnore, the data revealed, “The domain of curriculum, which had been destabilized many times and which finished the time series in a state of imbalance, appeared less able to support local structures stably than the more placid and balanced domains of school health and psychology” (p. 273). This confirms the observations of other theorists, who have observed that curriculum is a source of ongoing public debate due to conflicting values and beliefs (Cohen, 1985; Tyack and Cuban, 1995), tending to destabilize the institutional environment more frequently. Thus, it appears that districts tend to adopt specialized structures when the institutional environment supports it. However, in this study, it did not appear that Rowan accounted for economic fluctuations and revenues available to districts when they added or subtracted positions. While it may be that institution building takes place in a supportive Context of stable finances, this would be helpful to verify. This is in keeping with the 33 n-, tx‘. {In city In. argument posed in this review that declining district revenues limit district options for adding new administrative positions, thus forcing a different organizational response to external mandates. Current Context The current educational context iS marked by continued, sometimes escalating public demands for K-12 schools, increased mandates in response to perceived shortcomings of schools, and declining real revenues to support the time-honored organizational response to mandates through increased specialization of curriculum, personnel, and programs. AS observed by Cohen, prior to the 19803, teachers and their core instructional practices remained remarkably unchanged in response to mandates, situating reforms “within the organization and ideology that were adopted seven or eight decades earlier” (1985, p. 300). Ensuing declines in college prep test scores in the 19803, such as the Scholastic Aptitude Test (SAT), caused an increase in public concerns regarding K-12 schools. Thus, the focus of the 19803 reforms overall has been to demand more: more academic requirements, calendar time, graduation credits, core requirements (particularly in math and science), increased requirements for teachers, etc. (Cohen, 1985). Increased Mandates: 1 980s to Present Since the 19803, mandates for K-12 schools have increased greatly. This has had a demonstrable impact on K-12 districts and their leaders as they coordinate organizational responses to the mandates. Research conducted by a doctoral student (Scheerhom, 1995) at Michigan State University studied the effects of Michigan 1681' Slative reforms on superintendents and the organizational structure of their districts. 34 She outlined state legislative reforms for public schools from 1968-1995, spanning forty- one pages of text (pp. 332-373). In a quantitative survey of superintendents across the state, the study revealed that superintendents’ roles had been significantly expanded by state reforms, finding that superintendents spent “forty percent of available time administering, supervising, managing, leading, and communicating matters related to the state reform issues” (p. 219). In addition, Scheerhom discovered that the organizational structure of schools changed in response to state reforms: State reforms have forced schools to become more bureaucratic. There are more rules, more regulations, people, and resources to monitor the rules and regulations. . . . The combination of increased bureaucracy on one hand and increased purview on the other is responsible for changes in the role of the superintendent. She or he has more things to do, more people to see and be concerned about, and less authority to direct either the things being done or the people doing them (p. 220). In 1997, Wayne Peters built on Scheerhom’s work with a qualitative study of the effects of state reforms on superintendents and the organizational structure of their districts. His work focused on 208 school reform measures between 1969 and 1994, noting a significant increase in “the pace of school reform legislation and regulation and the sheer numbers of individual reforms enacted” (p. 181). In interviews with twenty- seven superintendents throughout the state and subsequent analysis, three major themes surfaced fi'om the superintendents’ reports: they did not see continuity or an overall plan to the mandates over time, local control was eroded, and the mandates created increases in superintendent workload and job dissatisfaction. And in keeping with Scheerhom’s findings, Peters’ study concluded that in response to mandates, district organizations became “more specialized, hierarchical, and universalistic as well as more diverse, diflhse, and inclusive” (p. 15 3)- 35 L. O“ Ink [LA Summary: Theoretical Explanations for Organizational Responses to Mandates This review describes the relationship between economic and political forces and the educational system in the United States, outlining the evolving purposes of education over time and their reflection in external mandates. Based on the theoretical formulations included in this review, it appeared that K-12 districts respond to policy mandates in curriculum, instruction, and assessment in some predictable ways. As anticipated by Weber’s (1947) conceptualizations, supported by Scheerhom (1995) and Peters (1997), K-l2 districts become more bureaucratic as they respond to external mandates. Thompson’s ideas (1967) predicted that the contingencies and constraints posed in the rapidly changing, heterogeneous task environment of K-1 2 schools would force increased specialization of organizational structures, while the multiple levels of interdependence within and outside of the district would require effective coalitions with others in power, thus increasing responsibilities for coordination and discretion by its administrators. Institutional theory as developed by Rowan and colleagues (Meyer and Rowan, 1977, 1978; Rowan, 1982; Rowan and Miskel, 1999), elevated the importance of the institutional environment of K-12 schools, predicting that districts would incorporate institutional myths as they seek isomorphism with the institutional environment. Institutional theory also predicted the sacrifice of rational organizational goals in favor of increased legitimacy and stability realized by assimilating institutional norms, values, and rules, along with decoupling of structural subunits as school leaders focus on administration of institutional rules rather than daily educational functions. 36 Incl mi In“. Theoretical Gaps and Exploratory Research Questions While prevailing organizational theory explained a great deal about the structure and function of K-12 districts, including their organizational responses to external mandates, they appeared to have two significant limitations. None of the theories included in this review fully addressed the challenges posed to K-12 districts in the current educational context of a plethora of complex mandates that come equipped with stiff accountability measures. They also did not consider the increased difficulty in responding to mandates given declining real revenues in states such as Michigan. As Rowan and Miskel observe, “the institutional environment of education is changing in the United States . . . There is a greater emphasis on monitoring organizational performance, a growing attempt to develop more coherent educational policy, and a growing interest in market-based controls over education” (1999, p. 379). Given the national trend for states to implement educational funding systems similar to that of Michigan, in which district budgets are based on enrollment, many more districts nationwide may face the financial constraints experienced in some Michigan districts (Odden and Pious, 2004). One favored response of the educational bureaucracy to external mandates has been to develop specialized positions, curricula, and programs. However, depending on the school finance structure used in various states, increasing numbers of districts struggle with small increases in real revenues, or even declining real revenues, to accomplish the additional work imposed by increasing mandates. It is possible that districts now exhibit different responses to external mandates than in the past. Thus, organizational theory requires further testing through research of K-12 37 districts, resulting in modification of prevailing theory in order to describe, explain, and predict these responses, as well as to elaborate the conditions under which they occur. In recognition of Michigan’s current educational context, the following questions were developed to explore K-l2 districts’ responses to policy mandates introduced through federal and state legislation. The questions recognized that while the unit of analysis was the district, the primary source of information for evaluating districts’ responses was its administrators. 1. How do K-12 administrators learn about and assess mandate requirements? How do administrators first learn about mandates? What is involved in assessing the various requirements? What are administrators’ responsibilities for mandates and how are they assigned? Answers to these questions will provide essential background for analyzing changes in district structure and function. This establishes a context for understanding districts’ responses to policy mandates, leading to the second exploratory question: 2. How do K-12 administrators respond to mandates and monitor district implementation? In complex organizations, administrators rarely act alone in enacting a response to significant external mandates. This question probes for information about the actors and processes involved. Who is involved in implementation and monitoring and what do they do? Does it involve others outside the district? How is work organized, assigned, and communicated to others? How much time is spent in these activities? 13 implementation monitored closely or superficially, and what contributes to such decisions? This leads to the third question: 3. What administrative challenges are created by these mandates? What conflicts do they pose for districts? Are district resources adequate to address the mandates? Are the mandates congruent with district and administrators’ values and beliefs? Is there fidelity of implementation, and how is this represented internally and externally? Do administrators perceive the policy mandates as unbending institutional structures that regulate their daily work, or do they generally ignore the mandates, creating alternative structures and rules to guide them? What is the role of special interest groups in district planning, implementation, and monitoring of mandates? Are there things administrators are unable to do because of mandate requirements and workload? These questions may draw out perceptions of continuity or discontinuity between the broader educational system, represented by external mandates, the formal organization of K-12 districts, and the administrators who work within them. 38 I 9'.) .1\ mo 4 nu" L I . . t It Summary This study was conducted to describe and explain the response by K-l2 districts to policy mandates introduced through federal and state legislation. The current educational context of increased mandates and demands for school reform has posed an interesting ‘ topic for study, as many researchers have found that little truly changes in education, despite the efforts of policy makers and educators alike (Tyack and Cuban, 1995). If there is any hope of meaningful change, it is important for the educational community to more fully understand how districts actually respond to policy mandates. This, in turn, may help to inform development of future policy mandates and implementation to increase the odds of sustained educational improvement. Thus, the current educational context, when viewed through the lens of the literature reviewed herein, helped to inform the exploratory questions that formed the basis for this study. While the exploratory questions appeared to follow a linear logic, during the research process, it was important to recognize the data collected did not fall in such an orderly pattern. Throughout the study, it was critical to look for and discern emerging patterns, and to consider divergent interpretations for collected data. In Chapter II, Methodology, the researcher addressed methods and sampling to gather and analyze data on the exploratory questions. 39 \L C". CHAPTER II RESEARCH METHODOLOGY Introduction The purpose of this study was to describe and explain the response by K-12 districts to policy mandates introduced through federal and state legislation. Many current educational mandates clearly delineate desired student outcomes. However, the mandates do not specify how districts may achieve these outcomes. In addition, it seemed likely the researcher would find common patterns in organizational responses to external mandates. Hence, this study was designed to explore two districts’ responses to external mandates, and to consider themes and patterns that may reflect the response of other districts. In this chapter, I describe the research methodology, conceptual framework, and exploratory questions formulated to guide the research process. I also review sampling strategies, data collection, and the interview process and protocol. A well-designed and written research study outlines how the researcher explored and developed answers to the questions posed. This study was conducted with deliberate, planned alignment between the problem statement, research questions, conceptual framework, research methods, and data collection and analysis, as recommended by prominent scholars of sound research methodology (Yin, 2003; Rudestam and Newton, 2001; Miles and Huberrnan, 1994). The following description outlines how the study was carried out to address research questions, while measuring each element against criteria formulated by specialists in research design and methodology. 40 Cw L-l. an [-1 (47 Exploratory Questions and General Case Study Methodology Exploratory Questions The purpose of this study was to describe and explain the response of a K-12 district to policy mandates introduced through federal and state legislation. While the unit of analysis was the K-12 district, the primary source of information was its administrators as they enact the district’s response. Exploratory questions, as presented in Chapter I, included the following: 1. How do K-12 administrators learn about and assess mandate requirements? 2. How do K-l2 administrators respond to mandates and monitor district implementation? 3. What administrative challenges are created by these mandates? What conflicts do they pose for districts? In researching these questions, it was important to consider factors that contributed to the district’s response, including the current context of increasing federal and state mandates. Case Study Methodology and Defining the Case In keeping with principles of sound study design, the exploratory questions helped to determine appropriate study methodology (Yin, 2003). When “how” questions are asked “about a contemporary set of events over which the investigator has little or no control” (p. 9), the case study method is preferred over other methods. In particular, it allows for the “situation in which there will be many more variables of interest than data points, and as a result, relies on multiple sources of evidence, with data needing to converge in a triangulating fashion” (pp. 12-13). In this study, the set of events was contemporary and the researcher was not seeking to manipulate the events. The case study method was chosen to allow study of 41 mm} com wucturf '0 later. hm“ .\Iif Stud}. EB. “ considered mandates r exploration responses L student ouz. limes (If- "I As I research dc: and Huhcm‘ IBQUlrt‘d It} mfimfldn [0 Coming-i. mysis. A J Pfii’dllte fl and he pmil many complex and interwoven variables, including the size, location, and administrative structure of the district, district enrollment and finances over time. As will be explained later, however, the research interview emerged as the primary method used in the study. Miles and Huberrnan (1994) advocated clearly defining the scope of the case study, as well as “bounding the territory” (p. 25), which identifies factors that will not be considered within the case study. In this study, district level responses to external mandates represented the unit of analysis. Thus, the study did not include exhaustive exploration of cultural factors, either externally or within the district, building level responses to mandates, classroom level implementation of mandate requirements, or student outcomes. Issues of “Fit” and Establishing a “Chain of Evidence ” As noted by experienced researchers, it was important to ensure the overall research design fit the research questions and conceptual framework (Yin, 2003; Miles and Huberman, 1994). By doing so, the researcher establishes the “chain of evidence” required by the readers “to follow the derivation of evidence . . . . [and] to trace the steps in either direction, from conclusions back to initial research questions or from questions to conclusions” (Yin, 2003, p. 105). In the next sections, I describe the chain of evidence constructed between questions, conceptual framework, methods, and data collection and analysis. Preliminary Conceptual Framework A preliminary conceptual framework helps to define “either graphically or in narrative form, the main things to be studied—the key factors, constructs or variables— and the presumed relationships among them” (Miles and Huberman, 1994, p. 18). A 42 graphic display of the preliminary conceptual framework is included in Appendix A, described here in narrative form. This conceptual framework was then modified throughout the data collection and analysis process, and fiilly elaborated in subsequent chapters. The preliminary conceptual framework was organized into shapes, containing conceptual constructs or entities, and arrows, indicating the direction of influence between them. Unidirectional arrows posited a primarily one-way influence, whereas two directional arrows indicated a reciprocal influence between the constructs or entities. As displayed in the yellow oval at the top, the “External Context” for K-12 districts was established through legislative mandates, both federal and state, and the state’s educational finance system. Increased legislative mandates in the areas of curriculum, instruction, and assessment were passed at the federal level (including No Child Left Behind) and the state level (as evidenced by the April 2006 passage of Michigan’s new high school graduation requirements). These mandates included strict accountability measures and consequences for noncompliance. In addition, in Michigan, the passage of Proposal A fundamentally changed school finance; prior to Proposal A, school funds primarily came from local property taxes. With Proposal A, school finding is based on a per-pupil foundation allowance to districts, generated by the state sales tax, state property tax, income tax, lottery firnds, and other revenues. New legislative mandates and changes in the state’s educational finance system thus comprised the external context presumed to have an impact on local districts. While the External Context included other elements, in the context of this study, the subset of legislative mandates and school finance were the only factors considered. 43 _ «a l. ‘u lirj In 3‘ the 0mm}: I function 0f districts Cor intermedist: department? personnel at Educational (081). etc. I Curriculum of supports 1 implications to assist is iIl counsel and external p." strove to co hmctional r' Influenced ‘ I illlmded b\ In addition, local districts have relationships with “External Partners,” shown in the orange rectangle. The External Context was presumed to influence the structure and function of both local districts and External Partners as they worked together to help districts comply with the mandates. External Partners included a number of state, intermediate, and local entities. The Michigan Department of Education (MDE) has departments that work at multiple levels with Intermediate School District (ISD) personnel and local districts to ensure compliance with mandates, including the Office of Educational Assessment and Accountability (OEAA), the Office of School Improvement (081), etc. Professional associations such as the Association for Supervision and Curricultun Development (ASCD) and its Michigan chapter (MASCD) provide an array of supports to local districts, including summaries of legislative mandates and their implications disseminated over listservs and publications, and professional development to assist with implementation. Researchers with university affiliations offer districts counsel and professional development in exchange for permission to do research. These external partners were presumed to be a significant support to local districts as they strove to comply with external mandates, thus having an impact on the structural and functional responses of K-12 districts. In addition, the expressed needs of districts influenced the behavior of External Partners. The blue rectangles represented the K-12 district, administrative responses to mandates, and consequences of responses for the district. In the context of this study, the blue boxes in the conceptual fiamework represented the primary focus of analysis. While the External Context and External Partners exerted influence on the district, the case was bounded by its emphasis on the organizational responses of the district to external 44 mandates demil- b”! 10.33] dl>lf W St'uctu'iii mandates- configuml organizatir structure If human resr Respimse v legislatii'e I resp’msibili included as: generalist at across multi external par reSl‘OrIsibiIQ llic It adminis mandates. Thus, the External Context and External Partners were not explored in great detail, but were important in terms of the challenges and opportunities they posed for local districts. Within the district, the two medium blue rectangles included elements of the Structural Response and Functional Response of K-12 administrators to legislative mandates. The Structural Response of the district was posited to reflect the district’s configuration of administrative responsibilities (i.e., as displayed through the organizational chart). At the level of K-1 2 district administration, organizations typically structure the division of labor within particular roles and departments such as finance, human resources, curriculum, and special education. At the outset, the Structural Response was conceived to illustrate possible, varying configurations in response to legislative mandates. One possible configuration thus included assignment of responsibilities to highly specialized positions or departments. Other structural responses included assignment of multiple areas of responsibility for compliance with mandates to generalist administrative positions, or shared responsibility for mandate requirements across multiple positions. Another response could have involved greater reliance on external partners through formal contracts as districts hired partners to fulfill certain responsibilities, or through less formal arrangements such as consultation and support. The Functional Response of districts was conceived to reflect the behavior of K- 12 administrators as they institutionalized “myths” of the external context (Meyer and Rowan, 1977), developed bureaucratic rules and protocols (Peters, 1997; Scheerhom, 1995; Cusick, 1992; Thompson, 1967), and increased monitoring of the task environment to learn about new mandates (Thompson, 1967). In addition, districts could display loose 45 or tight c: monitorir district cc and dare Fii consequcr responses include dc. with Extcr Another pt retired. “c1 boxes at th. Illnctiona} , “tonight to ; reSItv‘nSes, or tight coupling between mandate requirements, and fidelity of implementation and monitoring (Rowan and Miskel, 1999). Communication content and patterns within the district could also change to reflect increased communication about external mandates, and decreased communication in other areas deemed to be less important. Finally, the light blue box at the bottom, Consequences, displayed the consequences of the External Context, mediated through the structural and functional responses to legislative mandates, for the K-12 district. These were conceptualized to include decreased local control in favor of institutionalized myths, increased coalitions with External Partners, and impact on perceived and actual performance of the district. Another posited consequence was increased administrative turnover as administrators retired, were fired, or sought positions elsewhere. The two-way arrows between the blue boxes at the district level reflected the mutual influence between the structural and fimctional responses of K-12 administrators. The resulting consequences were thus thought to act as a feedback loop for the district, affecting future structural and functional responses. Sampling It is important to note that in case study research, the purpose for sampling is not the selection of a representative sample that can then be generalized to a population or universe, as in quantitative studies. Rather, the goal of sampling in a case study is to “expand and generalize theories (analytic generalization) and not to enumerate frequencies (statistical generalization)” (Yin, 2003). 46 t. Sampl-‘nx 3‘“ l n 1h" conduct 21 pi yielded \ all At‘te‘ into a case q would requi Stud) ofa li \anables of of interest. 1 SIUd}.1he rd and locatior mandates. ' 5m} and c. Pill” Swill} . Mi“ ‘\ Wings‘ act reSearch qt K-lZ mm: the low {rm The com Unit} Sampling Strategies In this study, I used the district where I am employed as Curriculum Director to conduct a pilot study. The pilot study guided development of the primary case study, and yielded valid, useful data that was incorporated in the overall study. Afier the pilot study, one district was identified for data collection and developed. into a case using “replication logic” (Yin, 2003). As opposed to “sampling logic,” which would require the study of a great number of cases, using replication logic allows for study of a limited number of cases. Cases may be chosen for either their similarity on variables of interest, thus predicting similar findings, or for their differences on variables of interest, thus predicting different findings according to theoretical constructs. For this study, the researcher used the pilot study and case study to examine how variables of size and location (suburban and urban) affected their structural and functional responses to mandates. This feature afforded the opportunity, albeit limited, for both within pilot study and case study analyses, as well as cross study analyses. Pilot Study and Case Study Parameters Miles and Huberman (1994) identified four within case sampling parameters: settings, actors, events, and processes. Sampling of these elements was aligned to the research questions and conceptual fi'amework. In conducting the study, the primacy of K-12 responses to legislative mandates in curriculum, instruction, and assessment was at the forefront of sampling decisions. The schools studied differed in several ways. It is important to note the identities of the study districts have been protected by using pseudonymous names. Fairview Community Schools, the site of the pilot study, is a medium-sized suburban district of 47 approximait an urban dis potential dii dNTlpilOfl ( Ano Spanned eig time samplc collection \\ The from me 51.. Educalion a resI‘OnsiblC inCluding 5‘ (firmer-g a' PrincipalS d gl’OUp. reELi' “onhxxhgjt decisiOn u; fftim bOIh } I kinds of [to approximately 3,400 students. Steele Public Schools, serving as the case study setting, is an urban district serving approximately 7,000 students. This allowed for the study of potential differences in response to mandates based on their differing characteristics. A description of each study site is more fully described in Chapter IV. Another feature of setting is the time period. The time sample for this study spanned eight years, from approximately 1999 to the present. This allowed a sufficient time sample to explore the responses to mandates over time, while keeping data collection within manageable bounds. The actors or people interviewed totaled twenty individuals, including personnel from the study districts, as well as representatives from the Michigan Department of Education and two Intermediate School Districts. Local district administrators responsible for coordinating any aspect of the selected mandates were interviewed, including superintendents, curriculum directors, human resource directors, and finance directors, along with teacher specialists with quasi-administrative responsibilities. Principals and assistant principals from Fairview were asked to participate in a focus group, resulting in one focus group session with four elementary principals. While worthwhile, it did not generate the kind of detailed information needed. Instead, a decision was made to conduct interviews with an elementary and a secondary principal from both Fairview and Steele. These interviews resulted in more in-depth detail and the kinds of responses needed to gauge building level administrators’ perspectives on district responses to external mandates. The events sampled included the passages of No Child Left Behind and MCL PA 165 and 166 (Michigan’s Compiled Laws pertaining to mandated HIV /AIDS and allowed 48 58X educallt curriCUlum' implication: with clearl.‘ federal legit reanthorizfl the arena of administratt accountahil" formal repo and 166 is r three years 4 requiremen‘ interesting \ description Fin. 0f respon 51' . rev - I ~P0n51bif' d? ‘- I ‘m‘tt‘iz‘cuh _ I' file mandat sex education). No Child Left Behind is arguably the most significant mandate in curriculum, instruction, and assessment of the last ten years, with far-reaching implications and demands on local districts; it is also an example of an external mandate with clearly specified accountability measures and reporting requirements. Passed into federal legislation in 2001, NCLB is currently six years old and is scheduled for reauthorization in 2007. MCL PA 165 and 166 was selected because while it falls within the arena of curriculum, instruction, and assessment, it is widely considered by district administrators to be outside the purview of core academic programming. In addition, the accountability measures are fewer and not as clearly specified, and it involves fewer formal reporting requirements to the Michigan Department of Education. MCL PA 165 and 166 is relatively new, passed into Michigan legislation in 2004. While it is less than three years old, it is not so new that districts have not had time to respond to its requirements. Mandates with differing characteristics were chosen as they posed another interesting variable to explore in assessing districts’ responses. A more complete description of the mandates is presented in Chapter 111. Finally, a variety of processes within each district were sampled. The distribution of responsibilities for mandate requirements was studied through relative specialization of positions and departments. The number of administrators fulfilling various fimctions relative to implementing the mandates was measured, including changes in allocation of responsibilities. Bureaucratic rules, regulations, and communication patterns within districts were scrutinized to determine the extent to which each district institutionalized the mandates. Evidence of district level decision-making regarding fidelity of implementation was sampled. And lastly, the processes administrators employed to 49 "d— decide “hat desirable ac (use Sump/ Mile confidence 1 SM} desigr clear about 1 different ch;| selected dis be conductd Study. Mi l: deSlgnS liter mCimed u appmach. ' the Chitllcn pr(“meted , ClEaI label“ €014} dlcad, ill-1110“ U l I decide what not to do, either in response to mandate requirements or relative to other desirable activities, were explored. Case Sampling Miles and Huberman (1994) asserted that “multiple-case sampling adds confidence to findings” (1994, p. 29). While the replication strategy of a multiple case study design may lend greater validity to the findings, in this study, it was important to be clear about the purposes for the districts’ selection. To choose districts with drastically different characteristics in many areas could obfuscate data analysis. Thus, the researcher selected districts that differed on a limited number of variables. It was hoped that using key sampling parameters for the pilot and case study would strengthen the validity of the findings, given that only two districts were studied. The design allowed for each study to be conducted and analyzed separately, with comparisons drawn after completion of each study. Instruments/Measures Miles and Huberman (1994) elaborated the inherent challenges of case study designs that are relatively unforrned prior to fieldwork and data collection, versus highly structured designs. I weighed the relative advantages and disadvantages of each approach. While a less structured approach would lend greater flexibility at the outset, the challenge lies in its ambiguity, potentially leading to more time in the field, a more protracted period of data collection and analysis, and the risk of collecting data without a clear focus or outcome. However, adherence to a rigidly structured case study protocol could lead the researcher to overlook unanticipated, important data and a reluctance to follow up on important leads, negatively impacting data collection and analysis. This 50 I' 658513 (JO-ES if: method irrstrum pertiner semi -strt and l66 ;' pertinent “Plimally rich nana: 311d tlexihi inteniecr-C‘ qUCSliong. ‘ parllClPCints preplanned A l,. \ MDE Cont» researcher formulated a moderate approach to case study design, recognizing time constraints and the risks involved in loose coupling between research questions and methods, while leaving sufficient flexibility to follow up on promising data. The primary instruments and measures selected for use in this study included interviews and review of pertinent documents. Semi-structured Interviews Heeding the cautions of Mishel (1991), the researcher devised a protocol for semi-structured interviews of district administrators, principals, and Intermediate School District (ISD) consultants involved in the implementation of NCLB and MCL PA 165 and 166 (Appendix B). The protocol provided a set of standard probes and sets of pertinent follow-up questions. However, in recognition of the interview as a process that optimally leads to collaboratively shaped discourse and construction of a contextually rich narrative, the researcher was careful to exercise the kind of listening, adaptiveness and flexibility lauded by Yin (2003) as characteristic of good interviewing. Thus, the interview questions were constructed to yield important data in relationship to research questions, while the interview process itself yielded significant opportunities in which the participants followed up on emergent leads, allowing the interviewer to diverge from preplanned questions and interviewees to respond in kind. Informants for the interviews included central office administrators, elementary and secondary principals, [SD and MDE consultants, and a focus group of elementary principals from Fairview. Review of Documents Documents from two levels were explored, including the External Context and the K-12 districts. Documents from the External Context for study included NCLB and 51 MC L PA requirem the follm ' Orgar ' Docu. and p: and B Yi cond uctin procedure C3156 Stud} fella/51],!“ the data C0 dfil elOpCd described \ deClSlOnS r 0! llé‘ld pr I}; 1 . ~6. Jim , Michigan MCL PA 165 and 166, and other documents disseminated to local districts outlining the requirements. From the K-12 districts, a variety of documents were studied, including the following: I Organizational charts and other human resource documents I Documents outlining responses to mandates, including meeting minutes, regulations and procedures, communications (letters, e-mails), presentations and reports at staff and Board meetings Procedures Yin (2003) described the importance of constructing a case study protocol prior to conducting fieldwork. The protocol contains an overview of the project, field procedures, case study questions and the data collection instrument, and a guide for the case study report. As Yin notes, “The protocol is a major way of increasing the reliability of case study research and is intended to guide the investigator in carrying out the data collection” (italics in original, p. 67). Thus, construction of this research design developed the primary components of the case study protocol. The project has been described with identified research questions and a conceptual framework that guided decisions regarding sampling and instruments/measures; in the next sections, description of field procedures, data collection, and analysis is offered. Preparation for Fieldwork Following the researcher’s successful Dissertation Proposal Defense on January 26, 2007, required protocols for obtaining approval to conduct a research study through Michigan State University’s Institutional Review Board (IRB) were completed. This 52 resulted A rex isit and her a Superint: pamnete adiisor it adt isor g Mr. Edmi conduct n contacts a informam questions. and in \m' mUIuall} a “as an im resolute kj ”limit?“ . millage. ~. ‘Jl‘< Obldlned . resulted in initial approval to conduct the pilot study in Fairview on February 27, 2007. A revision to extend the study to Steele was approved by IRB on May 14, 2007. Prior to conducting fieldwork, potential districts were discussed by this researcher and her advisor, based on their relative size and location. I gained consent fiom the Superintendent in my district to participate in the pilot study, outlining the purpose and parameters of the study. Based on his contacts with the selected case study site, the advisor initiated the first contact with the Superintendent for Steele Public Schools. The advisor gained preliminary content, and my advisor and I subsequently met together with Mr. Edmonds, Steele’s Superintendent. In order to build trust and solicit permission to conduct research in the district, it was critical to develop a mutual agreement with district contacts about data collection procedures, as well as confidentiality of data and informants (Miles and Huberman, 1994). Thus, I summarized the research purposes, questions, and methods for data collection and analysis with district contacts, both orally and in writing. Once agreement was formally secured, Mr. Edmonds and I developed a mutually acceptable timeline for data collection. Mr. Edmonds’secretary, Ms. Temple, was an invaluable liaison in gathering contact information, district calendar and human resource documents, etc. Similar procedures were also used for contacting and securing permission for interviews with representatives from the Michigan Department of Education and Intermediate School District consultants. Given that single interviews were sought with representatives from these entities, as opposed to full-fledged studies, permission was not obtained from their superintendents in advance. 53 ..-—"'-‘ ‘_ -F'V Y-E‘LHI“ '- Tut betueen fol Appendix lSD consul Interview .\ ln‘. within the consultunr informam. lRB—appn ~. lmfn'ieu _\ idiom-fir ll llll lnli'tr ”3113mm. \\ Data Collection Two types of data were collected in this study. Interviews typically lasting between forty-five to sixty minutes, using the Semi-Structured Interview Protocol (Appendix B) were conducted with district representatives, MDE representatives, and ISD consultants. Documents for review were also requested of informants. Interviews Interviews with local district and building administrators were conducted on site within the selected districts. The interviews with MDE representatives and ISD consultants were conducted at sites mutually convenient to the interviewer and informants. Appropriate procedures were used for obtaining written consent, using the IRB-approved Consent Form (Appendix C). Under the conditions of the Consent Form, interviews were audiotaped and transcribed. Inforrnants were told of the potential for follow-up interviews, although these were not needed. Transcript copies were shared with informants for review and feedback to ensure accuracy. No revisions to the transcripts were suggested or requested by the informants. Within Fairview Community Schools, interviews were easy to schedule and complete due to my access as a district administrator. These interviews proved helpful to the evolving research process as an opportunity to both field test the Semi-Structured Interview Protocol questions, and to practice and refine good interviewing skills with familiar colleagues. It was revealing to hear my colleagues’ perspectives on our district’s response to mandates; while I may have thought I could reliably predict how they would answer questions, the interviews gave me a unique opportunity to listen to fellow administrators in ways that often seem out of reach given the busyness of our work. I 54 - 5 w._;-.-. fl Haj discovered )ielded use pilot stud} quite saris: case stud} . ot‘sltill wit ln . called for t administr; tntenievs s bath to m; “as Under | raturned. f adminism from out mandala ended up SuWfintq Sat do“.T shined discovered I could not have anticipated all they shared. In addition, the pilot interviews yielded useful data for later analysis and comparison to the case study data. Overall, the pilot study confirmed the value of the protocol questions. In fact, the protocol proved quite satisfactory in gathering useful information, and required no revision for use in the case study; what likely changed from the pilot to the case study interviews was the level of skill with which the interviews were conducted. In contrast, scheduling interviews at Steele was problematic. My initial timeline called for completing them during the month of June. Once school was out in mid-June, administrators were often unavailable for long stretches of vacation. I scheduled interviews throughout the summer as administrators’ calendars allowed. When they were back to work in August, planning and professional development for the new school year was underway, and I rushed to complete as many interviews as possible before students returned, finishing the last two interviews within the first weeks of school. Most Steele administrators were very receptive to meeting with me and were generous with their time. From one of the administrators, however, a critical player in the district relative to these mandates, I received little response initially, despite repeated voice and e-mail contacts. I ended up consulting with my advisor, who encouraged me to contact Mr. Edmonds, the superintendent. Mr. Edmonds coordinated scheduling of this interview. When I finally sat down to talk with the administrator, she was initially cool, but gradually relaxed and showed signs of enjoying our discussion as we got further into the questions. Inevitably, there was one administrator, actually, a teacher with quasi-administrative responsibilities as the district testing coordinator, who indicated she was “too busy” to talk with me. 55 With 1h respk‘nS initial if the to?“ gfnUlnC 5(th “1 being 3U promim' couple oi collalxtrd to unload administr their dedi obstacles _\'. interestin, The range twenty-th- (”feted in 0510.3721- I: ; l . ahOlll ilk With the encouragement of my advisor, I interviewed an administrator with the same responsibilities in a district with similar characteristics to Steele. The demeanor of informants during the interviews revealed a common pattern: initial interest in the topic and interview process, a sense that they were “warming up” to the topic and questions, an eagerness to share their knowledge and experience, and a genuine desire to be helpful. Most displayed commitment and passion for their work. Some wanted to tell me “how things really are here,” but at times expressed anxiety about being audiotaped, seeking reassurance their comments would be held in confidence as promised. There were surprising moments of laughter and commiseration, and in a couple of cases, exchanges of information and promises of support for future collegial collaboration. I discovered that when they felt safe in sharing confidences, they wanted to unload at times about difficult dynamics in the district, problems with other administrators, and disappointments in their work. They also wanted to be recognized for their dedication to Steele and its students, and their professional successes in overcoming obstacles in doing the work they regarded as most essential to their roles. Notably, the tenure of interviewees occupying their positions varied, providing an interesting juxtaposition of their perspectives based on length of service and experience. The range of service within a given position ranged from approximately six months to twenty-three years. A record of the interviewees, their positions, and length of service is offered in Table II. Names have been changed to protect the identities of the informants. Obtaining Documents for Review I also requested documents to review fi'om informants, supplying information about the types of documents that would be relevant and helpful. The purpose for 56 documet 2003. p. and subs was 6:5} otiice ad While it “Cl? mu. rationale noncomn that some m3." “ere through p 10 do. In 3 district co Stud}; document review was “to corroborate and augment evidence from other sources” (Yin, 2003, p. 87). The researcher asked permission to borrow documents for photocopying and subsequent retum. The documents produced by the study sites varied in both quantity and quality. It was easy to acquire documents from Fairview, given the researcher’s access as a central office administrator in the district. At Steele, it was much harder to obtain documents. While it was also difficult to schedule interviews in Steele, on the whole, respondents were much more willing to sit and talk than to offer documentation. When given the rationale for my request and asked for such documents, they tended to smile politely and noncommittally. Follow-up requests for documents were most often ignored. It is likely that some of the reluctance was due to the expressed workload of the respondents; while they were willing to sit down and talk for an hour, to spend additional time combing through paper and computer files to cull pertinent documents was more than they wished to do. In addition, as the interviews unfolded, there were unforeseen layers of internal district conflicts in Steele that may have been a barrier to offering up documents for study. Data Analysis Collected interview data and documents were analyzed and weighed against the conceptual framework established at the outset of the study. Interview data and documents within each study site were read and reread many times, common patterns identified and coded, and patterns synthesized into themes. The advisor for this project was very helpful in providing input and feedback throughout this process, reading interview transcripts and sharing observations during meetings. Analysis was recursive 57 across inn reread ant CVOlVC‘d \\ anal} sis :1 sites. Fit constructit data and c into the "( Which illu stemming elaborate l: Distric Si districts :1 m5 gIO't. Cum'culu and offer 1" a and rtll" d F across interviews and sites; with each new set of interviews, the old interviews were reread and reexamined in the light of emerging insights. The phases of the project evolved with initial analysis and summarization of the pilot study data, subsequent analysis and summarization of the case study data, and a comparison of data from the two sites. Finally, analysis of the data continued throughout the writing process with construction of each new chapter and ongoing revisions of the manuscript. In writing the data and conclusions chapters, I worked to revise the preliminary conceptual framework into the “Conceptual Framework of the Educational System,” depicted in Appendix F, which illustrates the organizational relationships and responses to legislative mandates stemming from the External Context, External Partners, and K-l2 District. To further elaborate the response of K-12 districts, I developed an explanatory model, “Stages of K- 12 Districts’ Compliance with Legislative Mandates” (Appendix G). Significantly, a group of my colleagues with similar responsibilities in other districts assisted me in refining this model for explaining districts’ responses to mandates. This group included five assistant superintendents or curriculum directors, and one ISD curriculum director. They generously gave their time to meet with me, hear my ideas, and offer helpful feedback. Validity, Reliability, and Study Limitations Four criteria are commonly used to evaluate the quality of research studies (Yin, 2003). These include validity (construct validity, internal validity, and external validity) and reliability. In this section, I measure this study’s methodology against the criteria. 58 (‘0. questions l etidence. case studi: interviews principals document to the con C0nnectin analysis: t ‘0 Preserx asked to r th‘ii Sire: Validity Construct validity refers to whether instruments and measures address study questions and propositions. It is heightened by multiple sources of evidence, a chain of evidence, and having informants review drafts of the case study analysis. The pilot and case studies within this research project included multiple sources of evidence, including interviews with district administrators, ISD and MDE consultants, a focus group of principals, as well as review of pertinent district documents including human resource documents, meeting minutes, internal communications, Board presentations and reports to the community. In addition, the researcher established a chain of evidence by connecting research questions, conceptual framework, methods, and data collection and analysis; the case study protocol and case study data base were developed and maintained to preserve the chain of evidence. Finally, informants in the case study districts were asked to read and provide feedback for appropriate revisions to the case study analyses, thus strengthening construct validity of this research design. Internal validity reflects whether the study establishes correlations or causal relationships between study concepts. The primary burden of ensuring internal validity falls on the data analysis phase. Meticulous data analysis to elaborate patterns, construct explanations for patterns observed in the data, and test contradictory explanations increases internal validity (Yin, 2003). Rather than relying on single data points, either through interviews or document analysis, this study triangulated varied sources of data to derive patterns, develop themes, and report findings. Having informants review preliminary drafis of the data analyses through “member checks” (Rudestam & Newton, 2001) firrther enhanced internal validity. 59 domain theoreti studies. underpi follow. in\ 0l\ er m lets ir Legislat. district r 10 cont-c- Critical it generally 50 that or rallablliy, design a- External validity refers to generalizability of study findings to an established domain. With case studies, external validity is increased when evidence is tested against theoretical concepts, and when the research includes replication through multiple case studies. This criterion was partially met through elaboration of the conceptual framework underpinning the investigation, and by completion of research at two sites: a pilot study followed by a case study, plus comparison of results across sites. In addition, the involvement of five experienced K-12 district administrators and an ISD administrator in reviewing and providing feedback on the “Stages of K-12 Districts’ Compliance with Legislative Mandates” model, helped to test the validity of this model in explaining district responses in other settings not included in this study. The researcher is sensitive to concerns about external validity given the limited number of districts studied. It is critical to be appropriately cautious in drawing conclusions and making theoretical generalizations. Reliability A study is reliable when the methodology and procedures are clearly documented so that others may replicate the study if desired. This study was deliberately proposed, conducted, and written to document a clear chain of evidence, thus heightening its reliability. The researcher has described in good faith the formative steps from initial conception to final conclusion, in order to ensure the critical reader’s confidence that the design and execution are transparent and easily replicated. Limitations While the researcher measured the study against established criteria of quality, it is also important to note its limitations. The pilot study followed by completion of one 60 case stu. replicati addition using di: willing t sigmitica conducti case SIUC Primaril) With adrr School E the inten follow Ul lZiSted be 31mins. distriqs‘ intent?“ case study allows for greater depth of investigation, but also restricted the number of replications, which in turn restricted the variables explored and conclusions drawn. In addition, study sites were limited to those within forty-five miles of the Lansing area, using districts selected with personnel who know the researcher and/or advisor and were willing to grant access. Finally, the inexperience of the researcher was inevitably a significant factor. At the outset of a study, with limited practical experience in conducting research, it was difficult to anticipate what one does not know. Summary This research project utilized an initial pilot study in the researcher’s district, a case study in a second district, and comparison of findings across districts. It relied primarily on interviews as the chief source of data, both within the study districts and with administrators from the Michigan Department of Education and two Intermediate School Districts. A Semi-structured Interview Protocol was used as a general frame for the interviews, with the interviewer and informants mutually shaping the dialogue to follow up on emerging information and impressions. The majority of the interviews lasted between forty-five to sixty minutes, and were audiotaped and transcribed for later analysis. Additional sources of data included documents obtained from the study districts, MDE, and the ISDs, which primarily yielded corroborating support for interview data. 61 to policy present a in the pre frame“ 01 the feder: Intermedi Originatin ”335 fm one-Way 1 12 Dism'C through t‘ reprt‘Sen t ; 156 0n n l eduCaU-Or l Slitrimafi h CHAPTER III THE EXTERNAL CONTEXT: LEGISLATIVE POLICIES Introduction The purpose of this study is to describe and explain the response by K-12 districts to policy mandates introduced through federal and state legislation. In this chapter, I present and analyze information on the legislative policies included here. The legislative policies are the chief “players” in the External Context, described in the preliminary conceptual framework (Appendix A). The theory underlying the framework was that legislative mandates are “passed down from above,” either starting at the federal level and channeled through State Educational Agencies (SEAs) to Intermediate School Districts (ISDs) and Local Educational Agencies (LEAs), or originating at the state level and then channeled to ISDs and LEAs. The unidirectional areas from the External Context to External Partners and K-12 Districts posit a primarily one-way influence, while the two dimensional arrows between External Partners and K- 12 Districts indicate reciprocal influence. Thus, I inferred that the External Context, through the enacted legislation, established itself as the chief stakeholder in the areas represented in the legislation. The External Context for this study includes federal legislation, the No Child Left Behind Act of 2002, and Michigan’s Compiled Laws 165- 166 on Human Immunodeficiency Virus and Sexually Transmitted Diseases and sex education. The organization of this chapter includes three sections. The first section summarizes information on No Child Left Behind. The second section provides a 62 E» nun-1 SVD‘O p51 5 these SCt for comr and and section 5 S Left Beh. Educatio; understar COmm uni .\'t ARIESE' F(reused (— federa} 9 hi: been 1 $201.) bi 11 _~ Aunderpin EXCCUtix ( synopsis of information on PA 165-166, Michigan’s Sex Education legislation. Both of these sections include information on the primary components of the legislation, channels for communication and technical assistance, questions related to K-1 2 districts’ response, and available research on the legislative impact on local districts. The third and final section summarizes the similarities and differences between NCLB and PA 165-166. Federal No Child Left Behind Act of 2002 Signed into law by President George W. Bush on January 8, 2002, the No Child Left Behind Act is a sweeping piece of legislation totaling 670 pages (U .S. Department of Education, 2002). Comprehending NCLB’s significance to K-12 districts requires understanding its historical antecedents, primary components, and channels for communication and technical assistance. Historical Antecedents of NCLB NCLB’s roots may be traced back to the Elementary and Secondary Education Act (ESEA) of 1965, signed into law in 1965 during Lyndon B. Johnson’s presidency. Focused on meeting the needs of disadvantaged, low achieving students, ESEA was the federal government’s response to concerns raised by the Civil Rights Movement. ESEA has been reauthorized approximately every five years since 1965, and has provided over $200 billion in funding for academic programs and services, much of which focused on “underprivileged” students through Title I grants (The No Child Left Behind Act of 2002, Executive Summary, 2002). NCLB of 2002 is the most recent reauthorization of ESEA and is in effect through 2007, when it is again scheduled for reauthorization. Since 1965, increasing concerns about weak accountability measures and loose coupling between legislative intent and student outcomes have spawned changes in ESEA. For example, in 63 ' «fl. ..h'o'.) 3 1088. ll panicul coordin true to 1 children dlilric‘is bc’lu'cen accounts based in: .it‘c'mmu .\ Adequate and puhli for annu; includin: EUVQmP- and mart 11': 13h Sch. Teq 'ired 1988, the Hawkins/ Stafford Act introduced accountability measures for Title I, particularly school-wide assistance programs. In 1994, Title I and ESEA were firrther coordinated through the Improving America’s Schools Act. NCLB is widely regarded as true to the original aims of ESEA, but with increased emphasis on achievement for all children, and incorporates more “teeth,” or accountability measures for states and districts. Significant Components of NCLB NCLB purports to increase student proficiency and close the achievement gap between high and low-achieving students by 2014. Its predominant components address accountability, teacher quality, options and choices for parents, scientifically research- based instructional programming, and flexibility. Accountability NCLB’s accountability methods include testing requirements, measures of Adequate Yearly Progress (AYP), consequences for failing to achieve proficiency targets, and public reporting of school, district, and state performance. NCLB includes a mandate for annual state testing of students aligned to state curriculum standards and benchmarks, including Limited English Proficiency and special education students. The federal government approves assessments provided they meet criteria for validity and reliability. Required subject area testing was rolled out sequentially, with annual testing of reading and mathematics for students in grades 3-8 mandated by 2005-06, with social studies and science assessments required by 2007-08 at least once during the elementary, middle, and high school grades. The National Assessment of Educational Progress (N AEP) is required biennially in grades 4 and 8 in a random sampling of schools. 64 are meeti subgroup applied 0 achiex err b} 3013- minimum to “meet" pert‘onnar .\'t [SUPPOH 1 twinning make AY ,Vear SCllth funds foi- achjel'ent. Idenlified Possibiliti.I l S“1001 dLi' flat}: deer lhe SChOQ ~ Adequately Yearly Progress (AYP) is a measure of whether schools and districts are meeting achievement targets for all students, both collectively and for demographic subgroups including gender, ethnicity, and socioeconomic status. Prior to NCLB, AYP applied only to schools receiving Title I funds. AYP is based on increasing annual achievement targets, calculated by the state to ensure 100% of students reach proficiency by 2013-14. It is important to note that students may not be excluded from testing, as a minimum of 95% of students in each subgroup have to be tested for schools and districts to “meet” AYP. Schools receive “Report Card” grades of “A” through “F” based on their performance against annual state targets. NCLB identifies five phases of “school improvement” for schools receiving Title I support that do not make AYP. The consequences are more severe with each phase, beginning with Phase II, in which a school is identified for improvement if it fails to make AYP for two consecutive years. Phase 11 schools are required to develop a two year school improvement plan approved by the district, spend at least 10% of Title I funds for the next two years on professional development targeted to address identified achievement problems, and allow students to transfer to other district schools not identified for improvement, paying transportation costs for students whose parents elect this option. If schools continue to not make AYP, the sanctions increase, including the possibility of the following: provision of supplemental educational services outside the school day to low-income students, replacement of poorly performing staff members, implementation of new research-based curriculum and professional development for staff, decreased school management authority, appointment of an outside expert to assist the school in revising the school improvement plan, extension of the school year or day, 65 identified .\' ofeach. student and finally, school restructuring (reopening the school as a charter, contracting with an outside organization to run the school, or turning operations over to the state). Once schools in Phases 11 through V make AYP for two consecutive years, they return to “not identified” status, and required sanctions no longer apply. NCLB’s last primary method of accountability is public reporting at the beginning of each school year. States, schools, and districts are required to report disaggregated student performance data on state assessments, graduation rates, AYP status including whether they have been identified for one of the school improvement phases and actions taken, teacher qualifications, and graduation rates. Parents must additionally be notified of school choice information and Limited English Proficiency student placement and program information. Public reporting to parents and community members takes place through multiple venues, including school and district annual reports, publication of student achievement data and school and district AYP status on state educational websites and in the news media, etc. The mark of whether or not schools and districts are making AYP is very public, indeed. Teacher Quality NCLB defined new standards for teachers and paraprofessionals, including the requirement that school staff meet “highly qualified” mandates. By 2005-06, all teachers were required to possess at least a bachelor’s degree, and to teach only within the grades and content areas for which they were certified and endorsed. Alternative means of demonstrating competence, including district approval of professional teaching portfolios meeting state criteria, may be exercised as an option in some cases to ensure teachers meet highly qualified requirements. In addition, districts must make certain new teachers 66 meet min V6313. ant Paraprot‘t Options t ofschoo.’ increasec not meet consecu‘. AYP. er. SCllOols i on proxi Sé'igm If}. studenn underth and Stu achlm'ef grants { meet minimum requirements for professional development hours during the first three years, and that all teachers meet annual requirements for professional development hours. Paraprofessionals were also required to meet qualification standards by January 8, 2006. Options and Choices for Parents As noted previously, parents of students in schools identified in one of the phases of school improvement have significant rights and options. In Title I schools, there is increased responsibility to notify parents when their children are taught by staff who do not meeting highly qualified requirements or when the schools do not make AYP for two consecutive years. Parents may choose to move their students to other schools making AYP, enroll their children in supplemental educational programs, etc. In addition, in schools identified for later phases of school improvement, there is an increased emphasis on providing and funding parent involvement activities and programs. Scientifically Research-based Instructional Programming NCLB includes a strong emphasis on reading, with the goal of ensuring all students meet reading standards by the end of third grade. States receive federal money under the Reading First state grant program to boost teacher professional development and student reading achievement in the early grades. NCLB also supports increased achievement of Limited English Proficiency (LEP) students by combining categorical grants for bilingual and immigrant education to benefit more students, and increases accountability for achievement of LEP students through testing. NCLB also attempts to raise the bar for curriculum, instruction, and assessment through its focus on scientifically researched-based programs. NCLB identifies key characteristics of good scientific research, including use of the scientific method, 67 replicativ study des contergc flexibilt: ll {though I Consolie achieyer. Which it. “thh It; I Proticier Wiser Midis. u addressi replication of research results in multiple studies, generalizability of results, rigor of study design, methodology, and interpretation, meeting peer review standards, and convergence of study findings. Flexibility While increasing accountability, NCLB provides some financial flexibility (though not increased funding) to local school districts and schools. Through Consolidated Grant Applications for federal aid through Title I (aimed at increasing the achievement of low-achieving students); Title IIA (formerly the Eisenhower Grant), which funds teacher and principal recruiting and professional development; Title IID, which funds technology initiatives; Title 111 (programs and services for Limited English Proficiency students); and Title V (funding for innovative programs), districts may transfer funds from one grant to another. The exception to this flexibility is Title I grant funds, which may not be transferred to other grants. This allows for greater flexibility in addressing student and staff needs, as well as school and district initiatives. Channels of Communication and Technical Assistance Multiple communication channels exist for obtaining information about NCLB and its requirements. The United States Department of Education maintains a comprehensive website of information on the policy, its requirements, information on grants and successful projects, links to state information and research studies, etc. (http://www.ed.gov/nclb/1anding.jhtml). State departments of education have entire web pages devoted to NCLB, AYP, state assessments, and school improvement frameworks. Much information is relayed through state department of education conferences, 68 inrnned; publicatit 1.“ and also i local Ed NCLB’S Departm- documer. dissemin littered ll diflricts: twin ICSOUrCe have no “as that the qUQS NCLB} Prot‘icie This m2 rake- _ .- b q undCTSt intermediate school districts, and professional education organizations, workshops, publications, and listservs. There is certainly no shortage of information on NCLB. In addition, as states are held responsible for performance of local school districts, and also provide technical assistance to schools and districts in need of improvement, Local Educational Agencies (LEAs) usually do not have to look far to get answers about NCLB’s requirements. In the study districts, multiple binders fiom the Michigan Department of Education about NCLB, stuffed with PowerPoints, technical assistance documents, and resource pages filled central office administrators’ shelves. Publications disseminated by national and state departments of education, too numerous to mention, littered their desks. In addition, private publishers hawk publications and resource kits to districts: one such publication, No Child Lefl Behind Compliance Insider, was found deep within the files of one curriculum director. With the plethora of information and resources available, if information alone was enough, it appeared that districts would have no difficulty meeting mandated requirements. However, the other side of the coin was that the volume of information appeared more than a little overwhelming, begging the question of how well anyone could assimilate, let alone implement successfully, NCLB’s requirements. Given the ambitious goal of having 100% of students meeting proficiency standards by 2014, information alone cannot lead to successful outcomes. This makes the study of districts’ responses to NCLB important and interesting work. Questions Regarding K-12 Districts ’ Response to NCLB As reflected in the exploratory questions, the scope and complexity of NCLB raises questions about districts’ responses. The first layer is whether districts fully understand NCLB, both in the spirit and letter of its many requirements and technical 69 details. l requiren: \ll’lfll dl>I I commur. The inter RSBSCL‘V from pin that 1 [It | frequen'. is more i Entitled noon Smdem 111163m of COllecM C0millet Pl ) 0r. mi‘ludc. details. How do they come to understand it, and what is involved in assessing the requirements? Beyond districts’ understanding of the requirements, I wanted to learn what districts actually do in response, from assignment of responsibilities, communication, and challenges experienced relative to implementation and monitoring. The interview protocol was designed to elicit this information, with review of documents as a secondary source of data. Research Evidence on the National Impact of NCLB The goals of NCLB are unabashedly ambitious, solidifying a shifi in purpose from providing educational opportunities to youth, to requiring districts to demonstrate that 100% of its students to reach proficiency standards by 2013-14. There have been frequent reports touting the positive outcomes of NCLB in the popular media; however, it is more important to examine research findings to judge NCLB’s effectiveness. The Center on Educational Policy (CEP) has published several articles in a series entitled, “From the Capital to the Classroom: Year 5 of the No Child Left Behind Act” (2007). The cornerstone report, “Answering the Question That Matters Most: Has Student Achievement Increased Since No Child Left Behind?” addresses the central intent of NCLB (CEP, 2007). A panel of five educational testing and policy specialists collected data from every state, noting “not every state had enough consistent data to do a complete analysis of test score trends in reading and math before and after 2002” (2007, p.1) Only 13 of 50 states had sufficient data for complete analysis. Main conclusions included the following: 1. In most states with three or more years of comparable test data, student achievement in reading and math has gone up since 2002, the year NCLB was enacted. 70 Addunn Oi state ‘. fickety s Probleni lP-73), NCLB; Scboo]: Rennie? a“Clings: aflennr School \I 2. There is more evidence of achievement gaps between groups of students narrowing since 2002 than of gaps widening. Still, the magnitude of gaps is often substantial. 3. In 9 of the 13 states with sufficient data to determine pre- and post- NCLB trends, average yearly gains in test scores were greater after NCLB took effect than before. 4. It is very difficult, if not impossible, to determine the extent to which these trends in test results have occurred because of NCLB. Since 2002, states, districts, and schools have simultaneously implemented many different but interconnected policies to raise achievement. 5. Although NCLB emphasizes public reporting of state test data, the data necessary to reach definitive conclusions about achievement were sometimes hard to find or unavailable, or had holes or discrepancies. More attention should be given to issues of the quality and transparency of state test data. (CEP, 2007, p. 1) Additional findings noted that while NCLB initiated “massive changes in and expansion of state testing programs . . .the house of data on which NCLB is built is at times a rickety structure,” attributed in part to “overburdened state departments of education,” problems with testing contractors, and “continual corrections and revisions in test results” (p. 73). Significant improvements in data collection and analysis were recommended. In addition to these findings, other CEP reports elaborate firrther results on NCLB’s impact related to curriculum, instruction, assessment, teacher qualifications, school restructuring, and funding. In the area of curriculum and instruction, Jennings and Rentner reported schools “are paying much more attention to the alignment of curriculum and instruction and are analyzing test score data much more closely,” with particular attention to achievement gaps and the needs of under-achieving subgroups (2006, p. 2). CEP reported survey results from a nationally representative sample of 349 responding school districts, paired with district and school personnel interviews in 13 school districts, revealed several key findings (2007). Instructional time in tested subjects increased significantly in 62% of the responding districts since 2002, with 44% of the districts 71 decrea notable assessr cans. direct i recomr urge n; funds It into 5m are unir hat 6 ha 011 lCQCl dnnbu schools" “ith Di 0 >4) '1! “VJ ,. ' I Sungfm The} cg decreasing time in other subjects to accommodate this shift. This was particularly notable in districts that had schools identified for improvement. In the area of assessment, Jennings and Rentner wryly noted, “Students are taking a lot more tests” (2006, p. 2). In addition to increased emphasis on tested content, districts are increasing direct instruction of tested skills (CEP, 2007). These findings gave rise to recommendations to “stagger requirements to include tests in other academic subjects,” to urge states to give adequate focus to art and music, and to provide states with research funds to determine how to incorporate content area reading and math skills instruction into social studies and science (CEP, 2007, p. 2). Data on outcomes in response to the NCLB highly qualified teacher requirements are unimpressive. A CEP study found “NCLB highly qualified teacher requirements have had minimal or no impact on student achievement and have not had a major impact on teacher effectiveness” with only five states reporting some effectiveness in equitable distribution of experienced, highly qualified teachers among higher and lower poverty schools” (2007, p.3-4). Particular concerns were raised about obtaining enough highly qualified teachers to work with students with disabilities. The concerns for achievement of students with disabilities were also addressed in a roundtable discussion held by CEP on “NCLB’s Accountability Provisions for Students with Disabilities” (May 1, 2007), identifying districts’ struggles under NCLB in the areas of curriculum, teacher preparation, and assessment for students with disabilities. A group of 25 participating organizations voiced concerns about special education students, as a subgroup, shouldering the blame for schools and districts’ failure to make AYP (p. 3). They called for improvements in alternate assessments, differentiated accountability 72 mechani, improve: disabled 355655111 c state car that ha\ i. alloxtin: perfom IESL'UCIt States. til despite l 513193 IL’ anDual t. 15 513k. Educat"; mechanisms for schools failing to make AYP due to disability subgroup scores, improvements in teacher preparation programs to build teacher capacity for working with disabled students, and a “major research agenda” to fund research on curricula and assessment to better meet the needs of disabled students (pp. 6-7). Finally, the literature on NCLB and its national impact also raises concerns about state capacity to implement NCLB and assist low—performing districts. While schools that have not made AYP for five consecutive years are required to undergo restructuring, allowing for state assistance and even state takeover, Jennings and Rentner note, “Low- performing schools are undergoing makeovers rather than the most radical kinds of restructuring. . . . Very few of these restructured schools have been taken over by the states, dissolved, or made into charter schools” (2006, p. 2). They firrther stated that despite NCLB’s requirements, which expanded states’ roles in school functions, 36 of 50 states reported they “lacked sufficient staff to implement [the] requirements” (p. 3). An annual CEP survey of 50 states, conducted in 2006, along with data from interviews with 15 state officials from 11 states, identified four significant challenges for State Educational Agencies in implementing NCLB: (1) limitations in staffing and infrastructure; (2) inadequate federal funding; (3) lack of guidance and technical support from the US. Department of Education; and (4) barriers in NCLB and within state education agencies. A list of recommendations for NCLB’s reauthorization included grants for states to building leadership capacity for school improvement, additional federal funding, and improved technical assistance from the federal level to states. 73 As .‘vlic restruct of \Cl on scho inten'ie in four : lCQCIICI': sutlicie: Research Evidence on Michigan’s Responses to NCLB CEP conducted research in Michigan from August 2006 through January 2007. As Michigan has an accountability system that predates NCLB, our state had schools in restructuring sooner than other states, providing a unique opportunity to study the impact of NCLB’s accountability requirements. It also provided a sequel to other CEP reports on school restructuring in Michigan (CEP 2004; 2005). Research methodology included interviews with state administrators, review of restructuring documents, and case studies in four school districts, including interviews with district administrators, principals, and teachers. Findings revealed two-thirds of the restructured schools improved achievement sufficiently to meet AYP targets. The study also found Due to population loss and a declining tax base, the state of Michigan faced budget shortfalls for 2006-07. . . . All case study districts felt the effects of Michigan’s dwindling funds. All also suffered from declining enrollments, and, thus, from additional declines in revenue. The resulting financial pressures were as important as restructuring in influencing reforms, and at times limited the choices schools and districts could make about how to increase student achievement (CEP, 2007, pp. 23). Grants were used to help produce change in some districts. Furthermore, the study showed that few schools restructured by replacing principals, or using the “any-other” option provided through NCLB to create changes in school governance in to support reform. This reflected a shift over time, from a high of 94% of schools in restructuring using the “any-other” option in 2004-05, to only 23% choosing this option in 2005-06. Instead, many more schools chose to employ “turn- around specialists” to assist with restructuring. Overall, the study concluded all districts used multiple strategies to improve achievement beyond formal restructuring, including 74 __ fir! 1 9i r v’ u; '.-“ data-dr mahng Canul. Educat Monito Michig Central Pé‘CI' rei coherer "Clearl: 0\ er a S sense 0: ’eaurht Secret. recOmr NCLB. Wurst _| data-driven decision making, increased professional collaboration, and shared decision making at schools, rather than principals acting alone. In a discussion with other state school improvement officials, Yvonne Caamal- Canul, then the Director of School Improvement for the Michigan Department of Education, shared Michigan’s efforts to assist schools in implementing NCLB (Title I Monitor Roundtable, 2007), prior to her retirement from this position. She described Michigan’s partnership with AdvancEd, the new parent organization for NCA (the North Central Association Commission on Accreditation and School Improvement), to conduct peer reviews and audits of schools in Phase 6. She explained MDE has tried to develop a coherent approach in working with high-priority schools based on research, stating, “Clearly, we don’t have the resources to do the work that we need to do, including taking over a school district, and yet we have schools that are going into Phase 8, and there is a sense of urgency about what’s the right thing to do with schools that continue not to make adequate yearly progress” (Title I Monitor Roundtable, 2007, p. 10). She noted Michigan proposed a partnership with Microsoft Partners in Learning to implement a statewide leadership framework to build leadership capacity in high—priority schools. Status of Scheduled 2007 Reauthorization of NCLB As outlined in the previous section, suggestions abound for NCLB’s reauthorization, scheduled for 2007. A US. Department of Education report authored by Secretary of Education Margaret Spellings (2007) provides a summary of policy recommendations for NCLB reauthorization. The report states the intent to “build on NCLB’s results” through increased efforts to close the achievement gap, “more rigorous coursewor ” at the secondary level, greater flexibility and tools for states “to restructure 75 chronic. from M is cons; policy t 1' eport t from th- media chronically underperforming schools,” and more options for families, “without straying from NCLB’s core principles” (p. 4). The US. Department of Education NCLB website is conspicuously absent of specifics on the reauthorization timeline. In the meantime, policy talk continues to mount. The Center on Education Policy released a six page report on August 28, 2007, regarding recommendations for reauthorization, emanating from the various studies they’ve conducted since NCLB was first enacted. The news media, professional organizations and their lobbyists, and civil rights and special interest groups have predictably joined the fray. As a member of the Association for Supervision and Curriculum Development (ASCD), I received a “Legislative Action Alert” in an ASCD e-mail on September 11, 2007. This contained information about the NCLB “discussion drafi” posted by the US. House of Representatives Committee on Education and Labor the previous week, and ASCD comments regarding the draft document provided to the Committee. It notes positive changes in the draft, including “more flexibility and opportunities for schools to improve, and for states to assist schools in this endeavor. . . . a variety of approaches to address challenges, measure achievement, and develop assessment systems more broadly than the current law” (ASCD, 2007, p. 1). However, it raises concerns about the specter of increased recordkeeping requirements, as well as the need for resources, noting Extensive reporting and record keeping under NCLB require many districts to use precious resources (both financial and human) to demonstrate compliance. This discussion draft appears to continue this trend. . . . [We propose] a measure providing commensurate reduction in the requirements of this legislation if authorization levels are not met. Including such a provision would be good policy and demonstrate to educators that the Congress is ready to be an active partner in education and making this legislation wor ” (ASCD, 2007, p. l). 76 'r-i ‘ffl' “i reaud enab unng achh: legis depa hnph pend fiend The comments continue with a restatement of ASCD’s recommendations for reauthorization. Summary The 2002 enactment of NCLB solidified a federal educational policy shift in establishing the federal government as the chief policy maker in the educational system, using assessments and accountability measures as policy tools for increasing student achievement according to proficiency standards. It is a comprehensive, detailed piece of legislation administered by the US. Department of Education, channeled through state departments of education, and contains significant requirements for local district implementation. The body of research evidence that has accumulated over a five year period demonstrates varying outcomes. Conclusions regarding student achievement trends have been hampered by inconsistencies and flaws in state assessment data; although there appears to be some encouraging evidence of increased achievement, enough concerns have resounded about methodological issues to cause significant caution in interpreting results. In addition, it is clear that states have struggled with capacity issues in implementing NCLB requirements. Issues of inadequate assistance at the federal and state levels, quandaries of how to help restructuring schools, and a lack of firnds have dogged effective response to its requirements. The research evidence reviewed here has provided the “big picture” of the impact of NCLB, particularly at the national and state levels. CEP studies have reported on district implementation and restructuring issues. A narrower, in-depth focus on district- level responses, as utilized in this study, will contribute to the discourse on the impact of NCLB by describing and explaining how districts have responded to its requirements. 77 7:] rm Gilli: H ur edut pare iron COm him I 5.1: Ct. at This study takes a five year view of districts’ responses; further study will be needed to examine the impact of the legislation on districts’ responses in the next five to ten years. Michigan Compiled Laws (MCL) Public Acts 165 and 166 In 2004, the Michigan Legislature enacted Public Acts 165 and 166, intended to effect changes and consolidate requirements in Michigan Compiled Laws regarding Human Immunodeficiency Virus (HIV)/Sexually Transmitted Diseases (STDs) and sex education. Prior to passage of PA 165 and 166, the laws were not nearly as specific about parent and community input and sexuality education content. A groundswell of concerns from community health advocates and parents prompted legislation pertaining to composition of Sex Education Advisory Boards, and expanded their role to include formation of sex education goals and objectives, and program evaluation and mandatory reporting to parents. PA 165 and 166 also outlined a complaint process for parents concerned about possible program violations. In addition, for districts electing to offer sex education, the new legislation added required content and topics, and specified new standards for instruction. Michigan Compiled Laws (MCL) Aflected by PA 165 and 166 Several laws in Michigan’s School Code (SC) and Michigan’s State Aid Act (SAA) were included in PA 165 and 166. These included the following: I MCL 380.1169 (SC): amended June 2004, focuses on HIV and other “dangerous communicable diseases” (MDE, 2003), teacher training, materials, curricula, and abstinence education. 78 MCL 380.1506 (SC): last amended November 1977, focuses on reproductive health instruction, supervision, and student participation. MCL 380.1507(SC): amended June 2004, focuses on sex education, teachers, facilities, and equipment; emphasis on abstinence; parent notification; sex education advisory board; prohibitions against distribution of contraception. MCL 380.1507a (SC): added July 1996, focuses on notification of student excuse from class and enrollment in classes. MCL 380.1507b (SC): amended June 2004, focuses on sex education and instruction, along with curriculum requirements. MCL 388.1766 (SAA): amended July 1996, focuses on financial penalty to districts dispensing or distributing contraception or making referrals for abortion. MCL 388. 1766a (SAA): added June 2004, involves reproductive health or sex education and the parent complaint process. Overview of Michigan ’s Sex Education Laws under PA 165 and 166 It is critical to note all Michigan schools are required to teach about “dangerous communicable diseases” (MDE, 2003), including HIV/AIDS and other sexually transmitted diseases. The law requires this instruction must include the primary modes of transmission for such diseases and effective prevention methods. It also mandates sharing information about abstinence as the most reliable method for restricting and preventing STDs, and as a positive lifestyle choice for unmarried individuals. Beyond HI V/S T D Instruction Aside from HIV/STDs instruction, Michigan’s School Code allows local school boards to determine whether sex education will be taught in its schools, including 79 dech abstii sexu; inclu EMU: mam instn nuo; inclt With fnsu local EdU{ Proxfi Chah— decisions about whether instruction is “abstinence-only” (promoting instruction of abstinence as the only completely reliable method of avoiding negative consequences of sexual activity), or “abstinence-based” (which in addition to abstinence education, also includes ways to reduce risks of pregnancy and HIV/STDs). Overall, if a local school board adopts a policy requiring sex education in its schools, Michigan legislation mandates the content must include abstinence education. Further, curriculum and instruction must meet the following criteria: 1) age-appropriate content; 2) medically accurate content; 3) behavioral risk reduction strategies; and 4) content incorporating the “A to K” requirements (summarized in the next section). When a local school board opts to include sex education in its schools, this sets into motion a host of legislative requirements with which the district must comply, including appointment of a Sex Education Advisory Board. The School Board is tasked with approving advisory board members, terms of service, and a selection process to ensure members reflect the district’s population. By law, half the members must be parents of students enrolled in the district’s schools, and must include students, educators, local clergy, and community health professionals. The School Board selects a Sex Education Supervisor (approved by the Michigan Department of Education) who provides oversight for the district’s sex education program, and must also appoint two co- chairs, including at least one parent of a student in the district. Districts that teach sex education are strongly encouraged by the Michigan Department of Education to adopt a definition of sex education. The purpose of the definition is to set parameters for the content and materials considered to be “sex education,” thereby specifying curricula required to go through an approval process via 80 fit If no ui conlet its Sex Education Advisory Board. The Sex Education Advisory Board establishes sex education program goals and objectives, reviews and recommends curricula and instructional methods, evaluates achievement of program goals and objectives, and reports program results to district parents at least biannually. In addition, for both HIV/STDs and sex education, the law requires the district notify parents in advance of instructional content, their right to review instructional materials and observe instruction, and their right to excuse their child from instruction without penalty. Michigan legislation further outlines a complaint process and protocols, beginning with presenting complaints to the local district, and subsequent complaints to the intermediate school district and state if the complaint is not resolved at the local level. If districts fail to take corrective action to resolve violations of certain segments of the law (i.e. regarding the HIV/STDs mandate, advisory board requirements, public hearings and board approval, or parent notification), a financial penalty may be assessed to the district. Further, Michigan Compiled Laws specify significant consequences for distribution of contraceptives or referral for abortion, stating, “A district in which a school official, member of a board, or other person . . . dispenses or otherwise distributes a family planning drug or device in a public school . . . or makes a referral for abortion shall forfeit 5% of its state aid appropriation” (MCL 380.1506, 380.1507, 380.1507b, and 388.1766). Required “A to K” Curriculum for Districts Opting to Teach Sex Education For districts with sex education programs, Michigan law spells out required content and topics for instruction, informally referred to as the “A to K requirements.” 81 I‘r an lit b0 ins unl and Viol These include: a) the benefits of abstinence; b) discussion of the emotional, economic, and legal consequences of sex; c) possibility of unplanned pregnancy and STDs resulting from sexual activity; d) laws pertaining to students’ responsibility as parents to children born in and out of wedlock; e) ensuring instruction upholds laws pertaining to sexual activity; f) discussion of the consensual basis for sexual activity, and that it is wrong to coerce or harass others into sexual activity in any way; g) teaching students refusal skills to avoid engaging in risky behavior; h) teaching students they have the power to control personal behavior based on ethical reasoning, responsibility, and self-control; i) instruction on healthy dating relationships, limit-setting, and recognizing risk factors in unhealthy relationships; j) adoption and laws regarding the safe delivery of newborns; and k) laws prohibiting sex with individuals under the age of 16 and consequences for violating these laws. Teacher Qualifications for HIV/STDs Instruction and Sex Education Between 1977 and 1996, state legislation required sex education teachers to meet qualifications for teaching health, which meant teachers had to complete a twenty hour training program. In 1996, MDE erroneously gave local districts the right to determine teacher qualifications to teach sex education. In 2006, local districts were notified that the Michigan legislature enacted formal requirements for sex education teachers. Under this new mandate, teachers certified to teach all subjects, K-8, are qualified to teach sex education. Teachers with secondary certificates must possess a health endorsement, including the MA (health), MX (health, physical education, recreation and dance combined), or KH (family and consumer science). Secondary science teachers who do not have a health endorsement may only teach those sex education components 82 atir: nin‘. u ic‘ en i I) it“ \' .-\ tllt l up the n l I St St It‘\ at relating to secondary science standards and benchmarks. MDE also recommends a minimum of six hours of professional development for sex education teachers every five years. The qualifications for sex education teachers are more stringent than for teachers providing HIV/AIDS instruction. Any certified teacher who has successfully completed inservice training through regional School Health Coordinators, as approved by MDE, may teach HIV/AIDS content. Licensed health care professionals with training in HIV/AIDS are also permitted to provide this instruction. State Board of Education Policy to Promote Health and Prevent Disease and Pregnancy In addition to PA 165 and 166, the State Board of Education recommends that local school boards support their school administrators and faculty to select, adopt, and implement comprehensive sexuality education programs that are based on sound science and proven principles of instruction. . . . [to help] schools accomplish the teaching and learning goals of the federal No Child Left Behind Act of 2001 and of Michigan’s Education Yesl—A Yardstick for Excellent Schools” (State Board of Education policy adopted 9-25-03). Six “principles and recommendations” for local school board policies are included in the state policy: I Sexuality education programs should reflect “school and community standards and support positive parent/child communication and guidance.” The State Board recommends districts survey parents and community members to determine beliefs about sexuality education, topics for instruction and ages at which instruction should begin; 83 Substantive discussion of sexuality education programs should be ongoing in local districts, including planning for education to address the needs of diverse students, based on medically accurate, current information; It is important to use multiple data sources about student needs, knowledge and behavior to design instruction that will meet prevention needs of diverse students; Effective sexuality education is a part of coordinated school health programs, initiated before students may be drawn into risky behaviors and reinforced frequently; Effective sexuality instruction is provided by staff who demonstrate good content knowledge and skill, bolstered by ongoing professional development; Sexuality program materials and methods should be documented and revised periodically based on evaluation results, student and parent feedback, teacher input, and new information. Local advisory boards are advised to meet as least twice per year to engage in planning, program revision and evaluation. Channels of Communication and Technical Assistance Channels of communication regarding PA 165 and 166 are established through multiple state agencies, including the Department of Community Health, the Department of Education, and the Department of Human Services. In addition, the Michigan Model for Comprehensive School Health Education State Steering Committee actively networks with many voluntary and professional groups to inform health education practices in the State of Michigan, including sex education (Central Michigan University Educational Materials Center, 2007). This information is communicated to schools through intermediate school districts, MDE listservs and workshops, and numerous websites with 84 links to Michigan legislation and the School Code, Michigan Health Content Education Standards, research on best practice in sexuality education, Michigan Youth Risk Behavior Survey data, etc. In addition, technical assistance is available through Intermediate School District and MDE consultants, as well as private agencies and consultants who contract with MDE, such as Parent Action for Healthy Kids, as described by Ms. Barb F lis, founder and consultant (personal communication, 2006). Consultants provide information on legislative requirements, conducting parent and community surveys, assessing curriculum and instruction within local districts, and working with the School Board and local Sex Education Advisory Boards. Questions Regarding K-12 Districts’ Response to PA 1 65-1 66 PA 165-166 was passed approximately three years ago. Thus, it raises questions about how districts have responded to it, given its relatively short “lifespan.” Focused as it is on one specialized area of curriculum and instruction, an area that some educators may regard as less central to the core purposes of schooling, it provides an opportunity to study district compliance and fidelity with its requirements. The specifics of the legislation are also rather prescriptive in terms of the “A to K” requirements, detailing what may and may not be taught. In addition, while there is survey research on student risk behaviors (Michigan’s Youth Risk Behavior Survey, 2005), I found no research studies on the implementation outcomes of PA 165-166. Evidence appears to be scarce and anecdotal. As part of this study, the focus on district-level responses to PA 165-166 affords an intriguing 85 Ol‘l“ just reqt \\ (18 p01 i COIT the : SIUL prof Ellie Cl] 01 opportunity to explore district implementation. It also provides an interesting means to juxtapose district responses to two very different legislative policy mandates. Summary of Legislative Mandates NCLB and PA 165-166 provide the opportunity to study district responses to educational policy mandates enacted at the federal and state levels. While both pieces of legislation assert standards for curriculum and instruction, thus restricting control by Local Educational Agencies (LEAs) and school boards, they differ in scope, reporting requirements, consequences for noncompliance, and time elapsed since the legislation was first enacted, thus offering the means to juxtapose district responses to the two policies. No Child Left Behind, as a federal policy, is a much broader, more comprehensive policy than PA 165-166. Not only does it affect all states, it also covers the traditional content areas of English Language Arts, Mathematics, Science, and Social Studies, incorporating accountability standards for schools to ensure they meet proficiency targets for all students by the 2013-2014 school year. PA 165-166 only affects mandated instruction of HIV/STDs, and sets content requirements if districts choose to teach sex education. In addition, the reporting requirements under NCLB are more demanding, including mandated reports on highly qualified requirements, standardized testing, professional development, federal grant budgeting and expenditures, etc. Furthermore, reports under NCLB are heavily monitored at the federal and state levels. In contrast, PA 165-166 only requires districts to submit the names of their sex education supervisors, while mandating approval of the sex education advisory board and district curricula by 86 01'. ill: Ht 001 Elm les local school boards. Monitoring at the state level is sketchy at best, through teachers’ online reports of Michigan Model lesson delivery. The only way the state would know if there were major violations of PA 165-166 is through the parent complaint process. Hence, accountability under PA 165-166 is much weaker than under NCLB. Both policies have consequences for noncompliance. The most widely known consequences for noncompliance with NCLB include loss of federal funding if grant money is mismanaged, as well as the consequences for schools and districts failing to make AYP, outlined in a previous section. The public reporting of school and district performance, including standardized test scores and school report cards, is another consequence, particularly for poorly performing schools. In comparison, while financial and legal consequences exist for districts that do not comply with PA 165-166, they are less widely known and recognized by educators and the general public. And unlike NCLB, PA 165-166 allows a district whose school board votes to “opt out” of sex education to avoid most compliance requirements and negative consequences altogether. Finally, the time elapsed since passage of the policies differs, as well. Since it was enacted in 2002, districts have had five years to respond to NCLB. PA 165-166 is less than three years old, affording districts significantly less time to respond. In addition, more evidence is available on the impact of NCLB on LEAs. As it is scheduled for reauthorization in 2007, with expected revisions partially based on outcomes and response, a more complete analysis is possible, along the lines of a five year status review. It is anticipated that response to NCLB will be studied extensively at the five year mark, ten year mark, and so on. Hence, the story of districts’ responses to NCLB is far from finished, and will continue with subsequent reauthorizations and evolving 87 natio distri its in H1016 distri illust: based mam. national, state, and local events. On a smaller scale, it is also reasonable to assume districts’ responses to PA 165-166 will continue to evolve, though it is likely that study of its impact may be hampered by lack of funding, seemingly dwelling in the shadows of more comprehensive, heavy-hitting federal and state educational policies. Thus, the contrasts in the two policies provide a unique opportunity to study districts’ responses to federal and state legislative mandates. Chapter IV presents data illustrating the response of two districts to these policies. Chapter V offers an evidence- based model to describe and explain how districts respond to different legislative policy mandates. 88 to p0 prese well schot ill\ at iden: distr; CODc 01‘ BL; Con! CHAPTER IV PRESENTATION AND ANALYSIS OF THE DATA Introduction The purpose of this study is to describe and explain the response by K-12 districts to policy mandates introduced through federal and state legislation. In this chapter, I present and analyze data from multiple sources to demonstrate study districts’ responses. The primary source of data was semi-structured interviews with district administrators, as well as representatives from the Michigan Department of Education and intermediate school district administrators and consultants. The interview respondents were almost invariably willing, and even eager, to share their perceptions of districts’ responses to identified legislation. A secondary source of data was documents supplied by the study districts, though this information was notably more difficult to obtain. The organization of this chapter includes seven sections. The first section summarizes the conceptual framework guiding the research process and procedures. The conceptual framework, and data corresponding to its major components is used to organize the next several sections of the chapter. Information related to the External Context, or legislative mandates, was presented in Chapter 111. Thus, in the second section, data from External Partners (information from representatives of MDE and two ISDs) are described and analyzed. The third section presents descriptions of the pilot and case study settings. Data from each K-12 setting, the last component of the conceptual framework, are presented in the fourth section (the pilot study in F airview Community Schools) and fifth section (the case study in Steele Public Schools). Following these 89 lli within-case analyses, data from the pilot and case studies are compared in the sixth section, including an analysis of findings. The seventh and final section of the chapter is a summary of patterns and themes presented through the data. Conceptual Framework and Research Procedures The study was designed to describe and explain the response by K-12 districts to policy mandates introduced through federal and state legislation. Specifically, I sought to gather information related to the following exploratory questions: 1. How do K-12 administrators learn about and assess mandate requirements? 2. How do K—l2 administrators respond to mandates and monitor district implementation? 3. What administrative challenges are created by these mandates? What conflicts do they pose for districts? The plan for study was informed through development of a preliminary conceptual framework, identifying key components of settings, actors, and processes for data collection and analysis. Conceptual Framework As described in Chapter II on methodology, the preliminary conceptual framework (Appendix A) contains the External Context (N CLB and PA 165-166), External Partners (i.e., Michigan Department of Education and Intermediate School District administrators and consultants), and the K-12 District. The theory underlying the framework was that legislative mandates are “passed down from above,” either starting at the federal level and channeled through State Educational Agencies (SEAS) to Intermediate School Districts (ISDs) and Local Educational Agencies (LEAs), or originating at the state level and then channeled to ISDs and LEAs. 90 predt. implc \‘arief Spt’L‘l. exist; reliur' USeli ext? In this study, I sought to discover whether the K-12 District would exhibit predictable structural and functional responses as administrators learned about, assessed, implemented, and monitored implementation of the legislative mandates, leading to a variety of consequences for the District. Predicted structural responses included specialization of roles and departments to respond to mandates, added responsibilities to existing positions, diffusion of responsibilities across multiple positions, and increased reliance on External Partners. Predicted functional responses included institutionalization of practices to support mandate implementation through increased bureaucratic rules and regulations; increased monitoring of the task environment, or External Context, to stay abreast of requirements and changes; decisions about how tightly to couple district response to mandate requirements; and changes in communication content and patterns relative to the mandates. Predicted consequences for the K-12 District included decreased local control, increased external coalitions, changes in organizational performance, and increased administrative turnover. Research Procedures A two-phase research process was implemented, beginning with a pilot study in the Fairview Community Schools, where I am employed as Curricultun Director. The pilot study lasted approximately one month, with interviews and document collection taking place between late March and late April, 2007. Overall, the interview protocol questions and documents yielded interesting and useful data, requiring little modification in methodology for the case study. The exception was the focus group session. A focus group with four principals was conducted in F airview; however, this did not result in the kind of meaningful detail 91 mo in: lllll needed to describe and explain district responses, so a decision was made to interview two principals individually in both the pilot and case study districts, in lieu of conducting a focus group in the case study district. Afier conclusion and analysis of the pilot study, the Institutional Review Board at Michigan State University granted approval to extend the study to conduct a case study in Steele Public Schools. The district was selected based on a number of factors. It was different enough from the pilot district to explore potential disparities in responses due to its unique features, and yet not so dissimilar that it might prevent emergence of meaningful patterns across the two districts. It was also known to be a district receptive to MSU researchers, with a previous, collegial relationship established between its superintendent and my advisor. Finally, its relative proximity to my district allowed me to continue working, while taking time off to conduct fieldwork. A summary of interviews follows this section. Once permission was obtained from Steele’s Superintendent, I worked with his administrative assistant to identify central office and building administrators responsible for responding to NCLB and PA 165-166. While the Superintendent had agreed to contact likely administrators to inform them of my study and his approval, thus sanctioning district participation, this communication did not appear to have taken place. When I contacted administrators via e-mail and phone calls, they were unaware of the study or the Superintendent’s recommendation that I contact them. However, most administrators responded very willingly to my request for an interview. The exception was the Testing Coordinator; despite e-mails, phone calls, and assurance I would meet With her at her convenience, she refirsed all overtures. A decision was made to arrange 92 for an interview with an administrator with like responsibilities in a similar district (Harmony Public Schools), which ended up being my final interview. Interviews began in late June of 2007; due to summer vacation schedules, the last interviews took place in early September, 2007. Following the pilot study and initial interviews in Steele, patterns emerged in the responses I received, resulting in tentative changes to the conceptual framework, which helped to shape subsequent interviews. Common threads began to weave into recognizable patterns, which I was then able to articulate to interviewees, asking for their thoughts in response. This allowed for fruitful dialog through which I was able to confirm, disconfirrn, or alter my emerging model to describe and explain districts’ responses to NCLB and PA 165-166. Thus, the evolving dialectic across interviews helped to inform both process and findings. External Partners Michigan Department of Education The Michigan Department of Education (MDE) plays two different roles within the context of this study. As a state agency subject to the federal No Child Left Behind Act, it gathers pertinent information, assesses and interprets it, and implements at the state level, developing state rules and regulations that are passed down to Intermediate School Districts and local districts. In doing so, representatives from various offices at MDE partner with ISDs and local districts to provide assistance in responding to NCLB 93 Table 1. Persons interviewed at each site, by title and length of service in the position. Pilot Study Site: Fairview Community Schools *Name/Position *All names are pseudonyms to protect respondents’ confidentialigl. Length of Service in Position and Other Administrative Experience Donald Cooper, Superintendent 3 years; 4 years previous experience as a superintendent and elementary principal in other districts Melissa Green, Director of Educational Services, Retired ~7 years (4 years + 1 year interim, + 3 years as a TOSA-Teacher On Special Assignment—no Curriculum Director during these years) Ronald Parsons, Director of Finance 1.5 years Kathleen Peckham, Director of Human Resources 4 years; 3 years experience in another district Connor Simon, High School Associate Principal 1 year; 17 years of total experience as elementary principal in this and other districts Lily Barnes, Elementary Principal 1.5 years; previous 3.5 years of experience as MS associate principal [Focus Group Discussion of 4 Elementary Principals] Ranging from 8 months to 9 years Case Study Site: Steele Public Schools Douglas Edmonds, Superintendent 9 years; 6 years previous experience as MS principal Bob Hilliard, Deputy Superintendent for Finance 23 years Ruth Hughes, Assistant Superintendent for Student Achievement 5 years; previous experience at MDE Nila Taylor, Director of Special Services 4 years Maxine Higgins, NCLB Coordinator (administrative assistant to Assistant Superintendent of Academic Achievement) 4 years; previous experience as administrative assistant at MDE Testing Coordinator (*Refused interview; interview with a Testing Coordinator in a similar district substituted) Wanda Peasley, Director of Grants/Instructional Specialist 7 years Lucy Miller, Health & Human Services Coordinator (Sex Education Supervisor) 11 years Patricia Fitzwell, High School Principal 4 years; previous experience as HS principal and Curriculum Director in another district Sam Hanson, Elementary Principal New; 5 years previous experience as MS/HS assistant principal Additional Site for Supplemental Interview: Harmony Public Schools ‘Veronica Simmons, Curriculum Director and Testing Coordinator 5 years 94 Table l (cont’d.). Michigan Department of Education Administrators Laura Holt, NCLB Specialist 3 months; 10 years experience as assistant superintendent in a public school district Lisa Snyder, Office of Field Services Consultant 6 years Intermediate School District Administrators Connie Atwater, Assistant Superintendent for Instruction ~l year; 10 years previous experience as ISD Director of Special Education Willa Smith, Comprehensive School Health Regional Consultant 11 years; 11 years previous experience with her ISD as a Consultant and Michigan Model Trainer Summary Data Total number of interviews 20 Focus group participants 4 Total number of informants 24 requirements. As the administrative body responding to state education legislation, it develops and disseminates information on PA 165-166 requirements. MDE is responsible to the State Board of Education, comprised of eight elected Board members and a Superintendent appointed by the Board. The Superintendent consults with the Legislature on educational policy and funding, and is responsible for implementing bills approved by the Legislature, as well as policies adopted by the Board of Education. MDE has seventeen offices, some of which play central roles in educational policy implementation related to NCLB and PA 165-166, while others play peripheral, albeit supportive roles. The following information is not intended to be an exhaustive description of MDE’s purpose, functions, and relationships to other bodies, or the challenges and conflicts experienced within its departments. Rather, it outlines key information pertinent to understanding its role as an External Partner in this study. 95 lhl‘. Eda. MI; Sci“. CO'x SH: 30: im v—o- HI ,1 f — — _ — MDE ’3 Role and Functions MDE’s responsibilities relative to legislative policy mandates are carried out through roles and functions specialized by department (Michigan Department of Education, 2007). The Office of Administrative Law and Federal Relations coordinates with the US. Congress and federal agencies on federal legislation. It conducts administrative hearings and renders decisions. It falls under the general auspices of the School Finance and School Law Office, which in turn provides oversight and coordination related to “proposed state laws, current laws, the revised school code, the state school aid act. . . . the calculation and distribution of state school aid, school finance, pupil accounting, federal relations,” etc. (Michigan Department of Education, 2007). The Office of Special Education and Early Intervention Services oversees educational funding and programs for young children and students with disabilities. Three MDE offices that provide significant, direct assistance relative to implementation of NCLB include the Office of Educational Assessment and Accountability (OEAA), the Office of Professional Preparation Services (OPPS), and the Office of School Improvement (081). OEAA is subdivided into oversight for five programs: Michigan Educational Assessment Program (MEAP), Michigan Merit Exam (MME), Assessment of Students with Disabilities (MI-ACCESS), Assessment of English Language Learners (ELPA), Accreditation/Accountability (Education Yes and Annual Yearly Progress), and the National Assessment of Educational Progress (NAEP). All of these programs are designed to comply with NCLB assessment, accreditation, and accountability requirements. OPPS administers rules and regulations for professional preparation standards, highly qualified teacher requirements and ongoing professional 96 0F di development, all of which are addressed in NCLB. They also ensure school personnel “meet standards established by the Michigan Legislature and the State Board of Education” (Michigan Department of Education, 2007). In their role, they also advise districts on teacher certification and endorsement requirements for teaching sex education. Finally, as one of the largest offices at MDE, the Office of School Improvement is designed to “provide leadership and assistance at a state and local level to improve the academic achievement of Michigan schools and students.” It has three units. Curriculum and Instruction is responsible for development of Michigan standards and benchmarks, and also administers the federal Reading First program. The Field Services unit provides direct assistance to schools on school improvement, particularly for high priority schools, and coordinates twelve federal grant programs, including Title 1. Finally, the Academic Support unit assists Public School Academies, Migrant Education, and English Language Learner/Bilingual education programs. In summary, MDE holds significant responsibility for disseminating information on legislative policy mandates, as well as explaining and providing technical assistance to districts to support compliance and effective implementation. As the information from interviews with MDE representatives demonstrates, these are responsibilities they take seriously, even as they are challenged by significant capacity issues. Interviews with MDE Representatives Two MDE representatives were interviewed. Data obtained from their interviews revealed common themes as well as differences, perhaps because of their divergent assignments, responsibilities and length of service. As I had professional interactions 97 with bot during 1' Consult spent 16 school C based 0' not well SUpen'i: her unti. Who Shc She sat i the feds field sef office “ aSSiSIan. much le and uh:- "llé'ht t, people a to ldentil “mmum with both of them in the past, our familiarity may have contributed to open dialogue during the interviews. The first person I interviewed was Ms. Laura Holt, No Child Left Behind Consultant for MDE. While she had only worked for MDE for three months, she had spent ten years as an assistant superintendent for curriculum and instruction in a small school district in mid-Michigan. MDE hired her on a contract basis without an interview, based on her knowledge base and expertise. This was a new position for MDE that was not well-defined at the time of the interview. Interestingly, Laura reported that her supervisor was so preoccupied with his responsibilities that he was unable to meet with her until she’d been there for three days. She took the position without initially knowing who she’d report to, her hours, the location of her office, or her specific responsibilities. She sat in her office with “the thousand page manual that is well thumbed through from the feds regarding what is allowable and what is not.” She had some assistance from the field service consultant in her office, but not a great deal. A picture emerged of an MDE office where the human resources were stretched thin; the department was in need of assistance, and yet staff members were too busy to define department roles and needs, much less train and effectively use new personnel. When asked one particular question and whether she knew of this, she responded, “No, not from my cubicle. I mean there might be somebody else’s cubicle who [would say] oh, that’s important. . . . Right now, people are just . . . are scrambling to keep up.” She hadn’t been in the office long enough to identify reliable sources of support and information, acknowledging “that communication piece . . . is almost thought to be a luxury.” In Laura’s case, what was 98 panic dill‘cn Sen'lc for six fount r local d Ihroug lnl‘orm particularly interesting was what she’d learned as an MDE “insider,” a perspective that differed from her former role as a district administrator responding to NCLB. The second person interviewed was Ms. Lisa Snyder, a veteran Regional Field Services Consultant for the Office of School Improvement, having worked in the position for six years. Given her history in the department, predating NCLB’s passage, she was a fount of information. Her basic responsibilities include provision of direct assistance to local districts on Consolidated Grant Applications, approval of programs and funds through the various grants, and facilitation of regional workshops to disseminate information. She’d had enough experience at MDE to have a sense for the interplay between federal, state, and local agencies, as wells as how federal and state funds were allocated to various MDE departments and positions. Analysis of both interview transcripts revealed common patterns and themes, despite the difference in the respondents’ length of service and responsibilities. Information shared by Laura and Lisa fleshed out a picture of their work, which involved making meaning of NCLB at three levels: through the US. Department of Education as researchers, interpreters, and implementers of NCLB, getting the work of NCLB done at MDE, and working with local districts. In addition, they shared observations of districts’ responses to NCLB. Their work in each of these arenas likewise revealed some subthemes, connected in the next chapter with the larger picture of districts’ responses to NCLB. MDE representatives as NCLB researchers, interpreters, and implementers. Both Laura and Lisa described NCLB as an extremely complex legislative policy, requiring significant time and energy to learn about, interpret, and implement. Lisa had been with 99 MDE when NCLB was first passed. She recalls getting “work up copies before it was actually signed into law.” She attended national workshops on NCLB in general, as well as for programs for which she had direct responsibility. Early on, learning about NCLB took a great deal of time in the office with her colleagues. We pored over it and tried to figure out what was what. . . . We typically were in the office all together three days every two weeks. . . . [We would read] the law when it was initially passed out, and then as each guidance document comes out from the feds, we [would] read and discuss the guidance as an office, and we developed sort of cliff notes types of versions of the guidance that we can use for the districts for training, and also for things that we post on our website. And the cliff note documents are intended to simplify . . . in educational jargon rather than legal jargon. She describes this collaborative leaming time as significantly reduced at this point: “Not even a half day a month . . . because everything has become sort of routinized.” She and her colleagues sometimes are assigned responsibility for getting further information on a troublesome aspect of the legislation and then share the information. As a relatively latecomer, Laura felt as though she was on her own to learn NCLB’s intricacies and implications. When asked about professional development at the federal level, she stated, “I perceive that it’s done through notifications and meetings. I would say that from what I’ve heard, ‘inservice would be too strong of a word. . . . You know, it’s more, ‘This is it, are there any questions?”’ In addition, Laura described NCLB as “very vague.” Getting solid answers to clarify its requirements was not easy, either at the federal level or at MDE. Speaking of the Field Services unit and information she was seeking on Title I and consequences of a district’s failure to make AYP, she commented, “We are dying to get what new AYP [requirements are]. You know we’re just 100 yards away, but we can’t get information from [Field Services], not even preliminary information sometimes . . . because they’re 100 still \\ progr. docun certail explzu She \\ P01'll0] l'OU‘re comp] fiOfieg Persor Schoo] fie” a ”was this m; mVOhe feds," . still working [to understand] it.” For some pieces of the legislation, as with the Homeless program requirements, there are no guidance documents. Even with available documentation, Lisa indicated sometimes there is a lack of consensus on the meaning of certain NCLB language, so an MDE representative will call the USDOE to try and get an explanation. And sometimes they’ll say, ‘I really don’t know either, let me check with our lawyers,’ or maybe they’ll say, ‘I don’t know, but I saw something from another state, it seems like they’ve got that part of the law figured out.’ Because in the early parts of it . . . I think it’s safe to say that nobody has a clear view other than maybe the drafters of the law . . . . And then as guidance comes out, unfortunately it comes labeled ‘Drafi Guidance,’ because I think the federal government still wants to have some legal room to change what they meant or . . . . and it gets, I’m sure, a very politicized process in Washington, DC. about what . . . it means. She went on to say that sometimes, MDE staff would be sure they were implementing a portion of NCLB “really, really well,” and suddenly, “They’ll swoop in and say, ‘Nope, you’re not doing this part right.’ And so we’ll need to do a retraction and have a compliance plan for them on how we’re going to make a correction.” She also told stories of USDOE officials who would interpret NCLB in a manner congruent with personal values. For example, one auditor “used to be a head honcho within the private school-parochial school community, and so she came in . . . like a pit bull terrier . . . and even actually went at us for some things we were doing correctly, but her understanding . . . was to the benefit of private schools.” Lawyers were consulted and upheld MDE on this matter, “but it was her own personal agenda” that led to this conflict. Getting the work of NCLB done at MDE. It appears that state implementation involves many gray areas, leaving room for interpretation and possible “scolding by the feds.” The work of the department also reflects a surprising amount of discretion in 101 allocating resources to get the work done, collaboration to create meaning of NCLB requirements and communicate clearly to districts, and involves challenges of insufficient capacity to meet MDE and local districts’ needs. These patterns will be explored further in the school interviews. Both Laura and Lisa referred to cuts in the MDE budget over time, resulting in staff reductions. However, through reorganization and creative use of federal and state funds, MDE has tried to leverage the funds it has to get the work done the state leadership deems most important. Laura reported The Department of Education itself has - over 95% of our funding comes fi'om federal [funds with] administrative [expenses taken] off the top of federal funds, and so there’s a lot of things that we do . . . that really have no funding source. So if you keep all the federal funds congregated within a particular office, you can’t really use it for these overarching things. So what they needed to do is to make us part of a much bigger unit, that’s when the school improvement office came to be. And then they could start using our administrative funds for state initiatives. So it’s sort of a political thing. . . . As a state agency, we at some level have made a decision that some of those foundational things, like a model curriculum for the state, a school improvement template, all this stuff, is actually important for the meaningful and effective implementation of our federal categorical funds, and therefore [they] made the political decision to start finding some of those with federal fimds, whereas perhaps other states, I don’t know, have decided all their federal administrative funds go actually to administer the program, which is sort of what we ask districts to do. So it’s really the pot calling the kettle black here saying, ‘Well, we’re going to use our administrative funds to do all these other projects,’ but when we go to a district, we expect you’re spending your administrative funds to administer the program and nothing else. By organizing creatively, Lisa noted MDE “can pick up some people who otherwise would lose their jobs if they were state fiinded.” MDE has saved money “by not having central support,” and assigning more diverse responsibilities to staff members. In fact, Lisa feels “I’m trying to be a generalist,” while she sees that her actual expertise is 102 relatively narrow, which is assisting districts with implementation of federal grant programs. While Laura often felt fi'ustrated by a lack of communication and collaboration with her MDE colleagues, this may be a reflection of her short tenure in the department. Lisa described considerable collaboration with colleagues, notably intense in the early days of NCLB, and more “project-based” in recent times. Much of this work involves creating meaning of NCLB requirements and shaping how it will be communicated to districts. They’ll take typically one person from each of our regional groups — we’ll either volunteer or be assigned — and they’ll work on [a requirement] and then they’ll bring it to the larger group and say, ‘Here’s what we think, what do you think? Is this going to play in Peoria?’ And people will say, ‘Well wait!’— like the Detroit consultant will say, ‘Hold on a second, this is not going to work there,’ [but] the UP consultant will say yes, so we’ll try to come to some agreement that we think is going to be okay statewide, or at least shock people as little as possible. In addition, MDE Consultants also exercise discretion about how rigorously to enforce certain requirements. Lisa states [We think about] how far we think we can push this thing. . . . Some parts of the law . . . we can clearly see where enforcing this and really making a point of it is going to benefit kids, and some points of the law don’t seem to us like they make a whole lot of sense. And since we don’t have the energy to push everything with everybody, we’ll make a strategic decision, unless we get caught, and then have to move our priorities to something that we judge as educators to be less important. Examples of MDE using this type of discretion were shared; as Lisa commented, some things are “on the back burner,” and even when federal auditors are there, “They don’t even ask about them, so everybody’s in a ‘Don’t ask, don’t tell situation.”’ She was unsure whether federal officials “make a rationale choice” not to probe for certain information, or “if it’s a co-conspiracy between the states and the federal government not 103 to go there.” In summary, it appears there is some latitude, at least, for creating state level meaning of NCLB requirements. Ninety percent of the time, Lisa states “We’re going with letter of the law guidance.” When they “get caught” for not complying with requirements, “Then we change our tune, and then suddenly we have to enforce it, because we really have no choice at that point.” In addition, MDE consultants try to derive meaning for themselves in implementing all of NCLB’s rules and regulations. Both women verbalized beliefs about the importance of equitable opportunities for students to learn, building a sound curriculum, and providing quality instruction and services for children. Lisa observes, “I think people would not be able to work in our office without having some kind of a meltdown if they didn’t think there was some benefit to it.” Both also described common challenges related to insufficient staff resources and capacity to do all that needs to happen to improve education in Michigan schools. Laura noted, “The whole department is so decimated. . . . People are working really, really hard. . . . People’s jobs have been combined,” and in cases of staff departure, jobs are not replaced. She also reported that there are more staff members employed by Wayne Regional Educational Service Agency (an ISD) than in the entire MDE. Laura also elaborated on issues of poor communication and having to wade through bureaucratic channels. This was another surprise for her after she started her position. She noted somewhat incredulously that it takes a month or more to get an informational PowerPoint for use at a conference approved at the department. In the absence of information, ISDs and districts press to have their questions answered. Laura shared her embarrassment over getting called on the carpet by locals for not having 104 answers: “Well, it makes you look like an idiot. . . . [It’s as if they’re saying] ‘Why don’t you people get yourselves together?’ and you know, yeah, we wish so, too!” Working with local districts. The resource issue at MDE has also affected its work with local districts. The interview data revealed common patterns in MDE representatives’ work with constituent districts. Both expressed a commitment to providing quality consultation and assistance to districts. However, Laura reported field service representatives “mostly monitor for compliance. . . . You know, did you do your plan? Is this turned in? . . . They can’t also monitor for quality, so there are times when districts will pull things that were so surprising to me when I came.” As a district administrator, Laura stated, “We were in full compliance, and I didn’t realize there were times when we didn’t have to be!” She also expressed dismay about what this might mean for districts, and presumably, for student learning: “You would think that a district improvement plan should have continuous staff deve10pment, and they don’t check for that. . . . A piece of NCLB is quality professional development!” As Yvonne Caamal- Canul stated in the Title I Monitor Roundtable Discussion, “We trust what the districts say they’re going to do and we don’t have the capacity to follow up” (2007, p. 11). However, as Lisa shared, there were also instances of districts that were in an identified phase of improvement that apparently hadn’t even received notice or been contacted by MDE to offer technical assistance. It also appears that MDE relies on [SD supports when they can to shore up their own deficits in communication and technical assistance. Laura noted, “ISDs are really stepping up to the plate. The state is trying to use more ISD resources” to provide 105 assistance to local districts. She cited several examples of ISDs who specialize in district capacity building, school improvement, reproductive health, and early literacy initiatives. Observations of districts ’ responses to NCLB. Both MDE representatives reported a range of districts’ responses to NCLB requirements, and varying levels of compliance and commitment to implementation. In some cases, implementation in districts was inhibited by a lack of understanding of NCLB requirements. Lisa mentioned the difficulties for smaller districts that are more distant from regional MDE inservices. She also felt that the federal government has “unrealistic expectations of what districts should do . . . [to] be well-versed in the law and guidance.” Regarding districts’ uneven patterns of compliance, Laura reflected, “You only hear about the horror stories, just like you only hear about the bad kids.” She believed most districts “implement as it’s meant to be,” but commented on some regional differences: “You know, up north, especially in the Upper Peninsula, we hear, ‘This is bull----!’ And it’s hard to get people to comply.” In fact, she reported some districts fail to file their Consolidated Grant Applications, so they miss out on receiving a significant amount of grant funds. This shocked her, but she stated, “They’re just going, ‘We don’t want to do that [NCLB].’” Lisa also described substantive differences in districts’ responses to NCLB. I personally know of districts that are bending over backwards, are so nervous about any little change in their program, I’m like ‘Geez-oh-petes, you know, chill out, you’re doing a great job.’ Everything from that, like the super hyper compliant, I mean they actually read the stuff that comes from our office! Then . . . there’s the real blatant stuff. Even in my — I consider my area to be relatively easy to administer, at least compared to the Detroit Metro area, which has got incredible fires, because I’ve been pulled into some of those issues, and even within my area, people got caught on audits, had to give money — send checks back. One district who 106 will not be named had to just send that $200,000 check back to the government because they — it was like outright fraud. Some of her districts “get adversarial, like ‘just give me the money and don’t tell me—I know better than the federal government does about what I should be doing with this money.”’ Clearly, her “preferred” districts were the ones that “don’t have the resources [to implement], but they’re doing a pretty darn good job, because they’ve somehow managed to take the NCLB mandates and see that as furthering their own agenda as a district and where they want to grow anyway.” Finally, Lisa has the length of service to observe changes in district personnel over time, and the impact on implementation of federal programs under NCLB, including Title 1. Administrative turnover poses significant challenges in her role. She sees responsibility for state and federal programs shuffled around to various administrators “like the hot potato! . . . The lowest seniority person always sort of gets the crappy jobs that nobody else wants to do. . . . And sometimes it’s just personalities” or redistributing responsibilities. This inhibits good implementation, in Lisa’s opinion. She describes the public school academics in particular as having “no continuity in administration. . . So those are the black hole for technical assistance.” In addition, she notes that leadership responsibilities shifi because of individual career paths and administrative burnout: You can see in Central Administration what’s going on. . . . Boy, oh boy, it never used to be like this. . . . It used to be I would think a very gratifying job where you really felt like you were giving benefit. . . . It has a whole different feeling now. You got the board after you, you got the public after you, you got your teacher union after you, sometimes you got your colleagues after you. Holy Karnolians! I mean, I just don’t know how people manage to get up in the morning sometimes. In summary, interviews with both MDE representatives revealed common patterns and a few surprises. For one, there appeared to be a general lack of clarity on 107 various NCLB requirements, requiring an investment of time and energy to track down answers, but which also resulted in increased discretion in how to implement at the state level. Secondly, MDE leadership appears to have exercised significant discretion in allocating resources and organizing departments and positions, enabling them to address the work they find most critical. However, limited departmental capacity and the choices MDE made to allocate resources to other priorities also meant districts were monitored for basic compliance, rather than quality of implementation. And lastly, district responses to NCLB requirements MDE consultants observed from their unique vantage point, by necessity more of a “big picture” than an in-depth View, indicated considerable variations in districts’ compliance and commitment to both the letter and spirit of NCLB. Intermediate School Districts There are fifty-seven Intermediate School Districts (ISDs), also sometimes referred to as Regional Educational Service Agencies (RESAs) in Michigan (CEPI, 2005). Each ISD serves an identified group of Local Educational Agencies (LEAs), including public, charter, and non-profit schools. They receive firnds fiom a combination of local, state, and federal funds, and are required under the Michigan School Code to conduct regular assessments of constituent districts’ needs, to design programs and services aligned to needs, and to post a frnancial report detailing budget and expenditures on an annual basis (MDE, 2007). Each ISD is governed by a school board, whose members are selected by constituent districts, and its superintendent. ISDs ’ Roles and Functions According to a Michigan Association of Intermediate School Administrators (MAISA) publication, “ISDs were originally created to provide school districts with 108 programs and services too expensive or too extensive to be offered individually” (2001 , p. 12). ISDs pride themselves on offering “customized services” responsive to constituent districts’ needs; thus, programs and services offered by each may look somewhat different, depending on budget resources and local needs (MAISA, 2001). ISDs’ roles and functions tend to be specialized by department, program, and service offered. Departments are typically organized around programs and services in general education, career and technical education, Special education, administrative/support services, and technology services. Larger ISDs operate center- based schools for career and technical education, as well as special education. They also frequently form partnerships with business and governmental agencies, non-profit organizations, etc. ISDs have legal responsibilities outlined in the Michigan School Code, as summarized by MAISA (2001, Section V, pp. 14-21). However, they also have some latitude to design their programs to align to districts’ needs. In information posted to the one ISD’s website, the responsibilities of the Board and Superintendent in providing oversight for “quality educational services for learners throughout Ingham County” are outlined in detail (Ingham Intermediate School District, 2007). ISD departments providing programs and services in the areas of general and special education curriculum, instruction, and assessment, reproductive health, school improvement, and professional development, are most pertinent to this study. As ISDs are somewhat idiosyncratic in programs and services offered, a detailed explanation of ISDs’ organization and functions will not be included here. What is more important to understand is their responsibility for supporting constituent districts with varying needs 109 through dissemination of information, professional development, and technical assistance. They play a unique role in supporting district implementation of NCLB and PA 165-166. Interviews with ISD Representatives Two ISD representatives were interviewed for this study, coming from neighboring ISDs. Because their roles are different, limiting their responsibilities to either NCLB or PA 165-166, each interview will be treated separately, with a summary comparing and contrasting interview themes at the end of this section. Interview with an [SD Assistant Superintendent: ISD Responsibilities for NCLB Connie Atwater has been an ISD Assistant Superintendent for Instruction for approximately six months. Previously she was a special education administrator at the same ISD for about ten years, “working with local districts on compliance with federal and state mandates.” Her interview provided a frame for how her ISD conceives its role and responsibilities as a partner in promoting implementation of NCLB, conflicts, barriers, and challenges in implementation, and her observations of districts’ responses to NCLB. The ISD as a partner in promoting implementation of NCLB. Connie’s views on NCLB stem from her lengthy experience in special education and her personal values. When asked whether the work of NCLB prohibits her fiom doing other, valued work, she responded, “No, because I’ve got the commitment to work on those areas whether they’re a priority in a mandate or not. I create ways to link those into the work with the mandates and the priorities and I think that’s one thing we’ve really got to get schools thinking about, too.” She sees NCLB requirements as “a window of opportunity” to increase 110 collaboration and shared responsibility for all students, including those from general and special education, and tries to leverage the requirements to promote this collaboration. Beyond her personal views, she shared how her ISD has structured its role relative to NCLB implementation, its partnership with MDE, and NCLB supports and services to districts. Not surprisingly, she sees her ISD does not have adequate resources to do its work. Some of their work is mandated by state law. Beyond that, she stated, “As an ISD, you’ve really got to set your priorities and your commitments. . . . We’ve set that commitment to provide the technical assistance and support that local districts need around mandates. Probably not every ISD provides that level of service.” In fact, in reflecting on the focus of other ISDs, she believes her ISD is especially devoted to NCLB, saying, “One of the things that our ISD has really tried to . . . build a foundation for is the commitment and the culture around which these mandates are founded.” One of the ways her ISD has addressed this is through several years of leadership development series, including “Together We Can,” and “Together We Still Can,” drawing curriculum and special education directors from constituent districts to lay the groundwork for district reculturing, looking at student achievement data disaggregated by subgroups, and building a collective commitment to improved outcomes for all students. They’ve also conducted district leadership training series for several years. This year, they’ve launched a significant initiative through grant support from the HOPE Foundation, bringing together middle and high school building teams of principals, counselors, and general and special education teachers to participate in a “Courageous Leadership Academy” or CLA. The CLA is built on a “professional learning community 111 model,” intended to create a “moral imperative” for changing school cultures and practices to improve student achievement. She sees these initiatives as intimately connected to the core work required for schools to succeed under NCLB. In addition, her ISD has regular meetings with “stakeholder groups” that help to set the ISD’s priorities and directions. Speaking to me as a representative of one stakeholder group, she commented You serve as a need setting-direction setting vehicle for the ISD as a whole. . . . A lot of it comes from our work with the Department of Ed. If we know what’s on the horizon we’re often preparing and trying to build capacity before things have to be implemented. So it’s kind of a proactive and a reactive — kind of a lead-serve sort of relationship that we play. Connie also commented on the ISD’s relationship with MDE relative to NCLB and its requirements. Her ISD is situated in close proximity to MDE, and she states they have “historically had a very close relationship” with them. She talked about the decreased resources at MDE, reporting, “They often tap us for development work around the mandates, and how the State will meet the mandates, let alone how the mandates play out for local districts. . . . We play a real integral role not only in supporting the local districts, but also in supporting the Department of Ed.” Connie herself has “sat on several MDE-referent groups,” and several of her ISD consultants helped develop MDE’s School Improvement Framework, consulted on high school redesign, Career and Technical Education requirements, as well as General and Special Education requirements. Connie’s ISD also spends a lot of time preparing information to share with districts to support NCLB implementation. This work focuses on assessing and synthesizing information on mandate requirements “that can then be disseminated in a 112 user friendly way.” It is usually done collaboratively with other ISD staff, similar to MDE’s meetings to review new information. We’ll really break it apart into its main components and then ascertain salient pieces of impact . . . . With No Child Left Behind we did a fairly extensive analysis, and used professional organization analysis to help us sift through what were going to be the core and essential things that we needed to communicate. As an intermediary it makes sense for us to create meaning out of the mandates . . . . We help set and advise policy at MDE’s level. We then synthesize the impact and the salient components of that at the ISD level and disseminate it to our locals, and then it’s really your role to implement the mandates as you see fit based on the information we can provide. To do this work, the ISD uses a lot of website resources and contacts at MDE and USDOE. This requires “a great deal of time and vigilance monitoring legislative sites for pending legislation and changes in mandates.” This vigilance means they get timely information on “amendments, revisions to regulations around the legislation that’s mandated that are probably even more important than the legislation itself.” In addition, they share this information in frequent meetings and inservices with “constituent groups, like curriculum directors, superintendents, and special education directors, on the actual impact that this will have to their daily operations.” Connie described various ISD units that help to implement and monitor NCLB, primarily their general education unit. We have two school improvement consultants that are actively involved in helping folks around the AYP issues. . . .We also have a Planning and Evaluation Unit that has been very integral in the testing and accountability side . . . to help districts with implementation of assessments, as well as adequate yearly progress and school report card information that comes out. Our curriculum folks are well versed in No Child Left Behind, particularly around the accountability standards that the State has set and has been approved for our implementation here in Michigan . . . and they’ve been very actively involved in the content expectation and assessment development that’s been going on in the State 113 over the last number of years. . . .From a Special Ed perspective, there certainly are implications for No Child Left Behind as well, and in my former role I was doing quite a bit of analysis on the impact that No Child Left Behind would have on the subgroup for students with disabilities. We also have one of our consultants that does attend and provide information dissemination around Title I requirements which is another significant aspect to No Child Left Behind. Connie also addressed the ISD’s change in focus regarding NCLB implementation. She commented that beyond helping districts with the management issues related to NCLB, such as responding to accountability requirements, “It’s been a two to three year journey . . . to move from it being a theoretical discussion to a practical application . . . to get us to that level of awareness and context building so that people have a common understanding of the issues.” Conflicts, barriers, and challenges to NCLB implementation. As a former special education administrator, Connie is sensitive to some of the conflicts and barriers to implementing NCLB. Some of these issues stem fiom conflicts in the legislative requirements of NCLB and IDEA, the Individuals with Disabilities Education Act. She sees a conflict in the two sets of regulations and law . . .[because] IDEA is based on an individual education program, and NCLB really is group- based accountability, and the two don’t always match. We have a lot of issues with how many students take alternative assessments and how those decisions are made via an IEP [Individualized Education Program] process, and those types of things. She was also disappointed that “one of the things that really got comprised [in NCLB] were the highly qualified personnel requirements for special educators. They really had to regress those requirements . . . because the higher education and training institutions don’t have structures [to support] in place.” She sees this as a conflict, because while special educators can differentiate content for students, “they don’t know the curriculum 114 itself, and they don’t have the instructional skills to deliver that content or assess it. . . . There needs to be a very significant partnership to really fully realize the potential of both mandates, IDEA and NCLB.” She described what the ISD is trying to do in “cross functional work groups” to build ways to help general and special educators to work more closely together in constituent districts. One of the most significant barriers she sees for district implementation relates to this exact issue: “Our systems have been in little silos, not working together, no integrating resources, and now we need to do that.” However, she noted that sometimes the legislation itself requires silos. For example, Title I requirements in targeted assistance schools mandates that money goes to service only Title I caseload students, preventing implementation of “best practices” such as Title I teachers doing model lessons, or even co-teaching with classroom teachers. There is often very limited flexibility to transfer federal grant monies from one grant to another. Special education requirements also restrict how and where money is spent. So rather than integrating resources, “we compartmentalize everything, and kids aren’t compartmentalized!” The impact of this is that despite NCLB’s intent to support the achievement of “all,” issues with funding restrict use of resources to support all. However, the challenge Connie sees as arguably the most significant to district implementation of NCLB has to do with educators’ beliefs: You know, we rationalize an awful lot. I think there isn’t a belief really that all kids can achieve at high levels. I think we have that Bell Curve in our mind and it’s okay [because] kids choose not to be successful. I think we’ve lost the focus on student learning and it’s all about teaching; it’s got to be about teaching and learning. And if the kids aren’t learning, then you need to change how you’re teaching, and we don’t often do that, we just say, ‘Well, kids need to change.’ Or, ‘It’s because of these things, and I don’t need to change what I’m doing to make more kids successful.’ 115 Ultimately, she wonders whether educators are really committed to the “very hard work to make all kids successful in a classroom.” This is the reason she has been so focused at trying to get educators connected to a sense of urgency, or “moral imperative,” through her work at the ISD. Observations of local districts’ responses to NCLB. Throughout the interview, Connie’s perspective on district level responses to NCLB emerged. Initially, she saw increased activity as districts grappled to understand its requirements. In the early years, as the first schools and districts failed to make AYP, she witnessed peOple “doing a lot of finger-pointing at each other,” particularly at Title I and special education staff, expecting them to ‘fix that cell group . . . [or] get those kids with disabilities assessed the right way and get those numbers up.’ Special ed was saying, ‘Well, general ed, you’re not giving us any access to the curriculum, so how can we do that?”’ And she also heard people sighing, “Well, this too shall pass.” Furthermore, Connie has seen districts’ preoccupation with “the stick of accountability” and the administrative and managerial requirements spawned by NCLB’s compliance standards. She noted, “There are probably a good four to five hundred [compliance standards] in NCLB, so just the sheer volume of compliance indicators can be pretty substantive.” When asked about whether she thought their constituent districts were in compliance, she said she thought districts overall operate in good faith, but “sometimes there is tension between doing the right thing for a student or a program and doing what’s compliant. . . . Compliance is significant, but it can’t bury us to the point where we can’t have some flexibility in meeting kids’ needs.” She also sees that the details involved in compliance can be very distracting: “I think we are so used to and 116 mechanized in education to just responding to the mandates of the day that we really do lose sight of the values and beliefs underneath that.” Generally, she returns to the importance of the “moral imperative,” believing that “We’ll comply with the mandates if we have the moral imperative in place.” When asked whether she thought constituent districts were responding to the moral imperative for change embedded with NCLB, she responded, “I think we’re getting there. I’m not sure we’re totally there. . . . I think we’re more there at a district leadership level . . . around the unity of purpose considering the moral imperative needed today.” Toward the end of the interview, I asked whether she thought district preoccupation with the “nuts and bolts” of NCLB compliance standards set districts back. She replied I think with any reform comes a setback, because you have to take a step back and assess where you’re at and determine where you’re going to go, but it fell short in a couple — you know in a couple of those areas with the way the targets were set and those types of things. So I think you take some of the unrealistic expectations coupled with the fact that it was reform legislation, and it just sets people on their car in terms of helplessness. However, she is very hopeful that with time, the essential changes built through “collective commitment” will help districts implement NCLB more effectively. Interview with an ISD Prevention Specialist: ISD Responsibilities for PA 165-166 Willa Smith has worked for her ISD as a Prevention Specialist, which includes responsibilities as the Health and Safety School Coordinator, for eleven years. She is based at one ISD, but serves a total of three ISDs through grant funds. For eleven years previous to her tenure as Prevention Specialist, she was a Michigan Model trainer, giving her a total of twenty-two years of service at her ISD. 117 In her role as a Health and Safety School Coordinator, she provides consultation as one of 25 health coordinators across the state. She participates in several consortia meetings state wide, and consults with districts on PA 165-166 under the Comprehensive School Health Grant. She actually provides technical assistance on all health topics, but finds sex education to be “a sensitive topic, and recently in Michigan there have been laws enacted . . . [so] that is a major focus.” She shared many insights about PA 165-166 and its implementation during her interview, including how the legislation was developed through special interest group advocacy, her role as an external partner working with districts on implementation, conflicts, barriers, and challenges to district implementation, and her observations of district implementation. A story of special interests: Development of PA 165-166. When asked about how she came by information regarding PA 165-166, Willa reported she’d been notified of the legislation “before they were enacted” by MDE. Representatives at MDE were very concerned about some of the changes for sex education in the proposed legislation. What she shared was a fascinating story about the legislative process. A Michigan-based “family lobbying organization . . . loosely affiliated with Dr. J arnes Dobson” was networked with a national special interest group. This group “targets certain states [where] they think they can be successful in making sex ed laws more conservative, and then they will provide support for what the issues are and how to propose the legislation to make changes.” One of their legislative lobbyists, Dan Jarvis, “actually wrote the legislation and got a couple of conservative legislators to propose [it] on their behalf.” The purpose of the legislation “was to more actively involve parents and families in the process of sex education and to strengthen the emphasis on 118 abstinence.” They also wanted students educated on Michigan’s sexual activity laws, “including sodomy and co-habitation.” Some of the original language “could’ve been interpreted so that schools could not teach anything about risk reduction,” and also involved a “significant financial penalty . . . and a complaint process from the parent right to the State Department of Education.” Willa was a part of generating “grass roots support to impact changing those laws to make them more palatable to school districts.” However, this was far from easy, as she was stonewalled at many turns. When asked what she learned about special interests and the legislative process, she replied, “I learned that the legislative process is very long and very disillusioning, and that it is nearly impossible for the average citizen to participate the way it’s organized.” Working together with a network of likeminded people, they were successful in getting the legislation changed to be “less onerous” for districts. I also learned that you have to use the press in order to make a difference. One of things that really got some action was I finally got so frustrated at the hearings at not being called to testify. They would call all the people who were in favor of the legislation, and leave all the people who were opposed until the end, and then tell them they had one minute to speak or not call on them at all, and then they took a vote after the Democratic portion of the committee had left the room. It was appalling the things I saw and experienced. At that point where that hearing was so disrespectful and so poorly managed, I issued a press release, and complained in the press release about the flagrant disregard for the Democratic process, and the dishonesty with which the hearing was conducted. That Press Release was actually hand delivered to all of the senators and representatives in the legislature at that time, and they were so embarrassed, they finally started to come around and started negotiating about the language of the Bill. 119 She regards this as a moderate success, but is aware districts struggle with implementation, commenting it “still feels recent because schools are still scrambling to get into compliance.” Partnering for implementation of PA 165-166. Many of Willa’s responsibilities center on communication of PA 165-166 requirements. She communicates through a variety of channels: an e-mail group list that includes the designated sex education supervisor for each district, health advisory meeting three times yearly, and occasional meetings with curriculum directors. She finds the health advisory meetings are “not consistently attended,” but e-mails meeting minutes to stakeholders afterward. In addition, she reports, “I get literally hundreds of e-mails and dozens of phone calls every week,” with many of these contacts related to PA 165-166. One of Willa’s frustrations is cuts in funding for health education over the last few years, which has prohibited her from providing much direct assistance to districts. “1 used to go out and facilitate Sex Ed advisory committee work regularly and it was one of my favorite parts of my job. With the cuts my time has now been bought by other grant sources and I’m not able to do that very often.” She finds this to be a significant drawback, because “in working with districts I find that they don’t fully understand the law and the requirements and they really don’t fully have a handle on what their teachers are teaching in the classroom.” In addition, she reports she doesn’t have the time or authority to monitor district implementation. That’s not my role, and even the State Department doesn’t monitor implementation. The only thing they monitor is if there’s a Sex Ed supervisor on record with them, and I assist them with that. So I guess that’s sort of monitoring. What I do is I try to maintain a chart of what 120 each district is doing so that if they call me and ask, I can say well on this date I was told you were doing this. And I also keep professional development records of what teachers have attended Sex Ed training. I keep a record of what HIV curriculum has been approved by their school boards and what teachers have been HIV certified, because that is still required. So it’s more of just trying to figure out what people are doing to be supportive rather than monitoring. Beyond this, the only way she is able to monitor for implementation is if there is a parent complaint, and she is unaware of any complaints in her ISD or service area. Conflicts, barriers, and challenges in implementing PA 1 65-1 66. Willa is clearly passionate about the importance of preventative health education, including sex education, but is frequently frustrated by the conflicts, barriers, and challenges of district implementation. There are many factors involved that she believes can prevent good implementation. As noted earlier, lack of understanding of PA 165-166 requirements is a significant factor. In addition, competing district priorities and resources, communication of expectations to teachers, and difficulties working with sex education advisory boards can also inhibit implementation. Willa is aware that while educators may value health education, “The current climate in education doesn’t allow them to act on that concern in a way that gives them much instruction time to impact health behavior.” She sees districts as “stretched in so many different directions, with so many different legal requirements . . . and to be quite honest, with NCLB, Education Yes, and the focus on MEAP test scores, health is at the bottom of their priority list most of the time.” In addition, she finds that the district administrator responsible for sex education is “always someone wearing a dozen hats or more . . . [so] it make it very easy for [sex ed] to fall down in the priority ranking.” 121 She further observes that teachers don’t always understand they can’t simply teach sex education the way they see fit; unlike with other curricular areas, “Individual teachers really don’t have the right to make decisions about what they teach in sex ed and HIV.” Beyond ensuring teachers know what they can teach, she also notes there is “a lack of understanding on how to effectively impact sexual behavior among young people,” with far too much reliance on “cognitive information” and showing videos with little discussion. And so part of that is a professional development need for people to understand how to make a Sex Ed program as effective as possible, because if it’s not effective, why do it? The other is some teachers have discomfort with the subject and they will voluntarily teach less than they’ve been approved to teach out of their own personal discomfort, and then the kids don’t get the information and skills they need and they may even get a negative message, although unspoken, from a teacher who has personal discomfort with the topic, and therefore perpetuates this taboo about talking about sex. Another challenge to effective implementation she sees districts struggling with involves recruiting and retaining a sufficient number of parents to fill out the fifty percent requirement for the sex ed advisory board mandated by PA 165-166. She comments, “I think school districts are sometimes afraid to talk about their sex ed program with the community for fear that it will incite an uprising.” In addition, many districts struggle with parent membership on their advisory boards that is slanted in one direction or another, either liberal or conservative, and don’t take their charge seriously to represent the opinions and values of the whole community. She states, “At the district level, special interest groups shouldn’t be allowed to have a voice . . . . if you allow a special interest group to steer the direction of the outcome, then it really doesn’t have community buy-in.” She’s seen many examples of “an influential church group in a community, and 122 they will stack the attendance at a public hearing or a board meeting, or stack the attendance on the advisory committee in order to get their way.” Finally, she sees the lack of monitoring as an impediment to implementation. In her role, she does not monitor implementation, and also sees that districts don’t always know what specific sex education curricula and materials are approved, let alone track what’s taking place in classrooms. Observations of districts ’ responses to PA 1 65-1 66. When asked to describe district implementation, she states it is “inconsistent and diverse.” While she believes “the majority of the schools I work with view [PA 165-166] as an unbending structure that they need to comply with,” districts fear the consequences of not complying appropriately, “and rather than not comply with them, they will stop doing sex ed.” She described districts who have “shelved sex ed for a year because they can’t come into compliance” and didn’t feel they could risk a financial penalty if there was a complaint. Overall, she finds district compliance and implementation very spotty--some districts do a good job; some districts don’t do a good job, they just do as little as possible; and some districts don’t do Sex Ed at all because it’s not required by law, and it’s a hassle, and it can get them a lot of negative feedback from parents if they’re not careful, and so it’s very diverse. In general, she confirmed that districts’ responses to PA 165-166 demonstrate uneven compliance with its requirements, due to many factors: a lack of understanding of its requirements; competing district priorities and insufficient instructional time dedicated to health education; a lack of professional development for teachers to equip them to teach sex education appropriately; and a lack of instructional oversight and monitoring. 123 Connie and Willa, the ISD partners, had quite different roles and areas of responsibility in working with constituent districts. Their perspectives of their roles, as well as local district implementation of NCLB and PA 165-166, are summarized in the next section along with the two other external partners from MDE. Summary The external partners in this study included two consultants from MDE and two ISD administrators. Three of the four have responsibilities pertaining to NCLB, while the fourth works with PA 165-166. It is apparent their responsibilities vary depending on the level at which they’re employed, either at MDE or an ISD, and the legislative mandate with which they work. Generally, the two MDE consultants shared their perspective as state specialists in understanding, interpreting, and administering NCLB requirements. While they strive to disseminate information and provide technical assistance to LEAs, limited MDE capacity has forced them to rely more on ISD supports. The ISD consultants work with MDE, analyze and synthesize information on the mandates, disseminate to LEAs, and provide technical assistance for implementation within their constituent districts. The perspectives shared by the four external partners revealed some interesting patterns demonstrating districts’ responses to legislative mandates. Regarding implementation of NCLB, the state level consultants reported more variability in districts’ compliance and commitment to the letter and spirit of NCLB, representing a broad view of responses, but lacking some of the depth possible fiom the ISD perspective, who by design work with fewer districts. Connie, the ISD partner working with districts on implementing NCLB, portrayed districts’ responses as clustering into 124 some fairly predictable patterns: a scramble to learn about NCLB and understand its implications for districts; early “finger-pointing” and blame when schools and districts realized the consequences of not making AYP; preoccupation with the managerial details of monitoring for compliance with various requirements; and perhaps, a gradual shifting of attention to connecting with the “moral imperative” inherent in NCLB: assuring all students are learning and meeting proficiency standards. Her observations likely reflect her ISD’s work county wide to get districts working together on effective implementation. Willa, the external partner working with districts in a tri-county area on PA 165- 166, reported very “inconsistent” responses at the district level, perhaps because there is an “opt-out” provision for districts to decide they will not teach sex education, beyond mandated HIV education. She also noted that district capacity for responding to both NCLB and PA 165-166 is so limited, that many districts focus on NCLB, to the detriment of effective implementation of PA 165-166. Data fi'om the study districts, in the next sections, will be presented and analyzed to reveal more in-depth information on districts’ responses to NCLB and PA 165-166. To provide important contextual background in understanding the pilot and case study districts, the next section offers a description of each setting. Settings Pseudonyms were assigned to administrators, school districts, and communities included in the studies for confidentiality purposes. The names for the pilot and case study districts and selected characteristics of each are shown in Table 2. 125 Table 2: Characteristics of Fairview Community Schools and Steele Public Schools. Characteristicsa Fairview Community Schools Steele Public Schools Community State University city Industrial city Location Mid-Michigan, Suburban Mid-Michigan, Urban Population” 46,525 36,316 Bachelor’s degree or higherb-% 70.4 13.1 (25 years of age and over) Median household incomeb $28,217 $31,294 (in 1999 Dollars) Families below poverty level”-% 1 1.0 15.2 Student Enrollment %-2005 Enrollment # 3,520 6,894 White 63.7 55.2 Black 15.6 37.7 Hispanic 5.8 4.4 Asian/Pacific Islander 1 1.9 1.5 Native American 0.5 1.2 Multi-Racial 2.5 0.0 Economically Disadvantaged 24.0 64.0 English Language Learners n.a. n.a. Students with Disabilities 11.1 18.0 Schools of Choice 2006-07-%" 19.4 6.1 Enrollment Pattern ° Declining Declining 2001 Enrollment 3,606 7,376 2005 Enrollment 3,520 6,894 Student Proficiency on State Tests-2006 Reading Proficiency-% 87.8 70.1 Math Proficiency-% 81.2 56.2 Estimated Student Graduation Rate-2002: Cumulative Promotion Index (Urban Inst.) % 92.6 56.6 NCLB Information-2005: Is this district making Adequate Yearly Progress (AYP)? Yes Yes Revenue Per Student ($)-2004 Local $5,803 $2,601 State $5,904 $5,998 Federal $289 $969 Personnel-2007 c Number of Faculty 227 460 Number of Central Office 6 l2 Administrators aPrimary Source, except where noted: Standard and Poor’s School Evaluation Services, www.ses.standardandpoors.com (Percentage of economically disadvantaged students. State average: 33.4%). bSource: Census of Population and Housing (2000). cSource: Information obtained fi'om Fairview and Steele administration. 126 The Pilot Study: F airview Community Schools Fairview Community Schools is situated in the city of Fairview, a suburban university community of approximately 46,525 residents. Its pOpulation includes long- time residents, students, visiting university scholars, and an increasing proportion of its permanent residents in their post-childrearing years, contributing to the district’s declining enrollment over the past ten years. It is also primarily “landlocked,” with property values and local taxes high enough to discourage young families from purchasing homes in Fairview. To help offset declining enrollment, the district has advertised and accepted increasing numbers of Schools of Choice (SOC) students, with nearly 20% of enrolled SOC students currently attending its schools. SOC students have contributed to an increasingly diverse school system, with the majority of SOC students conring from a neighboring urban district. District enrollment in 2005 included 3,520 students, distributed between six elementaries, one middle school, and one high school. Nearly 67% of its students in 2005 were white, with 16% black, 6% Hispanic, and 12% Asian/Pacific Islander students. In addition, 24% of its students met criteria as economically disadvantaged, while 11% of the students overall have identified disabilities. As a community, the residents tend to be college graduates, with over 70% possessing a Bachelor’s degree or higher. The median household income in 1999 dollars was only $28,217, but this may well reflect a significant number of student residents. Eleven percent of city residents rank below the poverty level. Revenue per student in 2004, including local, state, and federal sources totaled $11,996, according to Standard and Poor’s School Evaluation Services. Within its 127 county, F airview has one of the highest foundation allowances per student relative to other districts. Student proficiency on state tests (2006) shows relatively high achievement, with approximately 88% testing proficient in reading, and 81% of students meeting math proficiency standards. In addition, the district met Adequate Yearly Progress standards (2005). The graduation rate was calculated at nearly 93% (2002). The Case Stuay: Steele Public Schools The setting for Steele Public schools is very different from F airview. Located in Steele, Michigan, it is regarded as a predominantly blue collar, urban environment built on an industrial base. Its total population is 36,316, with approximately 13% of adults holding a Bachelor’s degree or higher. The median household income in Steele is $31,294, with 15% of families living below the poverty level. While the city of Steele’s total population is actually lower than in F airview (whose numbers are swelled by the university student population), Steele’s district enrollment nearly doubles F airview’s, with 6,894 students. The student population is distributed between eight elementaries, two middle schools, one high school, and an adult/alternative school setting. It hasfewer white students, with just under 56% white, almost 38% black, 4% Hispanic, and 1.5% Asian/Pacific Islanders. The percentage of economically disadvantaged students is significant larger, at 64%, with 18% of students identified with disabilities. However, fewer of its students enrolled through Schools of Choice, with 6.1% SOC students in 2006-07. Steele also receives fewer dollars per student from local, state, and federal sources than F airview, totaling $9,568 per student in 2004. In addition, Steele’s proficiency 128 scores on state tests are lower. Approximately 70% of students test proficient in reading, with 56% proficient in math. The district did meet Adequate Yearly Progress standards in 2005. However, its 2002 graduation rate was not quite 57%. In summary, Steele is a predominantly urban, working class community, with a school district nearly double the size of F airview’s. The student population includes over two and a half times more economically disadvantaged students, a resident population with significantly less formal education, and fewer dollars per student to educate its youth. The overall student achievement and graduation rate in Steele is lower than in F airview. The different settings provide an opportunity to exanrine how contextual factors may influence the districts’ responses to federal and state legislative mandates. The Pilot Study: Fairview’s Responses to Federal and State Legislative Mandates The general characteristics of F airview Community Schools and the local context were provided in the previous section. As interview data and documentation from Fairview was collected and analyzed, a picture emerged of its responses to legislative mandates over time. Information unique to Fairview’s recent history and operations illustrates contributing factors to its responses to NCLB and PA 165-166. In addition, data is presented and analyzed to examine how the district has responded to NCLB and PA 165-166. Finally, I will smnmarize themes to explain Fairview’s responses to NCLB and PA 165-166 and how these responses differ. Local Factors Contributing to F airview ’s Responses to Legislative Mandates A number of local factors have contributed to Fairview’s responses to NCLB and PA 165-166, including significant turnover in all central office leadership positions since 1999, a pattern of decreasing district revenues based on state funding and declining 129 enrollment, cuts in administrative and support staff, and a community context described as “highly politicized.” These contributing factors will be described in detail. Administrative Turnover and Shifts in Leadership Interview data and district documents reveal a great deal of administrative turnover in the Central Offices of F airview Community Schools. From 1999 to 2007, a span of nine years, there have been three superintendents, including an interim; restructuring of the Director of Educational Services position, with a total of four people taking on related responsibilities; three Directors of Finance, three Directors of Human Resources, eight different shifts in the Director of Special Education position, two shifts in Director of Support Services responsibilities, changes in other key positions, along with shifts in assigned responsibilities within several of these positions. Table 3 summarizes the changes in administrator positions and responsibilities. Since 1999, there have also been many changes in building leadership. Only one principal remains in the same position she occupied in 1999, which was actually her first year as a principal. Of the other thirteen principals in 1999, two positions were eliminated (one associate principal at the high school, and one due to closure of an elementary school), seven retired, two resigned to accept positions in other districts, and three remain in the district in different building assignments. In 2006-07 alone, the high school had two new associate principals (two highly respected, veteran elementary principals transferred by the Superintendent to try and shore up high school operations), the middle school had a new principal and associate, and the two former high school associate principals were transferred to 5-6 buildings, resulting in a net effect of only the high school principal remaining in the same position in the 5-12 buildings. 130 Table 3. Changes in Fairview’s district administrator positions and responsibilities, 1999-2007. Central Office Changes Over Time Position Superintendent Dr. Ganson, terminated by Board effective June 2004 Mr. Reynolds, Interim Superintendent, June-August, 2004 Dr. Cooper, August 2004-Present Director of Educational Services (Formerly 2 positions, 1 for K-5, 1 for 6-12) Responsibilities filled by two “Teachers on Special Assignment” until 2000. I Dr. Owens, Director for six weeks in 2000, terminated I Ms. Green, Director (interim, then permanent), 2000-2005 I Ms. Ten-L Director, 2005-Present Director of Finance I Ms. Pinnell, Director, resigned 2003 I Ms. Bolen, Director, 2003-2005 (resigned) I Mr. Parsons, Director, 2005-Present Director of Human I Ms. Anselm, Director, resigned 2001 Resources I Ms. Flowers, Director, 2001-2003 (resigned) I Ms. Peckham, Director, 2003-Present Director of Public I Mr. Gray, position eliminated in 2001 Relations I Ms. Grable, half time Coordinator of Communications hired April, 2007, jointly funded by district and Foundation Director of Special I Ms. Anselm (both HR and Special Education Director in 1999) Education I Ms. Peters, 1999—2002 (resigned) Mr. Gibson, 2002-2004 (both Elementary Principal and Special Education Director during this period). Ms. Peters, Interim Director, 2004-2005 (part time and then resigned due to health issues) Mr. Monson, Interim Director, April-October, 2005 (retired) Ms. Delaney, Director, November 2005-August 2007 (resigned under pressure to accept a teaching assignment) Ms. Atkins, Interim Director, September-October, 2007 Ms. Calkins, Director, accepted position in October, 2007 Sex Education 1999-2002, full-time District Nurse coordinated responsibilities with Supervisor oversight by Director of Special Education I 2003-Present: District Nurses gradually reduced; completely eliminated effective June, 2007. Responsibilities for Sex Education shifted to Director of Educational Services. Director of Support Mr. Elwood, 2003-2005 (position eliminated) Services 2005-2006, Responsibilities shifted to Director of HR 2006-Present, Responsibilities shared by Directors of HR and Finance Director of Title I Until 1999, a Director-level position, position eliminated 1999-2005, part-time coordination by a teacher, with oversight by Director of Educational Services 2005-O6, responsibilities shifted completely to Director of Educational Services 2006-07, responsibilities shared by Director of Educational Services and a part time teacher doing field supervision 131 In addition, F airview’s administrators talked about the changes in district leadership. Ms. Peckham, the central office administrator with the longest tenure in the district, reflected on the changes she’s seen: Even though I’ve only been here four years, I’ve seen an enormous amount of change. What the district has lacked is a leader that I think understands a school district and roles of individuals, along with establishing what the needs are for the district, what their vision is for the district, what the goals are, and working collaboratively with everyone. We’re just beginning our [strategic planning] process and I think . . . once we can get through the initial process, I think that we will begin to move beyond not being effective, and with time I think we’ll get there, but it will be slow moving. The lack of consistent leadership left the district particularly vulnerable to the influence of special interest groups. Dr. Cooper, the Superintendent, discussed the strategic plan under development in the winter and spring of 2007, which he hoped would “deflect some of the strong interest groups who may be interested, intentionally or not, in sort of detracting . . . or distracting the school district from reaching a goal that they deem important.” Concerns about district leadership were also documented in the Strategic Planning Consultant’s “Internal Focus Group Report.” Eleven participants held discussion with the Consultant, representing various internal stakeholder groups, on critical issues within the district. The Consultant’s report indicates Participants expressed concern about the challenges before the Board and Administration, recognizing that strong and decisive leadership is needed given the realities before the District. Several participants noted that the District is not as strong as it once was and that its reputation in the community has faltered. As one noted, ‘We have been treading water for far too long.’ The corrective is perceived as needing to build a strong shared leadership style among the Board, Administration and Principals. 132 The Consultant noted in private discussions with the Superintendent and the author that the teachers in the Focus Group felt that the district had been held together by the strength of its teachers, but had been lacking “strong and decisive leadership” for years. Embedded within the Strategic Plan, adopted by Fairview’s Board on May 21, 2007, are two leadership goals: “Provide excellence in governance to assure achievement of mission and vision,” and “Develop effective leadership at all levels.” Decreasing District Revenues As noted in the previous section, one elementary building was closed in 2002, after much controversy and community opposition, due to declining enrollment and decreased revenue available to the district. Ronald Parsons, F airview’s Director of Finance for the past year and a half, shared insights related to Michigan school frnance: Prior to ’94, school districts were basically firnded off of property taxes. Then Michigan voters approved . . . Pr0posal A, which basically took local control of funding from districts and gave it to the State. With Proposal A, they reduced property taxes and basically funded school districts off of an increase in the sales tax, which went fiom 4% to 6%. So districts are not capable now to go to the voters and raise additional funding. We are dependent on the State, and when the State’s economy struggles, funding is in question, which it currently is. We’re 75% roughly through our school year and we don’t know what our funding is this year. So that’s impacted the amount of resources we get fiom the State, [which] is always in question when the economy is struggling. The district’s enrollment has declined over the years, and funding is directly tied to enrollment, so our funding has been an issue basically over the last six years. The district has gone into or has had to address budget deficits each of those years and thus the personnel reductions and the need to still address additional mandates by the Federal government as well as the State. In addition to a school closure, reduction in teaching staff, privatization of custodial services and the food service supervisor position, delays in planned bus purchases, building renovations, and upgrades to technology, budget problems have resulted in cuts in administrative and support staff. 133 Administrative and Support Staff Cuts The Superintendent made reference to “downsizing” by one director level position in the district. However, the three central office directors interviewed all went into significant detail about the budget cuts and reductions in administrative and support staff. Along with district records, interview data revealed the following cuts: Director of Support Services in 2005, with responsibilities shifted to the Directors of Human Resources and Finances; Significant cuts and consolidation of responsibilities for the Director of Educational Services, from the “heyday” of three positions for elementary and secondary curriculum directors and a Title I director, to one full time position, with some assistance from a part-time teacher coordinator for Title I; Elimination of all district nurse positions, including the former Sex Education Supervisor, resulting in a shift of responsibility to the Director of Educational Services; Elimination of the Public Relations Director, with partial restoration through a half- time Communications Coordinator in 2007; Reduction in central office support staff in the Business Office, including a separate position in receipts and benefits eliminated, with responsibilities transferred to the receptionist. All Fairview directors indicated they felt overwhelmed and overworked. The Director of Human Resources expressed frustration about her workload, saying I’m continually distracted from what I regard as my core work, the work I’m most qualified to do, by having to get bids for buses, monitor transportation problems, plan playground upgrades, work with the maintenance guys. I think that’s really indirectly related to mandate 134 requirements. . . . What I mean is, we have budget cuts and are losing administrators, while at the same time, some of our workload increases due to mandate requirements like highly qualified. And then when the mandates come with no additional funding, and the budget gets worse and I’m assigned even more responsibilities, I just don’t feel like I do an adequate job at anything, least of all HR. In fact, this was a deciding factor in the retirement of the former Director of Educational Services, who reported, “I always prided myself at being good at multi-tasking, but I had reached my limit. . . where I feel I didn’t do a good enough job. . . . I just couldn’t keep up the pace that I had been working under . . . and it was resulting in health problems and it wasn’t worth it.” The sense of inadequacy to meet competing demands and responsibilities on the job was a significant source of stress for central office administrators. They recognized the importance of keeping budget cuts away from classrooms and students as much as possible, but also worried about meeting federal and state compliance standards or committing a serious error, either by omission or commission, simply because they didn’t have the time to get all of the work done. Political Context and Competing Demands in F airview Situated in the community of one of Michigan’s “Big Three” state research universities, Fairview attracts many university families and visiting scholars. As the datum in Table 2 indicates, Fairview’s population is very well-educated. There is high involvement by parents at the classroom, building, district, and Board levels. Not surprisingly, community agendas differ. The Strategic Planning process and involvement of stakeholder groups bears witness to community expectations. The “Strategic Planning Community” was comprised of forty-three individuals, including Board members, district and building administrators, teachers, parents, university faculty, and representatives from the City of 135 Fairview. The 2007-2011 Strategic Plan document (Appendix D) is evidence of the community’s wide-ranging, significant expectations of the district, articulated in twelve goals, twenty-four strategies, and eighty-nine objectives. Notably, only two of the goals related to operational and resource management. The other ten goals address teaching and learning, professional deve10pment and evaluation, data collection and analysis, and leadership and communication within and outside of the district; thus, nearly all goal areas bear a direct connection to NCLB and student achievement issues. Fairview is a community with high expectations, a sense that its once lustrous reputation as a lighthouse district is on the wane, and generally is comprised of individuals unafraid to advocate for their desires in multiple venues. Some of the demands voiced by community stakeholders since my tenure in the district have included increased physical and health education, including doubled physical education time and nutrition education at every grade; increased funding for athletic facilities and programs; world language instruction at elementary; “Gifted and Talented” programs at elementary and middle school; district-firnded preschool programs; continuation of the full-day kindergarten program; honors classes and “tracking” at the high school; district funding for students to take college level Advanced Placement exams; individual tutoring for struggling students; “one-on-one” specialized services and programs for students with disabilities; and transportation for Schools of Choice students from their home districts. University students have submitted thirty-six requests to do research in Fairview, three university faculty members are currently conducting research projects in the district, and multiple partnerships exist with city and community agencies. Community stakeholders generally possess a fair amount of 136 political savvy and know how to generate attention to their demands. This results in a district context in which stakeholders expect to be heard, and Board members, administrators, and teachers sometimes feel besieged by competing demands. The Director of Finance expressed his frustration with the frequent welter of community demands: “I’m a firm believer in the good of the whole, so I like to look at things from a district standpoint rather than individual programming issues. I’m not in favor of how special interest groups are able to influence decision making.” However, it is widely recognized as part and parcel of working in F airview. F airview ’s Response to NCLB As noted, local factors have influenced F airview’s response to NCLB. Data emerged from interviews and district documents to demonstrate how Fairview responded, fiom initial steps of learning about and assessing NCLB’s requirements, how administrators initiated district implementation and monitoring, as well as administrative challenges and conflicts experienced in response to NCLB. Channels of Communication and Assessment of NCLB Requirements Most district administrators described similar patterns for gathering information on NCLB. Interestingly, even though NCLB originated at the federal level, most district administrators described that their initial wave of communication came from the Michigan Department of Education. For example, Kathleen Peckham, Fairview’s Director of Human Resources, reported, “It usually starts at the Michigan Department of Education, where leaders there in the Professional Preparation Office will disseminate information from the Superintendent of Public Instruction to all ISDs and/or school districts.” Melissa Green, retired Director of Educational Services, concurred, noting 137 “some of our leaders from the State [would give] seminars and speak [about] what was coming down the pipe.” The next wave of communication usually came from the ISD, through group meetings specialized by job functions and responsibilities, including the “Superintendents’ Roundtable,” and curriculum director, human resource director, and finance directors’ meetings. Melissa Green found the ISD curriculum directors’ group to be “most influential . . . they could put things in a nutshell and say this is what’s going to happen, and this is how it’s going to affect you.” Additional sources of information mentioned included print and electronic sources such as newsletters and websites through the US. Department of Education, MDE, and professional associations, including the Michigan Association of School Administrators, Michigan Association of Supervision and Curriculum Development, and Michigan School Business Officers, and the Michigan Education Association. It appeared there was no shortage of information about NCLB, readily available through various communication channels. According to Donald Cooper, the Superintendent, “You have to be asleep at the switch for a long time to not understand that this information is coming your way, whether it’s NCLB or any other mandated information.” The next layer of communication and assessment of NCLB requirements took place within F airview’s central office. The only administrator interviewed for this study who was working in an administrative position in Fairview when NCLB was first enacted is Melissa Green. She spent a great deal of time with her fellow administrators, stating the work involved just trying to dissect it down and figure out how it was going to affect [Fairview Community Schools]. And so it was a lot of ‘what ifs’ and ‘how comes’ and it was really helpfirl to work with our Financial Director, Title I Director, and our Superintendent [at the time], who was really 138 pretty good at hunting information down and playing the Devil’s Advocate and trying to see how we all fit in. She gave further details on working with the various Human Resource Directors, as “teacher certification and qualification is very integral,” and close collaboration with the Finance Director “doing the finances, because working hand-to-hand with the budget for the federal grants became very important.” Though district leadership shifted over the years, all administrators agreed communication with building administrators was initially disseminated through administrative meetings. Melissa Green recalled feeling overwhelmed by No Child Left Behind: “It was huge. You had to be J ohnny-on-the-Spot with everything that was happening. . . . [So] I got the administrative folks involved . . . because I needed more hands on deck. Some of them held supervisory roles,” such as direction of Title I, ELL, etc. Connor Simon, Fairview High School Associate Principal, previously an elementary principal when NCLB was enacted, noted the first task within the district was to “educate administrators about what it’s about.” In addition to participation in administrative meetings at which NCLB was discussed, he observed, “the primary source is probably the Director of Instruction and what . . . she provides to us on a very consistent basis.” Principals participating in the Focus Group concurred, indicating that once the first wave of communication from MDE and within the district was over, the most frequent communication came from the “curriculum director updates . . . she provides us with summarized information from meetings she attends.” Beyond communication with administrators, who would then sometimes address NCLB requirements with their building staffs, Melissa Green had structures for communicating with teacher groups, including “Curriculum Council,” comprised of K-12 139 curriculum chairs, and content area committees. Connor Simon also described communication with teachers “that’s developed across grade levels by virtue of the leadership team.” He shared district efforts to further develop the “knowledge base . . . over time . . . because once a mandate is put in place, there’s a lack of information initially.” He laughed wryly, stating “That’s sort of the change in the kind of thinking that, ‘Oh, my God!,”’ concluding, “It gets less and less scary over time, I think.” Administrators’ Implementation and Monitoring of NCLB Requirements After the initial phases of awareness, communication, and education within various levels of the district, Connor Simon reported a lot of the implementation decisions and guidelines were developed through committee, “in terms of just bringing policy recommendations onboard to the Board of Education, and then administrative regulations and rules . . . that really follow that process. Melissa Green noted You know the interesting thing about all of that is that the Superintendents have less and less of a role in it. It was much more up to the directors and then the principals for putting it all together. I found not only did both Superintendents that I work with have limited knowledge of all that it involved, but they did very little that’s implementation. This was confirmed by Dr. Cooper, who stated, “You know . . . I’m dependent upon you in your position, [Kathleen Peckham] in her position, and [Ronald Parsons] in his position . . . to, you know, be in a position where . . . we are receiving information appropriately,” and acting on it. He indicated he doesn’t really monitor implementation: “1 would say if there’s a glitch, I’m notified that we haven’t complied, we’re not doing what we need to do. I believe that would come to my attention. . . . Do I monitor closely? I think I monitor other pieces of our work more closely. I think that piece would probably have to be brought to my attention.” 140 Some nuances regarding district implementation also emerged, including how administrators understood NCLB requirements, how responsibilities for implementation were viewed, and marked inconsistencies in building implementation and monitoring. Understanding of requirements. Interview data revealed the knowledge base of both district and building administrators was uneven. Part of this may be attributed to specialization of jobs and retention of information pertinent to job responsibilities. For example, Ronald Parsons’ understanding was by his own admission limited to responsibilities relating to finance, such as set-aside budgets to develop highly qualified teachers, Consolidated Grant budgets, etc. In the Hmnan Resource Director’s view, she believes the “primary responsibility [for NCLB] has fallen in my court,” although a great deal of its requirements fall outside of her realm of responsibility, in the areas of curriculum, instruction, and assessment. Building level administrators also reported varying levels of knowledge of NCLB requirements. One Focus Group participant, an elementary principal with many years of experience, stated, “I’m a research buff, so I got copies of the legislation and read it myself.” Connor Simon also appeared to have significant knowledge, built up through multiple sources, including direct reading of the legislation, government and policy institution white papers, etc. In contrast, Lily Barnes, formerly a middle school associate principal, and an elementary principal of approximately one and a half years, laughed and stated bluntly, “I don’t really know what the requirements are. I mean, I couldn’t list them for you. It’s one of those things everybody talks about. . . . I mean, we know by 2014 everybody’s supposed to be proficient. You know, that’s about the extent of [my knowledge],” observing, “I haven’t felt a need” to understand the particulars of the 141 legislation. She further indicated she’s not sure whether it’s her fault that she lacks information, or the district’s responsibility to ensure she’s fully informed. Part of Ms. Barnes’ lack of understanding may be attributed to her relatively recent appointment as a school principal, well after NCLB’s passage and the initial waves of communication took place. Principals participating in the Focus Group noted it take time to understand NCLB. One principal commented, “I’m understanding it better the longer I have to work with it, and the more I’m responsible for parts of the mandates. Repeated exposure makes it more a part of your working knowledge.” Other principals concurred, stating it takes reflection time to “sit down and piece together the parts . . . [to understand] how they interact.” Furthermore, the commitment to learning about and understanding NCLB has developed over time, as well. Principals noted that for years, educators had the “common misconception that NCLB would go away,” especially once President Bush leaves office. People clinging to this belief may not have invested the kind of time needed to understand NCLB. Indeed, out of the administrators interviewed during the pilot study, only one appeared to understand that NCLB is actually the most recent iteration of the Elementary and Secondary Education Act, dating back to 1965. Responsibilities for implementation and monitoring. There were also differences in how individuals understood their responsibilities for NCLB implementation and monitoring. At central office, this was less often the case. When responsibilities were primarily assigned to one person, as with the highly qualified requirements and the Human Resource Director’s position, there was little confusion. For example, Ronald Parsons has an annual cycle of budgeting and reporting for Title I and other federal grants, and assigns responsibilities within his department and monitors task completion 142 accordingly. A principal who helps to coordinate Title 111, programs for English Language Learners, was able to articulate her responsibilities very clearly. Kathleen Peckham has a comprehensive system in place for documentation and periodic review of staff credentials. However, this sometimes meant the new work related to NCLB supplanted other work that administrators formerly used to define their professional responsibilities, as described by Melissa Green. I [thought] of myself as not so much doing curriculum as working on these mandates. . . . And you know, it was really interesting going to the Curriculum Directors’ meetings. I heard that song from every Curriculum Director—they were so overwhelmed, so overburdened, it was hard to delegate and make sure that things were happening, so it’s best do it yourself. And so all Curriculum Directors commiserated that they were having a hard time doing curriculum. She further noted that things like Sex Education or mathematics were put on the back burner. “I knew we had a problem with our math program. I could not, I did not have the time to really delve into the math program and get that underway, because of all the other that I was dealing with. That’s why it was up to you when you took over.” Even when people had assigned responsibilities, however, administrative follow- through was sometimes lacking. According to Melissa Green, “Sometimes things did slip through. It was not my intention, I just thought everybody knew they had certain responsibilities and they were supposed to do their job. It was pretty overwhelming to make sure, especially when you designate people to do certain things . . . because it didn’t always happen.” Furthermore, the more responsibilities needed to be shared and diffused across building leadership, the greater the disparities in understanding what that might involve. 143 The most comprehensive understanding of school leadership under NCLB, framed through the school improvement process, was expressed by Connor Simon. Understanding the data piece is probably the groundwork. . . . helping staff to understand what those strengths and weaknesses are. At the high school that is really more on a departmental level basis. Attaching that really to a school improvement process and establishing some pretty clear and concrete goals based on what the data tells us, and really having target goals and objectives that you’re working on in terms of improving student performance. Understanding the comprehensive law itself, what the mandates are in terms of No Child Left Behind and what we have to do by 2014, and what’s on the plate and what really needs to be brought to the front burner, and what are some back burner items that can wait. Kind of prioritizing what the work is going to be at a building level, disseminating that knowledge out, disseminating the work out because it really has to happen in the classrooms, and logistically trying to make those pieces come together. This level of understanding was not widely shared among other principals. A significant moment occurred during the Focus Group discussion. When asked, “What are your responsibilities with regard to No Child Left Behind?” there was a long, almost awkward silence. Responses were halting and slow in coming. When they did start offering ideas, there was an unspoken sense of relief, as if they were thinking, “Oh, so that’s what responsibility for NCLB involves in our roles.” Responses included, “articulating what it means to staff in practice, so they understand why we’re changing things and aligning things to federal requirements;” holding “discussion on why students aren’t achieving;” helping teachers to become “more comfortable with the data piece,” etc. One principal verbalized some frustration and discomfort with NCLB’s requirements: “When I think about the higher achieving students, I think they’re ok and so it’s not so much my problem to worry about them. . . . All children are going to succeed and grow, but there is a balance. Not all may be successful [according to NCLB]. But it’s not ok to say that.” In summary, it didn’t appear that all principals had 144 a clear understanding of what their responsibilities for implementing and monitoring NCLB requirements entailed. Inconsistent implementation and monitoring in schools. Given the discrepancies in principals’ understanding of NCLB requirements, not to mention their differing beliefs about what it means to implement and monitor in buildings, it was not surprising to find significant inconsistencies in how this was operationalized in buildings. The Focus Group principals did not share much information regarding implementation and monitoring, other than to comment on what they saw as a firndarnental shift in the role of the principal, from managerial to instructional leadership. In her interview, Lily Barnes shared her view of NCLB implementation in concrete, pragmatic terms, saying, “I have to help the teachers in the school understand they’re accountable . . . for the learning that goes on in the school.” She reported using various assessments, observations, and parent feedback to “encourage teachers to stick to the curriculum and teach what they’re supposed to be teaching . . . in a way that’s appropriate for all students.” Furthermore, while Connor Simon had clear, specific ideas about school level implementation and monitoring, he acknowledged having little time in his day for this type of leadership as a high school associate principal, saying about “80% of my [job] was probably student discipline, and then 20% was evaluation [and] parent communication.” He had more time for this work as an elementary principal. In discussing inconsistencies in principal monitoring under NCLB, he noted, “This profession has always been pretty frontierish,” which runs counter to the kind of “systemic, sustained, strategic implementation that’s very consistent from building-to- building” he believes is necessary for effective implementation. 145 Administrative Challenges and Conflicts A district with eight schools, approximately 227 teachers and 3,400 students, is likely to have some difficulties responding to reform-based legislation that shifts the locus of control from local districts to the federal government. In addition, with its accountability and compliance standards, it gives districts more work to do. Data fiom F airview illustrated a number of themes related to administrative challenges and conflicts that emerged as the district responded to NCLB, including early implementation and compliance issues, a lack of shared commitment and accountability, incongruence between NCLB’s purposes and implicit values and district and personal values, an inability to connect district work to the purposes of NCLB, and capacity and resource issues. Distracted by early implementation and compliance issues. As noted by Connie James, one of the External Partners in this study, NCLB contains somewhere between four to five hundred compliance standards. Through the lenses of various administrators, a picture formed of the district learning about NCLB requirements and then scrambling to get into compliance in multiple areas, according to external timelines. This was reflected in the Superintendent’s comments about implementation of NCLB. I believe I’m Superintendent of a school district that has implemented No Child Left Behind and . . .other mandates that we’re required to in a full, professional, comprehensive manner. And that would certainly be my position, and if something is — you know, askew, not, not in, in, in it’s proper place, I, I think I would know, and we would be very, we would be very invested in, in righting any wrong, but no, we would want to be, we would want to be a very professional, fully compliant school district in Fairview. No question about it. Melissa Green’s comments about her NCLB-related work speak to the kind of “comprehensive” compliance referred to by the Superintendent. She talked about 146 “dissecting down” the compliance standards section by section, and then constructing “flowcharts of what I had to do and at what times, because we were told that we were responsible, and the feds were, you know, watching, and the state is watching,” reflecting a sense shared by other administrators of increasingly external, highly public scrutiny brought about through NCLB. The kind of detailed work of checking teacher certifications, implementing required assessments, and responding to Consolidated Grant requirements and budgets ate up administrators’ time. In addition, it seemed the sheer volume of work involved in compliance not only changed the way administrators spent their time, but also had the paradoxical consequence of shifting district focus, at least temporarily, from student, classroom, building, and district performance, to external compliance indicators. Budget and administrative cuts meant fewer people were doing more work, and there was little time to focus on NCLB’s underlying purposes and meaning, let alone consider the kinds of changes it would require in district and classroom practices. It is also possible this deeper work was deferred, because administrators found it easier to focus on pragmatic compliance issues. Overall, as Dr. Cooper observed, “I listen to the frustrations [related to compliance issues], but bottom line, we will comply, we will do what the State Department . . . and the Federal Department of Education . . . has asked us to do.” However, he also noted, “We’re reactive too much and not proactive enough. . . . We are hustling and working so hard, we’re not taking time to think about the things that maybe we should be doing or want to be doing.” Thus, the “hustling” in response to compliance requirements has ironically appeared to inhibit effective response to NCLB’s core intents. 147 Who is accountable? In a previous section, discrepancies in administrators’ responses to NCLB were noted. Most educators would agree that achieving 100% student proficiency in English Language Arts, mathematics, science, and social studies is a daunting goal. If it could be easily achieved, it would have happened long ago, without NCLB. It stands to reason that such a goal may only be accomplished through significant changes in K-12 education. Given the educational system’s historical resistance to reform, it is apparent that the kind of change required cannot be effected without a great deal of collaborative work at all layers of the system, through collective commitment and shared responsibility. And yet, interview data indicates that Fairview has not yet defined what effective implementation and monitoring is needed to achieve NCLB goals, nor has it consistently operationalized this in buildings. It is also clear that while the district may comply with standards regarding teacher qualifications, student assessment, parent notification, etc., teachers continue to teach as they see fit and blame students who fail. Lily Barnes commented her teachers don’t appear to pay much attention to NCLB. They only care if it’s going to pinch them some way. If you’re going to change the curriculum without their input, because you don’t feel that it’s appropriate for addressing [the] benchmarks - then they care. But it’s not — you know, they’re totally devoid of any responsibility. I mean I’ve really been surprised at their response to — for instance MEAP data. There’s always excuses and rationale, and not often does someone say, ‘Boy, I really ought to look at my practice so I can help these kids be more successful at this.’ And I think that that’s the most difficult thing that an educational leader has to deal with, figuring out how to let them do all that rationalization and venting or whatever, and then kind of turning it around [to], ‘Okay, so now what can we do?’ She confirmed that some teachers still feel a sense of autonomy and permission “to do their own thing,” and while “We try not to make it easy [for them to do that], frankly, it 148 probably is.” While Connor Simon and others were more optimistic, saying “a vast majority of them are working toward those goals anyway,” Simon also sees the need to work more systemically, building “consensus” toward working more collaboratively and intentionally to support individual students. Incongruence between NCLB and district and professional values. Dr.Cooper asserted his belief that NCLB’s purposes are congruent with the Fairview’s values: “I think I’ve said publicly multiple times that it’s very challenging to argue with the spirit of No Child Left Behind. It’s a very appropriate spirit. Let’s make sure that all children learn.” However, he also recognizes the implicit tension between focusing on the needs of “the bottom half of our learners as opposed to our top half of our learners,” given the number of F airview parents who want “Gifted and Talented Education” for their children. The Finance Director verbalized similar sentiments, questioning whether NCLB is really “doable. . . . I understand it’s a lofty goal . . . but is it possible to do that? . . . Are we impacting other students by taking resources to those students that aren’t meeting expectations? Is that hindering other students?” Melissa Green disagreed that NCLB’s values were consistent with F airview’s, saying, “I think [it] dictated what our values were going to be, based on what was important for No Child Left Behind.” She went on to say, “Our district has always valued all students succeeding to a point . . . but [we] always put a lot of emphasis on the high ended kids, not so much the low.” In fact, a number of parents have complained there is not enough attention to the needs of high-achieving students, as represented in district meetings and in the Strategic Planning documents. They see federal and state mandates as externally imposed “threats.” 149 While Lily Barnes supported NCLB’s emphasis on achievement of all students, she doesn’t believe the legislation is congruent with the district’s values. She is frustrated, “because we haven’t recognized yet that we’re going to have to start working for that group that is not progressing.” She observes the district’s pattern as “kind of coasting along, because our assessments are fairly decent, and we have a population that does fairly well, but . . . we’re going to hit the ceiling pretty soon, and then all of a sudden we’re going to be in a panic.” She also doesn’t see any increased interest in addressing the needs of lower-achieving students, commenting, “I don’t know if that has to do with a fear of not knowing what to do, so if you ignore it, it will go away, or if it’s an unrealistic sense that we’ll come out okay anyway—or even, and I’ve thought this in the back of mind—we’re going to have to change that.” Lily Barnes also struggles with doubts. Specifically, she questioned NCLB’s lack of consideration for “special education kids and kids with learning styles and differences that just aren’t going to progress at the same speed, in the same manner as the expectation is. So how much pressure are we putting on kids? What impact does that have on their education?” Melissa Green also spoke to concerns about the amount of student assessment and the incomplete picture of student achievement resulting from overreliance on standardized assessments, saying, “Tell me how all the testing we do to a child helps the teacher teach better or the child learn? . . . So all this money is being poured into MEAP testing and the Iowa testing, and for what good?” She questions whether the “lofty” goals of NCLB can ever be achieved, given the focus on student measurement, without sufficient allocation of resources to actually ensure student achievement. 150 In fact, the consequences of increased academic rigor and performance expectations, a core intent of NCLB, were a concern raised by many of Fairview’s administrators. Focus Group participants talked about decreased attention to developing the “whole child,” including character education, arts education, health and physical education, recess time, etc. They see increased academic expectations as “squeezing out” time spent in other valued areas. Finally, while educators can hardly argue with the ideal of universal academic proficiency, the question remains whether F airview administrators and teachers believe that all children can achieve according to standards. This was not directly assessed in the interviews or document review; however, it is apparent that if educators do not believe that all children can achieve basic proficiency levels, getting them to accept and work toward NCLB’s basic premises may be very difficult to do. Making meaning of mandates. It would seem that the most fertile context for NCLB to flourish in would be a district that sees it as a route toward its most basic aims. Thus, a district that connects the underlying purposes and values of NCLB to its own work may find the implementation smoother and less onerous. There is insufficient evidence to support a picture of Fairview as a district that has effectively harnessed NCLB as a tool for district improvement. While the Strategic Plan reflected significant effort to unify the district in identifying and working toward goals that seamlessly connect to NCLB’s aims, the Operational Plan is in its infancy. Enough inconsistencies exist in the understanding, implementation, and monitoring of NCLB to cast doubt about F airview’s efforts thus far to create a sense of meaning around it. Lily Barnes commented, “The Director of Curriculum and Instruction 15] is probably the main person” talking about NCLB, but “quite frankly, there’s nobody else that brings it up. It doesn’t appear to me to be a driving force for change in our district.” And as Connor Simon explained, NCLB is “really nothing more than a framework of improving student performance over time.” However, since transitioning to his role at the high school, he has seen the school improvement process as effectively stalled. Capacity and resource issues. Among those interviewed for the pilot study, there was unanimous agreement that achieving NCLB’s goals will require more resources than Fairview currently has. While Connor Simon believes most teachers accept the rhetoric that all children can learn, he commented, “Where we get hung up is, are the resources there to support that kind of mandate? . . . To break learning down for some kids that need that one-on-one instruction? . . . That kind of gets in teachers’ minds and they . . . certainly get frustrated with it. . . . Some of it is how we allocate resources; some of it is just purely we don’t have the resources.” Educators’ ideas abound to improve student learning, as Simon observed, but the funds are not there to implement student support programs. Ronald Parsons summarized Fairview’s years-long period of budget deficits, noting increased federal and state mandates, paired with cuts in personnel, have reduced administrative capacity to deal with increased workloads. Dr. Cooper concurred, stating, “Resources are lacking in our work . . . and there is no question that the expectations are higher than ever.” Fairview ’s Response to PA 165-166 As described in the External Context section, which summarizes the legislative mandates included in this study, Michigan’s sex education legislation, PA 165-166, has different purposes, highly specific and prescriptive requirements, and different 152 accountability structures and mechanisms. Data from interviews and documents reveals F airview’s responses to PA 165-166, including an initial flurry of work on compliance issues; conflicts during the implementation process; conflicts between PA 165-166 values and directives in opposition to district values and practices; and a laissez-faire attitude toward monitoring and accountability. Initial Compliance Work PA 165-166 was enacted in 2004, changing many aspects of sex education implementation, including an increased role for parents, greater restrictions on districts choosing to go beyond HIV instruction to teach sex education to its youth, and increased accountability requirements. The administrator primarily assigned to implement PA 165- 166 was Melissa Green, then Director of Educational Services. Prior to PA 165-166, she reported responsibility for sex education was assigned to the special education director, who had “one heck of a great nurse” who assumed most of the operational responsibilities. Upon her retirement, the district cutback on nurses, and it fell to the special education director to oversee, and when they “decided they didn’t want to have anything more to do with it . . . it was shifted into my office area.” Melissa Green pulled together an elementary and high school curriculum chair to attend meetings with her on the new legislation. She also had a principal who had some responsibilities in working with the Sex Education Advisory Board (the parent and district committee tasked with making sex education related recommendations for the Board of Education). She reported the work with bringing the district into compliance, and having “the organizational meetings with the masses of the community and the teachers and all the 153 students and everything and to make sure that all the materials have their viewings . . . was pretty mammoth.” Melissa’s work involved collaboration with other administrators and curriculum chairs, but the collaboration was not always effective. Early on, there was little involvement of other central office administrators, as there were few issues related to finance or human resources. In addition, the elementary principal who was initially assisting her “was trying to pull out of [it]. She found that it was a lot of work.” And while she was aided by a parent co-chair, who helped with organization of the Sex Education Advisory Board, she couldn’t rely on the curriculum chairs, particularly the elementary chair, who “was released for an hour to work on sex ed, but she didn’t do that much, so it was pretty tough.” Her overall tasks included working with the curriculum chairs to realign curriculum; reviewing teachers’ records to make sure all teachers had the appropriate training to teach HIV and sex education, compiling related documentation in a permanent record for the district; ensuring the Sex Education Advisory Board had the required membership of at least 50% parents, a community health practitioner and clergy member, teachers and administrators, and received formal Board approval; viewing and approving materials through the advisory board; and filing appropriate documents and reports with the ISD and MDE. Melissa generally felt overwhehned by the work, reporting, “The other Curriculum Directors hated sex ed, too. They can’t get to it all.” In fact, the Superintendent verbalized his belief that “sex education [is] peripheral, yet very important . . . but I think it strays a little bit from our core.” This belief resonated with many other administrators, influencing Fairview’s implementation of sex education instruction. Melissa Green also felt NCLB was more important, so this 154 is where she concentrated her energies. She further believed the comprehensive health model, which districts are advised to use as the umbrella for sex education implementation, was far too big for her to handle. When that all really came down . . . about the year before you took over, there was a lot to do, but see I had neglected it in the past [because of] NCLB. You’re probably finding it high right now because what I saw coming down, making this huge committee and all these little - I remember drawing this on the board — all these little committees, these offshoot committees that were going to be under this big umbrella, was absolutely overwhelming. That’s when I said, ‘Good luck to you, Kellie.’ You inherited a mess with that. Conflicts during Implementation The transition of leadership for sex education from Melissa Green to me was not particularly smooth. The first meeting with the Sex Education Advisory Board revealed many parent members had dropped out; the physician on the committee came to the meeting to resign, furious over what she perceived as the previous year’s mishandling of Advisory Board meetings by my predecessor; one curriculum chair announced she would no longer be on the committee, due to her responsibilities for directing a new grant she’d received for the district; the elementary chair attempted to abdicate responsibilities for participation to someone else at the high school; and the elementary principal begged to get off the committee due to newly assigned responsibilities for Title III; with the net result of a handfirl of people showing up, unsure of how to fix the problems. We floundered along throughout 2005-O6, viewing and approving videos and curricula. In the fall of 2006, we arranged for a consultant who contracts with MDE to provide technical assistance for districts struggling with their Advisory Boards, to come in and advise us on how to implement a more effective process with this group. She and I met with the elementary curriculum chair and parent co-chair for an entire afternoon. 155 She brought a three inch binder stuffed with information on the requirements of PA 165- 166 and best practice literature for implementing sex education effectively. In addition, she came to our first Advisory Board meeting in October, 2006, presenting a PowerPoint on the group’s responsibilities, emphasizing their role in representing the community’s preferences, rather than their own personal agendas. In accordance with her recommendations, the district surveyed classroom teachers responsible for teaching sex education to gather information about current practices and fidelity to the curriculum. We also conducted a parent and community survey, offered online as well as in hard copies. Following a three month response period and a total response rate representing 13% of F airview parents, I hired our parent co-chair to analyze and report the findings. She found overall alignment between topics taught at grade levels, per the curriculum, and what parents expressed they believed to be important, with some topics taught a year earlier than parents would have liked. However, the survey findings spawned further controversy within the Advisory Board, who were not all in agreement with the preferences expressed by parents and community members. One person wanted to personally conduct focus groups with parents, hoping to either invalidate survey findings, or to change parents’ minds about when instruction should take place, using research and education to demonstrate why their preferences should change. Despite my assertions about the inappropriateness for Advisory Board members assuming this role, and the lack of district resources for investing further time in ascertaining community views, a couple of members succeeded in detailing group process. Between the liberal, young doctoral student and “birth doula,” joined by a local gynecologist and a women’s health practitioner, and our more 156 conservative parents, joined by our clergy member, the meeting was ineffective and did not reach resolution. It took another call to our consultant, and subsequent feedback to the committee, to hammer home the message that F airview had, in fact, done far more than most districts to assess community values and preferences, that the survey had been used with good effect in other districts across the state, and that it would not be appropriate for Advisory Board members to conduct focus groups in Fairview. Further problems at the committee level ensued when MDE announced new rules regarding teacher qualifications for sex education, resulting in mid-year discovery that our middle school science teachers no longer met the requirements. Our middle school teacher representative succeeded in stirring up the committee again when she announced there was no room in the science curriculum to teach reproductive health, they already had too many science standards and benchmarks to address sex education, and that the middle school students were suffering in a variety of ways as a result. This created a hullabaloo amongst committee members, who demanded to know what I would do to “fix” the situation. In working with our Human Resources Director, we decided to hire a sub for one of the high school physical education teachers, so she could teach sex education for two weeks in the middle school science classes. The teacher was enraged by this decision, called a lawyer from MEA whom we all then met with, and in the middle of the turmoil, as we were placing calls to MDE to see if there were other options we hadn’t considered, we learned we could file for a one year waiver to have our science teachers continue to teach sex education. However, the damage in labor relations had been done. Another lower seniority PE teacher in an 80% assignment at the high school, believing he should 157 have been offered a full-time, year long assignment at the middle school at the beginning of the year, succeeded in winning a grievance settlement from the district over this situation. The district ended up paying him $8,000 in back pay, plus benefits. In the meantime, the Advisory Board continues to be frustrated over programmatic issues. They expressed a desire to work directly with classroom teachers to realign the curriculum and improve classroom practices. The teachers have verbalized their disinterest in having this level of parent involvement in their work. Using a different stratagem, during the August, 2007 professional development days prior to the start of the school year, I brought in a consultant to work with sixth grade teachers to examine teacher and parent survey results, the legal requirements of PA 165-166, including the “A to K” requirements, and to further identify current practices and how to work toward needed improvements. This session took place while I was in a full day of professional development with K-S teachers on our new math program. According to the consultant and principals’ reports afterward, the meeting was fiaught with anger and tension over what teachers regarded as an intrusion into their work. It was clear classroom teachers either wanted to be left alone to continue their practices unquestioned, or to have their responsibilities for teaching sex education completely shifted to the physical education teachers. Conflicts between PA 1 65-1 66 and F airview Values and Practices Interview and focus group data demonstrates administrators’ confusion over what the district should do about sex education in response to PA 165-166. Melissa Green reported she felt primarily responsible for trying to comply with PA 165-166, but didn’t express particular value conflicts. To a person, however, the other administrators 158 verbalized uncertainty about whether the district should invest its energies in this area. The elementary principal who used to sit on the Sex Education Advisory Board felt the legislation was “almost scary.” She concluded, “There is a part of me that says maybe we should get out of the business of sex ed, because there’s a very fine tightrope we have to walk between the mandates and what we have to do to be in compliance. . . . It’s not always educationally best practice.” Connor Simon agreed, saying, “Sometimes I wish it would just go to parents and leave it there, get it off our table, it’s an unnecessary evil and in other ways I see it as an absolute: we have to inform and educate kids about it.” Principals participating in the Focus Group agreed that implementing sex education is tricky. One principal stated, “I disagree a lot with the legislation. It puts teachers in a precarious position. . . . It can be a real trap, and I watch every word I say. I think it’s far beyond what teachers should have to be responsible for.” Others expressed frustration over constraints in sharing “honest information . . . You can’t even give high school students a phone card to call Planned Parenthood.” Another stated, “I really have concerns about how we’ve watered down what it is we can share.” She noted that beyond grades five and six, when students “really need to start asking questions about their own sexuality of adults they trust,” PA 165-166 makes teachers “fearful” of open discussion. One K-4 principal commented, “I worry about it every spring, and whether there will be questions that will come to me about how it’s been taught, and whether teachers or parents perceive there are problems.” Lily Barnes echoed these sentiments, commenting Frankly, I’d say kick it out of school. I just think it’s, and not because it isn’t important and not because kids shouldn’t know about HIV and you know all of that stuff, but because I think that that’s something that they can get the resources for in other places. It just doesn’t seem like it should 159 be a part of school anymore. Not for moral reasons but for academic reasons. In addition, the rules and regulations related to PA 165-166 change, and communication is not as thorough or timely as with NCLB. As reported earlier, new rules on teacher qualifications are a barrier to implementation, as described by Kathleen Peckham, HR Director: Now we’re given this new mandate that teachers have to be certified and re-qualified in this area which would be science, and/or perhaps health, to be able to teach the Sex Ed. And it might cost the district money to either put those staff through training and/or testing to make them qualified and knowledgeable to teach it, or put a district in a position where you have to hire additional staff, because you don’t have current staff that are qualified now based under the new regulations to teach it. And I don’t think that they think about that, and when I say roadblock, that’s what I mean. They don’t think about the ramifications of what they’re putting a district in position-wise when they make the changes. The roadblock has not been fully addressed in F airview as of this writing. The district is considering establishing a new requirement for health and physical education in eighth grade, currently not required until high school. This would allow students high school credit, and allow the district to transfer qualified staff to teach sex education to the middle school, but this change has to go through the Board approval process. In the meantime, the district is trying to resolve how sex education at middle school will be taught this year. Kathleen Peckham and I have been in communication with MDE to see what the district might do, as we cannot get another waiver for science teachers to teach sex education. In a recent e-mail received from a representative from MDE, following several previous exchanges, we discovered we can skirt the qualification requirements by obtaining substitute teacher permits for our science teachers to teach sex education: Okay, I think I now have enough information to know there is no easy resolution. The MDE will not issue you a full-year or emergency permit 160 for a two week assignment. The consultants in the Health Education unit state that the reproductive education law requires a qualified health teacher to teach the class, which you do not have at present. So here is my suggestion, obtain a day-to-day (180) substitute permit (for each) for the two weeks that these two will be teaching the reproductive health section of science and you will be covered. If the teachers teach the biology of reproduction as the principal topic then you will be fine without a permit, but if they get into decision-making a permit will be needed. A firrther e-mail exchange confirmed the details; Fairview plans to secure two l80-day substitute teacher permits through the ISD, paying all related fees, allowing the science teachers to teach reproductive health. As this evidence demonstrates, it takes significant persistence to figure out how to address roadblocks, which places additional stress on district resources. Finally, it is apparent that despite PA 165-166’s specificity about what can and cannot be taught, principals report teachers continue to develop their own lessons, despite prepackaged curricula and materials that have been approved by the Sex Education Advisory Board and F airview’s Board of Education. Principals know it goes on, but have difficulty monitoring classroom implementation closely, so they “worry every spring” about whether there will be problems when sex education units are taught. A Laissez-faire Approach to Monitoring and Accountability Despite principals’ anxieties about how sex education is implemented in their buildings, they are rather laissez-faire in monitoring it. One exception is an elementary principal who co-teaches the lessons to fourth grade students in her K-4 building. The other K-4 principals do not monitor closely at all. Lily Barnes acknowledged she does not monitor sex education as she does the core curriculum, stating, “It’s such a miniscule part of our curriculum, when you consider all the curriculum that we’re teaching, that it 161 can be easily dismissed.” In addition, reproductive health begins at fourth grade, so this limits how much is taught in her K-4 building, which she describes as a “brief introduction to the pieces and the parts.” When asked whether she believed PA 165-166 requirements are implemented with fidelity across the district, as she has also worked at middle and high school, she responded, “No, absolutely not. . . . I’m sure that they are developing their own lessons and doing their own thing.” Connor Simon does not monitor sex education at the high school, as this is not one of the areas assigned to him, so is unsure of whether actual monitoring takes place. The Focus Group principals were unclear about how to monitor implementation, other than making sure parents have an annual opportunity to view curricula and materials. One of them mentioned she might see it in teachers’ lesson books, but there is a definite sense that principals would like to close the door on sex education and not have to think about it. As far as classroom accountability for complying with PA 165-166 requirements, there is little substantive “checking” on what teachers actually do. Teachers are asked to log Michigan Model lessons taught into an online data base, with reports submitted to the ISD and MDE, but beyond this, there is little reporting of what takes place. The only other avenue the district would have to know whether there are classroom concerns or issues would be through the parent complaint process. Parent complaints occasionally reach my level. They tend to stem from a parent disagreeing with a particular video or speaker that has already been approved by the Sex Education Advisory Board and Board of Education. I listen to their concerns and gather information from them, as well as the teachers involved. These situations have not resulted in any findings, as yet, to demonstrate that classroom practice violates PA 165-166 requirements and Board 162 approved practices. I remind parents they are free to “opt their student out” of sex education. Thus far, I have not had any complaints that have been taken to the next level in the complaint process, which is a formal complaint filed by parents with the ISD. Summary of Themes in F airview ’s Response to Legislative Mandates There were both similarities and differences in F airview’s responses to NCLB and PA 165-I66. Passage of both legislative mandates initiated a period of information gathering, discussion, and decisionmaking about district implementation. Early on, this resulted in a great deal of administrator time to assess and implement locally, involved more collaboration between administrators, and later teachers and other stakeholders. Both mandates induced a period of preoccupation with compliance requirements. With NCLB in particular, administrators’ understanding of its requirements varied significantly. Given the complexity of its various components and requirements, administrators indicated it took a lot of time to understand and feel comfortable in their knowledge base. PA 165-166 was more prescriptive, and they found it easier to digest. However, they also found it easier to dismiss PA 165-166, overall preferring to limit the scope of their school’s work to traditional academics. The increased standards and expectations under NCLB also seemed more intertwined with the core purposes of schooling, not something they could easily “get off the table.” Furthermore, they expressed significantly more value conflicts with PA 165-166 than with NCLB. For both mandates, while the Superintendent represented that the district is fully compliant with all of the requirements of both NCLB and PA 165-166, it is clear that this is not the case. There was a greater sense of collective concern and effort to comply with NCLB, but basic compliance does not ensure NCLB’s mandated results. Moreover, it 163 appeared administrators were not particularly certain how to monitor building implementation of NCLB. While F airview appears to have met most compliance requirements, it has not yet managed to leverage NCLB as “a driving force for change in the district.” The district does not appear to have created meaning out of NCLB to enable it to further its own goals. Further research in the district after another five years might reveal the district has made greater inroads in changing deeply held beliefs and core practices. Finally, the stories of Fairview’s responses to NCLB and PA 165-166 are very different because the stakeholders are different. The chief stakeholder for NCLB is the federal government, and while there may be concerns about various aspects, as Donald Connor noted, it’s hard to argue about the spirit of ensuring academic proficiency for all students. The consequences for noncompliance with NCLB are better known and much more public than for PA 165-166; if nothing else, it is known for its accountability structures. Through passage of PA 165-166, the state has ensured parents have a significantly larger voice in local decisionmaking about sex education. It is a system more vulnerable to the exercise of special interests. The Case Study: Steele’s Responses to Federal and State Legislative Mandates The general characteristics of Steele Public Schools and the local context were provided in a previous section describing the settings for the pilot and case studies. As with the pilot study in Fairview, when interview data and documentation from Steele was collected and analyzed, the data illustrated unique, local factors contributing to its responses to NCLB and PA 165-166. In addition, data is presented and analyzed to examine specific themes and patterns in Steele’s response to NCLB and PA 165-166. 164 Finally, I summarize themes to explain Steele’s responses to NCLB and PA 165-166 and how their responses to the legislative mandates differ. Local Factors Contributing to Steele’s Responses to Legislative Mandates A number of local factors have contributed to Steele’s responses to NCLB and PA 165-166, including significant reductions in leadership positions since 1999; redefined responsibilities within key administrative and support positions; a pattern of decreasing district revenues, as well as changes in available grant funds and rules governing their use; and Steele’s collective sense of needing to address relatively low student achievement, while battling a reportedly poor public reputation. These contributing factors will be described in detail. Reductions in Leadership Positions As noted by Douglas Edmonds, Steele’s Superintendent for the past nine years, Steele has eliminated a significant number of leadership positions, confirmed by review of organizational charts and records from the late 19908 to present. Mr. Edmonds quantified this as “twenty-five percent of our administrative team over the last five years.” He also noted that while “the amount has declined, the quality has increased,” reflecting increased expectations and better professional development for administrators. Table 4 outlines the changes in Steele’s administrative positions and responsibilities over time. In the five major categories of leadership within the district, all have experienced reductions, including the Superintendent’s Office, the Department of Finance and Operations, the Department of Student Achievement, the Human Resources Office, and building administrator positions. The Superintendent’s Office has included two administrative level positions at separate times, both of which have been eliminated, 165 including a Project Coordinator who provided oversight for high school renovations made possible by passage of a bond in 2004, and a Director of the Educational Foundation, who in addition to fulfilling public relations functions, also worked on personnel and labor relations issues, interfacing with the Human Resources Office. The Department of Finance and Operations lost one administrative position in the Transportation Office, as well as the Director of the Educational Service Center, while adding a Data Systems Analyst in response to computerization of student records. Arguably the most affected categories, presumably with the highest correlation to the legislative mandates in this study, the Department of Student Achievement and building administrator positions, have experienced the largest cuts. The Department of Student Achievement has lost three full time positions, Director of Elementary Education, Director of State and Federal Programs and Grants, and Director of Title I, as well as a partial position, Director of Early Childhood Education. In the area of school leadership, all three elementary associate principal positions were eliminated. Despite reductions in administrative positions, there is significant stability within key leadership positions over the period studied. The reductions have mostly been handled through retirement and reassignment to other administrative positions. In addition, many cabinet level positions have been occupied by the same person since 1999, with the exception of the Assistant Superintendent for Student Achievement, joining Steele in 2001 , and the Executive Director of Human Resources, who recently left to accept a position in another district. The turnover in school leadership has been more significant, with retirement and reassignment of several individuals, along with a couple of principals resigning to accept positions in other districts. 166 Table 4. Changes in Steele’s administrative positions and responsibilities, late 19903-2007. Original Central Office Central Office Positions in Current Status/Changes Over Positions, 1999 or earlier 2005 Time I Superintendent I Superintendent (1999) I Same Superintendent I Steele Educational Foundation I Project Coordinator I Each specialized position as Director (Personnel/Labor (oversight for high noted in 1999 and 2005 Relations/Public Relations) school bond issue) eliminated Deputy Superintendent for Deputy Superintendent of I Same person in position—23 Finance Finance years I Supervisor of Financial Services I Director of Transportation V Supervisor of Transportation I Director of Technology V Dir. of Educational Service Center I Director of Operations V Supervisor of Operations I Asst. Director of Financial Services I Supervisor of Transportation I Director of Technology V Data Systems Analyst I Director of Operations V Asst. Director of Asst. Director same person since 1999 Dir. of Trans., same person as 1999; one position cut Same Dir. of Tech. Data Systems Analyst added due to computerized records Retirement of D00, D00 is former Proj. Coord. Operations I Asst. is a new person Assistant Superintendent of Assistant Superintendent I Asst. Supt—3 shifts; original, Student Programming for Student Achievement interim, to current person Director of Elem. Education Dir. of State & Fed Programs/Grants Director of Title I Non-administrative positions V Admin. Assistant V Instructional Specialist V Instructional Specialist V Health & Human Services Coordinator (Sex Ed Supervisor) I Non-administrative positions V NCLB Compliance Coord. V Director of Grants/Instruc. Specialist V Testing Coordinator/ Instruc. Specialist V Health & Human Services Coord. (Sex Ed Sup) Elimination of 3 Directors: El. Ed., State/Fed. Programs, & Title I (assigned to Elem. Principal) Restructured non-admin. responsibilities: V New person in 2001; oversees NCLB V State/Fed. Grants shifted here (same person) V District wide testing coord. assigned here (same person) V Same person 167 Table 4 (cont’d.). I Director of Student Support Services V Asst. Director of Sp. Ed., Elem. V Asst. Director of Sp. Ed., Secon. I Director of Alternative and Community Education I Director of Early Childhood I Director of Student Services & Early Childhood V Asst. Director of Sp. Ed., Elem. V Asst. Director of Sp. Ed., Secon. I Director of Alternative and Community Education I Director of Athletics I Same person, added responsibilities for Early Childhood, Gifted & Talented V Same persons at both Elem. and Secon. I Same person I Elimination of Dir. of Early Childhood; add district wide Dir. of Ath. Executive Director of Personnel & Labor Relations Executive Director of Human Resources I 2 different people, plus current Interim ED Principals (14) I Associate Principals (9) Principals (13) One elimination due to school closure - I Associate Principals (6) I Reduction of 3 APs in large elem. Schools I Principals assigned additional responsibilities, i.e., Title 1, District Annual Report Redefined Responsibilities Elimination of positions and changing needs in the district resulted in new responsibilities assigned to remaining positions. This affected all levels, including the Superintendent. As Bob Hilliard, Steele’s Deputy Superintendent of Finance and Operations for the past twenty-three years noted, “I think the Superintendent wears more hats these days than probably they did ten years ago.” Generally, these responsibilities have been absorbed by cabinet-level administrators, or reassigned by them to other people within the department. In the Department of Student Achievement, the Assistant Superintendent assumed oversight of Elementary Education, and State and Federal Programs and Grants, including Title I, with the Director of Student Services charged 168 with leadership for Early Childhood and Gifted and Talented Education. Similarly, in the Department of Finance and Operations, two administrative positions in Transportation were collapsed into one. One head principal position was eliminated due to closure of an elementary building. Elimination of associate principals in three elementaries meant that those principals simply had a great deal more work as the sole administrators of large schools with enrollments ranging from 817 to 561 students. In addition, positions within the Department of Student Achievement were redefined to focus on responsibilities directly related to NCLB and student achievement. The Assistant Superintendent’s administrative assistant, Maxine Higgins, has assumed the title of “NCLB Compliance Coordinator,” overseeing many issues related to appropriate spending of Consolidated Grant Funds, teacher certification and endorsement requirements under NCLB’s highly qualified standards (reassigned from the Human Resources Office), issues related to district and building AYP, parent notifications, as well as “a ton of different duties [my supervisor] deposits on me.” The Director of Grants/Instructional Specialist, Wanda Peasley, took on responsibility for grants when the cabinet-level position was eliminated, and assumed responsibilities for programs falling under NCLB including the Twenty-First Century Community Learning Center grant (designed to provide after school learning opportunities in a safe, drug-free environment), Reading First (designed to improve reading achievement for students in grades three and under), and coordination of the Homeless program. The Testing Coordinator/ Instructional Specialist position was redefined to encompass all NCLB mandated tests, including state tests and other standardized assessments. Even the title of Assistant Superintendent was changed from “Assistant Superintendent of Student Programming” to 169 “Assistant Superintendent for Student Achievement.” In fact, NCLB has redefined the role of the Assistant Superintendent, who indicated “75-80% of my job is Title I or NCLB.” Finally, the district has tried, with varying levels of success, to either hire new staff or reassign responsibilities to building administrators. According to Douglas Edmonds, “We had a position we tried to keep creating which would help monitor the progress of students and work especially on . . . [Section 504] issues . . . . But when you’re in the budget cutting, it really gets you,” so hiring new staff has not proved feasible. Assigning responsibilities at the building level hasn’t always worked either; due to issues with assessment coordination at the high school, all standardized state and district assessments are handled through the Testing Coordinator in central office. Mr. Edmonds holds greater hopes about his current plan to reassign Title I responsibilities for the 2007-08 school year, with oversight from the Assistant Superintendent and Director of Support Services, to an elementary principal of a small school of approximately 175 students. The principal will receive a “stipend to help us do that” through Title I funds. He is also considering assigning another principal to share Title I responsibilities. In addition, time-limited responsibilities such as completion of the District Annual Report are sometimes assigned to building principals, with teachers providing building coverage for them two to three afternoons a week so they can work at Central Ofiice. Between administrative reductions at the cabinet level and in schools, and restructuring of administrative responsibilities through various methods, it is clear Steele administrators continue their efforts to respond to increasing workloads and assumption of new responsibilities. These changes have influenced Steele’s response to NCLB and 170 PA 165-166, both in terms of administrative time to respond to legislative requirements, as well as the expertise to do so effectively. Decreasing District Revenues and Changes in Grant Funds The most notable source of decreasing revenues, according to Deputy Superintendent Hilliard, is declining enrollment. According to Standard and Poor’s, Steele’s enrollment decreased by nearly 500 students from 2001-2005, which represents a loss of approximately seven percent of its students. This has resulted in a school closure and reduction of administrative and support positions. He noted In terms of personnel, I feel we’re understaffed not just in the Administration Building, but throughout the district. . . . If we had more dollars, how would we spend them? That’s hard to say, but if there was another person, a compliance coordinator or something, I think [it] would go a long way in meeting some of those mandates and ensuring that we’re in compliance. In addition, the district has experienced changes in available grant funds. According to Wanda Peasley, Director of Grants, the Reading First grant, “due to some unfortunate circumstances . . . was pulled from us, which was very disturbing to me, because it was to help the children who really were struggling in the area of literacy, for reading.” She saw this grant as critical in ensuring students are able to read and for the district to meet proficiency targets, so is concerned about how loss of these funds will affect student achievement. Further, as noted by Ruth Hughes, Assistant Superintendent, the district was informed they could no longer use Title I funds in 2007-08 for “supplemental services” such as school nurses and social workers. Flexible use of Title I funds for supplemental services has been allowed for schoolwide Title I programs for many years, so she was especially frustrated to hear this will no longer be approved by MDE. She sees this change as extremely detrimental to the district’s ability to meet 171 children’s basic needs, particularly given their high percentage of economically disadvantaged students. She does not see these services as something the district will be able to provide without grant funds. Both decreasing revenue due to declining enrollment, and either loss of grant funds or more restrictions on how they’re spent, has influenced and will likely continue to influence Steele’s responses to NCLB and PA 165-166. Low Student Achievement and Poor Public Reputation Several individuals referred to Steele’s low, albeit improving, student achievement data and poor public reputation in the community, both during the formal interviews and in casual conversation afterwards. Douglas Edmonds discussed community frustrations and pressure routed through the Board and various community members. He proudly recounted the improved achievement scores and how committed he is to ensuring they continue to improve, as did the Assistant Superintendent and some of her staff, but there was general acknowledgement they believe student achievement is not where they would like to see it. In addition, as noted by the district nurse responsible for implementation of PA 165-166, while she believes Steele “is doing a lot of really great things . . . our reputation hasn’t always followed,” so to publicly acknowledge when there are problems invites additional criticism and scrutiny. As will be demonstrated in more depth in the next sections, the traditionally low student achievement and graduation rates, along with public pressure and scrutiny, have created varying responses to NCLB, in particular among Steele’s educators. Some educators have blamed poor student achievement on community ills such as a high rate of poverty and less educated parents. In fact, documented data might lead one to conclude 172 these are significant issues for Steele. Standard and Poor’s data from 2005 indicates Steele’s percentage of economically disadvantaged students is 64%, significantly higher than the state average of 34.7% and the county average of 38.3%. In addition, the community is less educated than the state average, with 84% of adults possessing a high school diploma, and only 17.9% with at least a bachelor’s degree. It is also noted in MDE’s “Focused Monitoring Report” on Steele’s website, which cites the “larger than average number of families” with “economic challenges,” inadequate “resources to provide academic supports at home,” and a “high rate of mobility, both within and into the district” (Appendix E). These difficulties were discussed by several administrators, including Nila Taylor, Director of Student Support Services, who shared her efforts to “teach the parents of our students . . . many of whom don’t read.” These difficulties provoke varying responses in Steele. As Ruth Hughes observed, when she first started talking with teachers about the achievement gaps between student subgroups, “They looked at me like, ‘Yeah, so?’ That was their attitude. . . . ‘We can’t teach those kids, those kids come from families where they don’t get the proper support they need.”’ While she believes attitudes are changing, other people interviewed for this study, including the Director of Student Support Services and the Director of Grants, believe these attitudes persist in a significant number of Steele’s teachers. In contrast, there also appear to be educators who have responded to NCLB and local achievement gaps with a sense of urgency. They see what is at stake for students who are failing, as well as the specter of failure for schools who do not make AYP, and want to be a part of changing student achievement outcomes. This was generally the attitude expressed by most of Steele’s administrators. 173 Thus, Steele’s history of low student achievement, paired with community discontent and pressure, has influenced its response to legislative mandates. The impact of local factors contributing to Steele’s responses to NCLB and PA 165-166 are reflected in the next sections. Steele’s Response to NCLB General factors unique to Steele’s context contributed to its response to NCLB. Further data emerged from interviews and district documents to demonstrate in depth how Steele responded, including what they did to develop their knowledge base and assess NCLB’s requirements, how administrators manage district implementation and monitoring, as well as administrative challenges and conflicts experienced in response to NCLB. Developing a Knowledge Base and Assessing NCLB Requirements As Superintendent since 1999, Douglas Edmonds was established in Steele before NCLB was enacted. He partly sees his role as putting district “systems” in place to respond to federal and state legislation and monitor district implementation. He receives information about legislative mandates through three primary channels of communication: the legislative documents themselves, Middle Cities Education Association (a consortium designed to advocate for and serve urban districts), and meetings with external partners and Steele administrators. While he finds the documents themselves to be quite lengthy, he describes the legislative update disseminated weekly through Middle Cities to be an invaluable, timely source of information. Monthly Superintendents’ meetings through ISD provided significant opportunities to share and discuss information. He also described the Director of Student Support Services and 174 Assistant Superintendent for Student Achievement as “very knowledgeable,” and depends on them for information and recommendations related to NCLB. He acknowledged, “I wouldn’t say I knew the details, but I was always in a general sense involved in the movement” of gathering information and promoting district discussion of legislative mandates. In particular, the Assistant Superintendent, Ruth Hughes, has played a pivotal role in bringing NCLB information to Steele. As a former MDE Office of Field Services consultant, with Steele as one of the districts she serviced, she came to the district with significant content knowledge on NCLB. I was with MDE when this came into being . . . from ’92 through 2002, and so as a staff a MDE we did a lot of pulling apart and looking at the legislation, because NCLB is not just the regulations, but it’s the programming piece [and] the financial piece as well, and the compliance both programmatically and financially. So we try to separate those two things and still make sure that what we do is supplemental and is appropriate for those expenditures, be they Title I, Title 11, Title II-D, V, whatever it is. So that’s one way that we divide it out. And then another way is looking at —all of our buildings are school-wide buildings, and so because we’re all school-wide, we don’t have to tease it apart as much as we would if we were targeted assistance, and so that’s one advantage that we have. It’s a huge advantage. She filrther described herself as the calculus expert who came to the district and needed to teach Steele administrators how to add and subtract, though she found “I lost my expert status when I moved here” rather quickly. She described the district as not “having much in place for implementation of NCLB when I arrived, and so it was an interesting challenge in the beginning.” Dr. Hughes built up the district’s knowledge of NCLB through multiple methods: administrative meetings and trainings she conducted, sending “key administrators and staff to trainings that either MDE was putting on, MIEM was putting on, or the ISD,” and 175 written communications. She also had MIEM come in last year on two Saturdays to do a “boot camp” for district administrators on “No Child Left Behind compliance . . . just a little bit of everything, kind of a refresher-reminder.” She reported, “Little by little [NCLB] became a household term.” Most Steele administrators confirmed Dr. Hughes’ role as an important source of information and training on NCLB, citing the forms of communication and training described above as helpfirl in building their knowledge base of NCLB requirements. When asked where they learned about NCLB, her name was usually the first mentioned, referring to administrative professional development sessions and e-mails from Dr. Hughes as primary sources of information. Nila Taylor, Director of Student Support Services, stated, “Well, in our district, our Assistant Superintendent for Curriculum . . . has pretty much kept us informed . . . so between that and doing my own research and of course, whatever we get fanned out through the State of Michigan . . . that’s pretty much how I’ve learned” about NCLB requirements. Bob Hilliard, Deputy Superintendent for Finance and Operations, reported, “Our Curriculum Director made a presentation to other administrators and board describing the different things that would have to take place.” Sam Hanson, elementary principal, stated Dr. Hughes has lead responsibility for educating administrators about NCLB, noting “her main form of communication is through e-mail,” though he also reported, “Administrators are contracted, [so] we actually have one professional development day every month . . . plus the three at the beginning of the school year.” Dr. Hughes also brought her MDE administrative assistant, Maxine Higgins, with her to Steele; Maxine had a wealth of information on NCLB prior to her arrival in the 176 district, and described herself as a “go-to person” for many Steele educators requesting information on NCLB requirements. Steele educators firrther mentioned professional associations, conferences, and meetings they’ve attended, specialized by job responsibilities, as sources of information on NCLB. Nila Taylor has found “there’s been quite a nice little marriage between NCLB and IDEA” (Individuals with Disabilities Education Act), which she discusses with her special education director colleagues through the Michigan Association of Special Education Administrators (MASE). Patricia F itzwell, Steele High School Principal, finds information fi'om the Michigan Association of Secondary School Principals (MASSP) as a helpful resource, and also noted, “I subscribe to every educational publication I can get my hands on.” Wanda Peasley, Director of Grants, is a member of the Association of Supervision and Curriculum Development and Michigan Association of State and Federal Program Specialists and receives information from both organizations on NCLB, and attends monthly meetings through MASF PS as well. In addition to educating Steele administrators, Dr. Hughes trained her instructional specialists, the Director of Grants and Testing Coordinator, on NCLB requirements. Once they had the appropriate information, “they would turn around and work with the teachers in the buildings.” In this way, NCLB information was disseminated through the district. The “chain of command” pattern for communicating NCLB requirements, as Sam Hanson described it, had one small flaw. As a former associate principal who made his way up to a head principal position, some information was shared “just through my head principal,” who actively attended meetings while Sam remained behind to take charge of 177 the building. This resulted in gaps in his understanding of building administrator responsibilities. In some areas, he appeared unaware that he was missing information; in other instances, he commented, “I’ll be responsible for going through that and educating myself on that. So it will basically be a self-education thing.” However, he knew he could always “go to Dr. Hughes, I couldn’t tell you if [she’s always] the right source or not, but I know she would point me” in the right direction. How the district trains new leaders on legislative mandate requirements was not always clear. Administrators ’ Implementation and Monitoring of NCLB Requirements As noted earlier, Superintendent Edmonds described his role in putting “systems” in place to implement and monitor district responses to legislative mandates. Weekly cabinet meetings were the venue for discussion and problem solving with “All of the department heads and the Curriculum Director [and] Special Ed Director, and we began to discuss what parts were going to be difficult to implement, what it would cost, where were the resources, that kind of stuff.” He also found the high school principal, department heads, and staff have been very involved in this process as well. Steele administrators’ responses to NCLB have resulted in assignment of responsibilities for NCLB compliance, and also reveal inconsistencies in implementation and monitoring across the district. Assignment of responsibilities for NCLB compliance. As the initial layer of response to legislative mandates, Mr. Edmonds indicated assignment of responsibilities “took place through discussions with the Assistant Superintendent for Curriculum, [as] she would definitely have ideas on where we would assign different things.” Dr. Hughes sees herself as “responsible for everything [related to NCLB] except the financial piece. . I78 . . If it has anything to do with student achievement, I’m responsible for it. I’m not responsible for buses, I’m not responsible for transportation, but that’s about it.” In turn, when asked who else is involved in implementation and monitoring of NCLB requirements, Dr. Hughes laughed, replying Everybody! It’s a household word here, I’ll tell you that for sure. I mean the implementation starts with me and with Bob, who is our finance man, and then it moves right on down through the chain of command until we get to our parapros. Everybody has their piece that they’re implementing, the data that they’re collecting and analyzing and monitoring and determining different interventions, and our Special Ed people are looking at response to interventions and all of that data. We have ESL people that are working with our second language students to try and make sure that they have all that they need as far as meeting the challenges of No Child Left Behind. I’m not sure that there’s hardly anybody, except maybe Payroll, in the district that doesn’t have something to do with implementation of No Child Left Behind. Thus, specific responsibilities were allocated to departments and individuals, largely specialized by position, starting at Central Office. Central Office administrators were generally quite clear about their areas of responsibility, and their work often requires collaboration across positions and departments. As Dr. Hughes noted, she works closely with Bob Hilliard, each of them taking responsibility for separate areas of NCLB, with her department overseeing programming decisions, and “Finance working on budget.” Mr. Hilliard explained this further: I’m responsible for compliance in the sense that the dollars are spent as they are intended. The Curriculum Office would be responsible for the programming piece, so if we need professional development . . .then they see that it’s appropriate, and then we are responsible to make sure the money is spent as intended. . . . She meets with the principals, helps them comply with what they need to do at their building level, monitors their expenses throughout the year as they’re being expended . . . and then it comes down and we make sure it’s coded correctly on the books. 179 Dr. Hughes’ administrative assistant, Maxine Higgins, who is Steele’s NCLB Compliance Specialist, is also integrally involved in implementation and monitoring in the district. She described her in work with buildings, particularly with new principals who “really don’t understand the Title I aspects and what hoops you have to jump through to keep us school-wide.” She also assists them with ensuring they have school improvement plans and annual reports completed correctly, so that “they follow the script and fill it out according to Hoyle.” In addition to internal monitoring of programming and budgets regulated by NCLB, Mr. Hilliard noted they have external audits to see if the district is compliant, “Both from a program and financial standpoint. They do testing of our books and of our procedures. We’re required to report on all of our federally funded projects. Throughout that audit process, they assist us in making sure we’re in compliance. Dr. Hughes oversees curriculum, instruction, assessment, and professional development, with a variety of people assisting in these areas. In the area of curriculum, two different structures were described to align curriculum to state standards, the “curriculum cycle” model used by Steele’s Curriculum Council, and department work at the high school level. Curriculum work has been a central focus of district efforts, as student performance according to state standards is at the core of NCLB’s accountability mechanisms. According to Superintendent Edmonds, the district has implemented a “curriculum cycle” model for years. Curriculum work is facilitated through Steele’s Curriculum Council, which oversees district wide alignment and articulation. Wanda Peasley noted, Steele’s curriculum is “a working document and we’re still working on aligning some of our curriculum. . . . Prior to that, some of our curriculum had not been 180 updated or revised for probably six or seven years. Under NCLB, we are working on that.” Edmonds was careful to point out these efforts are not new since NCLB, but agreed curriculum alignment has probably intensified since its passage. However, NCLB has also disrupted the five year curriculum cycle in many ways. As the state standards undergo more frequent changes in response to NCLB and other national pressures, resulting in MDE adoption of new high school graduation requirements and content standards, the district has struggled to keep pace. This has increased curriculum—related burdens on the district in two ways: educators’ work to align to state standards, and in the financial strain to purchase new, aligned program materials. Curriculum work is also facilitated at the high school level, through high school principals and department heads collaborating on “how to implement the legislation.” According to Superintendent Edmonds, NCLB helped to leverage curriculum change at the high school, citing as an example, “The legislation probably forced that discussion [math alignment at the high school], because our Math Department really wasn’t interested in change too much before that, as I recall.” With established curricula, Dr. Hughes indicated she believes that this sets the stage for good classroom implementation. When asked whether she found monitoring consistency of instruction and lesson delivery difficult, she stated, “Not really, because we have a consistent curriculum and consistent professional development for the people who are working with it so the only, the only difference would be in, in the presentation.” While she did not specifically address how classroom implementation is monitored, Mr. Edmonds discussed his commitment to principal oversight of instruction in buildings: “We insist that administrators visit all their classrooms every week at least. I’ve got 181 some that do it every day.” He also shared his experience listening to a fellow superintendent who did classroom visitations weekly, saying That is what I want to do, and that’s a great monitoring tool for making sure the principals are staying on top of it. If I know what [teachers] are supposed to be doing vaguely, I can stay a little bit on top of it, or I [can] challenge the principal: ‘Hey, I was in the science class and . . . it says we’re doing this, but I didn’t see it, and kind of question what they’re doing so that they monitor it closer. Mr. Edmonds thus insinuated that principals are not always “on top of it,” and hopes to improve their instructional oversight. He also shared how he has changed his principal evaluations to reflect their responsibility for student achievement: “We monitor graduation rate, we monitor MEAP results, and we constantly talk about making gains. I put in their evaluations they have to raise scores by 5%.” In addition, he assigns three goals to each principal, and “I’ve informed all of them one of the goals is that . . . there’s three goals on every teacher’s evaluation,” which he is having them align to Charlotte Danielson’s Domains . . . . I’m making it easy, they’ll be able to just pull those out and put them in there if they want to do it that way, or they can come up with something separate, but I’m going to hold them accountable for giving each teacher three goals. . . . Think about the combined size of that 450 [teachers] with three goals each. It should be powerful. Instruction for students with diverse learning needs was also addressed in the interviews. Dr. Hughes discussed consultant services hired by the district to improve programming for English Language Learners, who developed a program manual describing district protocol and procedures. Moreover, she described work with the Director of Student Support Services, Nila Taylor, “putting together manuals and processes and policies and procedures for response to intervention, and for the universal 182 learning, so that in the fall those things will be there, and that will help to close the gaps, because we do desperately want to close the gaps” for special education students. Nila Taylor further discussed Steele’s decision to put together procedures for implementation of NCLB for special education students, reporting it stemmed from “Focused Monitoring” visits from MDE. Focused Monitoring is MDE’s response to “State Performance Plan” requirements in IDEA 2004, including assessment and written reports on indicators including student identification and student time in special education classrooms. As Ms. Taylor noted, NCLB and IDEA are integrally related, with IDEA 2004 intended to support NCLB implementation for students with disabilities. Ms. Taylor worked with two other special education directors to put together a manual to assist with NCLB and IDEA implementation, “so that if we left tomorrow, there would be something there for someone to grab a hold of and say okay, this is what we need to do.” They’re also planning to put together “literal toolboxes to go into every building, so that people can pull stuff out and say, ‘Oh, here’s something cool we can use as an accommodation, or I guess in general ed land, intervention.’” She referred to the difficulties of ensuring things are institutionalized and systematic in building practices for students with disabilities. She’s also working with two building principals, an elementary and secondary principal, to use a committee process to “revise our student study teams,” which work on behalf of students with identified difficulties. In fact, the “Focused Monitoring Report” on Steele’s website refers to noncompliance with federal regulations in Steele’s special education programs, including overidentification of students with “Specific Learning Disabilities,” and students spending too much time in special education classrooms (Appendix E). The Focused 183 Monitoring Report spells out what Steele is to do, within a calendar year of the report, to produce “Evidence of Correction” in the areas of noncompliance. Required corrections include reduction of students identified for special education, professional development for teachers to implement appropriate accommodations and modifications for special education students, and evidence that special education teachers are “integrated” with general education teams at the middle school level. It appears that the actions described by Nila Taylor align with the recommendations of the Focused Monitoring Report, and address ways to improve student achievement within the special education subgroup under NCLB. In the area of assessment, responsibilities for all standardized tests mandated under NCLB are handled through the Testing Coordinator. She did not make herself available for an interview, but I was able to talk with Veronica Simmons instead, who holds a comparable position in Harmony Public Schools, a similar district. As Assessment Coordinator, she stated her role has lots of little branches. I get the state mandated assessments and distribute them. I communicate with principals about how to use them and I talk to them about the directions they should give to their staff. I assign teacher codes for the district, so that the results come back per teacher. I also work with assessment data, so that I work with our Curriculum Specialists-- in terms of interpreting the data, and work with them in terms of their work with teachers . . .[on] what to do now that we know these results. I don’t get to do that quite as much as I’d like to, because most of my life is spent on getting stuff from the State and sending it on to somebody else, but I do that. As a former principal and an educator passionate about helping children to meet standards, her greatest interest lies in helping principals and teachers understand how to use assessment data to develop interventions for low-achieving students. However, she experiences many conflicts within her role, described in the next section. 184 Additional interventions provided through grant programs regulated under NCLB include Title 1, before and after school programming through the 21St Century Grant, and Homeless services. Responsibilities for Title I are shared by Dr. Hughes, her administrative assistant, Ms. Higgins, the Finance Department, and building principals. As noted earlier, one to two building principals have particular responsibilities assigned for coordinating Title I, while all principals are tasked with Title I oversight in their buildings. All Steele’s Title I services are delivered through “school wide” programs, which means buildings have significant flexibility in designing their programs to boost student achievement through supplemental academic services, including services within general education classrooms, pull-out support in specialized groups, etc. Responsibilities for the 21St Century Grant and Homeless Services are coordinated through Wanda Peasley, Director of Grants. She indicated there are five sites, including two high schools, two middle schools, and one elementary, and she “coordinates, shares information, and meets [with] the five site coordinators.” Her work also involves interactions with teachers, principals, and counselors “in regards to the identification and the services that we can provide to students who are eligible to receive services under the grant.” These services include tutoring and “enrichment activities that correlate with the regular school day activities to help those students . . . close the achievement gap . . . [for those] who are struggling academically.” As noted by Mr. Edmonds and Dr. Hopkins, building administrators also share responsibility for implementing and monitoring NCLB requirements. Their descriptions of responsibilities shared by building administrators for things such as data collection and analysis, providing regular instructional oversight through classroom visits and feedback, 185 developing and monitoring appropriate Title I programs and services, and monitoring interventions for students did not completely match other descriptions of building level implementation and monitoring. These inconsistencies are addressed in the next section. Inconsistencies in implementation and monitoring. Reports of inconsistent implementation and monitoring emerged in two areas: execution of assigned responsibilities at Central Office, and building implementation based on reports from Central Office staff and principals themselves. In each area, inconsistencies are described and analyzed to explain how they might have occurred and how the district responded to identify and correct the problem. Starting with Central Office, inconsistencies in implementation and monitoring emerged during the interviews. The first was a problem described by the Superintendent, the Assistant Superintendent, and her administrative assistant, concerning response to the highly qualified teacher requirements. As described by Superintendent Edmonds, identification of the problem led to fairly swift resolution: Certification at one time went through Human Resources, got very gummed up in that system, and then we made an executive decision to change it to her assistant who’s done a great job of charting it all out ..... The Assistant Superintendent had a recommendation and then we adopted that and monitored to see if it was going to work and we’re very pleased with the result of that. Maxine Higgins, the NCLB Compliance Specialist charged with monitoring the highly qualified requirements indicated the Human Resources Office had two individuals “Who really didn’t know what things were . . . [or] what some of the requirements meant. They had made some errors and it cost the district quite a bit of frustration and some legal matters.” However, she described further errors stemming from teacher hires: 186 Some principals have chosen to ignore things and, ‘I want this person and this person.’ However, they can’t teach those classes because they are not qualified. . . . We had to hire a lawyer to dismiss them and get legal advice, how to remove them. I mean, they hired a teacher that didn’t have a teaching certificate. . . . That was like in 2005, I mean, ‘Hello!’ until he had been here for years already. Ms. Higgins also described problems with the professional development report submitted to MDE through an online database called the “Registry of Educational Personnel” (REP). In accordance with NCLB, teachers are required to participate in annual professional development hours, which the state monitors through the REP report. Ms. Higgins stated, “The person in HR who’s no longer here didn’t know what it was,” so Maxine did the report herself. Last year, she reported I had been taken and removed from doing any REP because that was an HR duty, and the Superintendent pulled me off, because I mean, I would go and say, ‘It’s not in, it’s not done, you know we’re going to lose this, we’re going to lose that, you know, and so they just said, ‘Oh you worry too much,’ so they took me off. . . . [And] we got an e-mail a couple weeks ago from CEPI [Center for Educational Performance Information] that said our REP report hadn’t been accepted, it had been submitted with considerable errors, including no submissions. . . . [So] I went down and talked to the person who submitted it, and she said, ‘Yeah, I knew it was wrong when I sent it.’ Take our money because she knew it! There are no consequences for screwing up. In these cases, one inconsistency was resolved through reassignment of the responsibility to another individual. In the second case, the problem was identified, but not actively addressed as of this writing. It is uncertain whether the district will experience firrther consequences, other than having to resubmit the report, or not. Having oversight responsibilities for the REP report in F airview, I can speak to the amount of time and painstaking attention to detail it takes to complete it correctly. It is apparent many regard it as “nuisance wor ” and a drain on district resources. It may also be the kind of work administrators would prefer not to do, concentrating their energies on other 187 matters they regard as more critical. The REP report involves just the kind of “busy work” required under NCLB that many love to hate. Failure to implement NCLB requirements properly raises the ire of people like Maxine Higgins, who observed there are people in Steele who simply “choose not to implement it” and ignore possible consequences. Building implementation and monitoring of NCLB, based on Central Office staff reports, was also somewhat uneven. The reports varied based on the position of the person interviewed, the portion of NCLB compliance they monitor, and how broadly they interpret building level responsibilities for NCLB compliance. Reports of inconsistent implementation and noncompliance were less frequent from cabinet level administrators, particularly the Assistant and Deputy Superintendents. Dr. Hughes indicated she thought about “sixty-five percent of our teachers who are committed to all children and they’re, they are discovering that all children can learn,” which would mean approximately 35% of the teaching staff is not committed to NCLB’s intent and requirements. Superintendent Edmonds did acknowledge that while “there’s a very strong thrust forward,” there are pockets of noncompliance. When asked how he represents this both in and outside of the district, he asserted, “I say we’re moving forward and we’re addressing each problem as we go.” His largest area of concern has to do with programming for special education students to ensure they’re making adequate progress: Like what we’re in the middle school right now. We created [the situation] so that every child is on one of the middle school teams, and then they’re out in general education as much as possible. We put one Special Ed [teacher] — we used to have them segregated into their own team, and this is the right thing to do and I can — on paper it all looks good. I did this same idea like ten years ago when I was a middle school principal, and it lasted for about three years, because the teacher just said, ‘Hey, I don’t want to do it. I don’t want to — ifl don’t have to do it.’ But 188 now the law says they have to do it. That’s a change, that’s different than what I tried to implement, so it’ll be interesting to see what kind of barriers they put up to — like, ‘The law says that . . .this IEP says this is what we have to do.’ You mark my words, they’ll find ways to — the people who live by the law, die by the law you know, they really can frnd ways to manipulate it. The Director of Student Support Services repeated this concern. She indicated changing attitudes in the schools has been challenging: “It was like, ‘Special Education, you have all that money over there, you just take care of them over there.”’ She has worked to educate administrators and teachers on special education law, required assessments for special education students under NCLB, and the expectation that the vast majority of special education students will be educated in the general education curriculum. In fact, as noted before, the district was cited in their “Focused Monitoring Report” (Appendix E) for overidentification of special education students, and keeping them out of general education classrooms for inappropriately long periods of instructional time. Other Central Office staff, including Wanda Peasley, Director of Grants, also shared their belief that principals and teachers are not always committed to doing all they can to ensure students succeed, per NCLB requirements. It really bothers me to hear an educator say ‘This is too much work’ -- when it comes to helping the children to succeed, you know? And I look at No Child Left Behind, it’s not really asking you to do any more than you should be doing anyhow. My background is reading, and that’s why I was very, extremely supportive of Reading First, because I found myself saying to the teachers, ‘Reading First is not asking you to do anything you shouldn’t be doing anyhow. Everything that’s required in Reading First you should be doing. They’re just trying to hold you accountable to make sure you’re doing it, because no one else has the guts to hold you accountable, and Reading First is saying, you know, ‘Hey this is what needs to be done to help these children.’ It frustrates her that not all administrators hold teachers, or themselves, accountable, noting, “Sometimes there are no repercussions, depending on who it is.” She sees 189 pockets of greater accountability, as well as schools where people “don’t have to answer for anything, they can do what they want. . . . [And] there are leaders that allow that to happen.” And unfortunately, she believes the buildings whose students have the greatest needs tend to get the weakest leaders and the “least experienced teachers,” because “we know this group of parents are not going to complain.” Maxine Higgins also shared some inconsistencies in building level implementation. Overall, she believes the district is in compliance, but talked about “those stumbling blocks and roadblocks we have to cross. . . . There’s always that one mule that stands there and we just gotta either bribe it or just shoot it!” She shared some examples of administrators “blatantly saying, ‘We’re not going to do it. . . . It’s going to be this way and that’s it.” This included cases of noncompliance with highly qualified requirements, “definite supplanting and definite broad misuse” of Title I funds, and inappropriate scheduling of “Special Ed students and ESL students.” She stated she believes about fifty percent of the principals try and skirt the mandates in one way or another. However, she has secured the commitment and cooperation of the Department of Finance to “crack down” on these issues during the 2007-08 school year. The Assessment Coordinator in Harmony also shared frustrations about trying to assist building level implementation of NCLB. She has prepared extensive data analysis reports, focused on the needs of “target kids.” She did a two hour session for principals “in probably January of last year with the data.” Principals were then supposed to work with teachers to build student interventions. Eight months later, she reported, “I had a principal e—mail me the other day and said, ‘I’m ready to look over that data now, can you give it to me?’. . . I’m going, ‘Were you at that meeting where we spent like two hours 190 going over that stuff?” She noted that in her work with curriculum directors in other districts, she hears similar stories, and that “administrators are feeling quite overwhelmed.” However, given that her work focuses on assessment, her “personal rub is if that’s as far as it goes.” She doesn’t see assessment data actively used across buildings to help improve student achievement as NCLB intended. Based on principals’ reports, building implementation and monitoring of NCLB requirements did not always match up to what was described by the Superintendent and Assistant Superintendent. Patricia Fitzwell, the high school principal, indicated, “1 try very hard to follow the absolute letter of the law and then look at once a few years have gone by, look back and see that really didn’t work, and we don’t have to do that.” In particular, she has had difficulties implementing the highly qualified requirements: “We had a teacher here who . . . worked with NASA and is internationally known and a phenomenal guy, and he had to go back and get a different degree to continue teaching . . . so we lost him. Things like that have been really negative.” However, she noted she does “make sure I have highly trained in the right spot.” Beyond this, she noted, “The only part I really monitor myself is the highly qualified piece, that’s about it. Making sure our students are meeting restrictions and all that kind of stuff.” She acknowledges she does little with NCLB, and believes that to be more within the purview of the Assistant Superintendent. Over the course of the interview, she shared many frustrations with NCLB, because “it’s taking up an enormous amount of financial resources and considerable human resources.” In addition, she discussed her frustrations with the “huge inaccuracies” she believes are communicated by Department for Student Achievement, saying, “I cannot 191 rely on that person who’s in charge of disseminating information to be most recent and accurate information.” She believes the district tries to implement NCLB “probably way more than its intent.” She cited a couple of examples of information she checked on at MDE, where they gave her more flexibility to do something than what had been communicated to her by Central Office, including a “class that did not have a certification attached to it, it was like an office assistant kind of thing for non-special ed kids . . . and they gave me room on that . . . [And] something with having a parapro in an in-school suspension room, that was okay because no instruction was taking place.” There was no mention in this interview about looking at student achievement data, aligning curriculum to state standards, or how the high school targets interventions for students with low achievement. With a 56% graduation rate and overall low achievement, this was somewhat striking. As a head principal of a large building, she may delegate some of these responsibilities to one of her four associate principals, or perhaps she hasn’t connected school improvement work to NCLB. In either case, it revealed a possible disconnect between NCLB and her role as an educational leader at Steele High School. As a new elementary principal, Sam Hanson had fairly limited knowledge of his NCLB-related responsibilities, though he gave more of a list of these responsibilities than the high school principal. He knew about having to complete the Annual Report, and “looking at student achievement data . . . obviously on the MEAP scores. I know as a district we’re already at 100% of staff is highly qualified, so we don’t have to know about anything like that.” He also cited Dr. Hughes and the curriculum office as having primary responsibility for implementation and monitoring of NCLB: “It basically comes 192 down to between herself, obviously the superintendent, Mr. Edmonds, and then if there’s an area that they can’t—you know, they may bring someone in. And I do believe they’ve also, I don’t know if they’ve actually used an attorney for that or not, I couldn’t tell you off the top of my head.” When pressed to describe what he would do to monitor implementation of NCLB, either through what he’d done already, or projecting himself into his new role as elementary principal, he talked about doing “A lot of walk-throughs, especially during preparations. . . . All my teachers are going to be mandated to be using this form of [MEAP preparation called] ‘The First and Second Ten Days of MEAP.” He also talked about making sure “things that can’t be on the walls” during MEAP administration are not inadvertently posted. His knowledge related to NCLB requirements appeared to be somewhat superficial and limited to concrete kinds of issues. He appeared to have a healthy respect for NCLB and consequences for poor performance, saying, “I think people would be behind if they didn’t say that the No Child Left Behind mandate is a lot scarier than the Sex Ed. . . . I know what it means to not make AYP.” However, the depth of his understanding and how to monitor implementation of NCLB requirements did not appear to be well grounded. Hence, considering all sources of data presented here, assertions made by Steele administrators that they are in “full compliance” with NCLB requirements, raise a shadow of doubt. Certainly, it appears there are differences in how compliance may be defined and quantified. However, enough inconsistencies in Steele’s implementation and monitoring of NCLB exist to question whether the district is fully compliant at all levels. 193 Administrative Challenges and Conflicts With nearly 7,000 students and approximately 450 teachers in eight elementaries, two middle schools, a high school, and an alternative education school, it may be expected there would be significant challenges in implementing a legislative mandate requiring a district to demonstrate 100% of its students have achieved proficiency on standardized assessments by 2013-14. In addition, a district with disproportionately high nrunbers of students from economically disadvantaged, less educated families may also experience greater difficulties meeting mandated standards. Data from Steele illustrated a number of themes related to administrative challenges and conflicts that emerged as the district responded to NCLB, including early implementation and compliance issues; a lack of accountability and problems in leadership; tension between NCLB’s purposes and implicit values and district and personal values; an inability to connect district work to the purposes of NCLB; and capacity and resource issues. An overwhelming focus on “Ietter-of-the-law ” compliance. A definite sense emerged during the interviews of district administrators that they are determined to fulfill NCLB requirements to the letter. This is reflected in the Assistant Superintendent’s comments that the district is in “full compliance, no doubt in my mind.” When asked whether there were places where the district backs off from the mandates, she replied, “No, I don’t think so. We pretty much do the letter of the law.” She talked about “chain of comman ” implementation across the district, perhaps based on her paradigm for implementation conring out of MDE. In this model, everyone has a job to do, responsibilities to complete, and is simply expected to comply. And in her capacity as 194 the recognized authority on NCLB and district expectations, she has a critical role in setting tone in the district for its response. Nonetheless, there was evidence to indicate that “letter-of-the-law” compliance was not really the law in Steele. Inconsistencies in implementation were reported by many at Central Office, as well as in the buildings. There was overt tension between key leaders in the district related to NCLB implementation, with a building administrator expressing distrust over what she perceived to be overly rigid rules handed down from the Department of Student Achievement, and representatives from the department citing a lack of cooperation from building administrators. It begs the question of whether educators’ compliance and deep changes in practice can simply be motivated by an expectation they will comply. In addition, while it’s clear district administrators do want students to be successful, as the Assistant Superintendent noted, they are extremely careful to implement NCLB faithfully, “because we know that there’s going to be somebody here with a hammer if we don’t. . . . And I can use that for leverage to get things done.” Thus, early implementation of NCLB in Steele appears to have a flavor of “do it or else,” even more than, “do it because it’s what we want for our students.” In fact, Superintendent Edmonds hopes the district is successful in moving educators in a more values-centered direction. I want us to be people of the heart, not just people that follow the law. That’s my job is to get people to really see that this is what’s right for kids. . . . But then things get in the way like testing them to death or sending in monitors or — ‘We’re going to make you follow the law,’ and you know — we’re good at following the law, we will follow the law, but will change really be made? People need to follow the law with their heart. . . . People will follow the law, there’s no doubt in my mind that we’ll implement every piece of the legislation and I can pretty much 195 guarantee that, but real change comes in people’s hearts, and will our teachers? Sometimes the law can push us in the right direction, I think — don’t you think? In other words, Mr. Edmonds observed that sometimes compliance issues have distracted educators from realizing the greater purpose in what they’re doing. Dr. Hughes believes she has seen evidence of Steele educators changing their values and beliefs over time in response to NCLB. She sees that there has been a gradual process in Steele to implement assessments, collect and analyze data to improve curriculum and instruction, etc. She commented the district is now to the point where they’re developing “a laser focus in what you’re doing, why you’re doing what you’re doing . . . and if it doesn’t work, trying something else, not waiting until the end of the school year and saying, ‘Well, he didn’t 9” get it again. And when Steele’s teachers see the positive results of their work, reflected in improved achievement scores, she believes this helps to shift their attitudes and practices. However, it is unclear at this point in time whether her perceptions are widely shared by others 11 the district. Issues of accountability and leadership. Inconsistencies in district and building administrators’ implementation of their responsibilities under NCLB exist, as described previously. Furthermore, several people commented during their interviews that they did not believe the same standards for accountability apply for all district leaders. There were a couple of different explanations offered for this. Regarding building leadership, Maxine Higgins observed We can’t hold our principals accountable. They have a very strong union. I mean they’ll run to Daddy downstairs, ‘Mommy says we gotta to do this,’ Daddy says this, and you know they play each other back and forth. We have a lot of game playing here in Steele, it’s awful. . . . It makes it challenging, who gets to Daddy first and who says, ‘You know it’s a mandate.’ Sometimes I don’t think he understands mandate. 196 Nila Taylor noted this dynamic as well. She voiced frustration in dealing with building principals over the Early Childhood Program, assigned to her a couple of years ago. She stated, “I’ve been working for the last two years trying to regain control” from the principals, who don’t understand the grant regulations or the curriculum, noting, “It’s been a bit of a power struggle.” She believes that when people are given “these responsibilities . . . they have to be given the authority to go with it, and right now, that’s a little bit of a power shift here . . . . It has to be told to the principals, ‘It is not your bailiwick.’” Instead, what she’s experienced is that “They don’t like Marna’s answer, so they go to Daddy . . . You know how children do it.” Wanda Peasley also verbalized disappointment with what she sees as “a lack of accountability and the Good Ole Boy system” operating in Steele, saying, “It’s the lack of accountability, because some of the things that are said and some of the things that are done in this district, I just cannot imagine any other district that will allow that.” She believes many of the leadership decisions to overlook inappropriate behavior or a lack of accountability are made based on relationships and politics. It’s also important to recognize the difficulty of being the individual or group of individuals at the top who have the sometimes unpleasant job of holding others accountable. Superintendent Edmonds remarked My administrators think I’m too nice. I’ve lasted in this job nine years, the one before me lasted over two and a half. I’m tough, but . . . I try and say yes as much as I can, so I try to kind of counterbalance that. . . . I mean, you know, if you get stuck with a hard decision, it’s going to come into a meeting with the superintendent, and say, ‘This is the two sides, and he’s going to have to make a decision.’ It seems easy from the outside, but it isn’t, it’s very challenging, very challenging. 197 It is clear Superintendent Edmonds feels a sense of mission for his work; even so, he sometimes finds it hard to keep going, noting health problems have plagued him over the last year. His doctor informed him that he believes work stress has contributed to these problems. Mr. Edmonds concluded, “If I didn’t have my mission, I probably wouldn’t be so [determined].” Regardless of how it looks to others, it is apparent Mr. Edmonds is attempting to increase expectations for Steele’s educators. He shared some of the inconsistencies he has observed, noting, “In the public domain there are great people at loafing and then are great workers. . . . I need to push those people [who aren’t working] until they say, ‘Ouch!’ and then I can back up a little bit and feel comfortable that they are working.” One way he is doing this is to establish goals for all Steele administrators and teachers. Tension between “old” district ways and NCLB values. There is disagreement over whether NCLB’s implicit values are congruent with Steele’s district values, as well as those of its administrators. Each administrator interviewed for this study had a different response to this issue, signifying there is not widespread consensus throughout the district supporting NCLB’s values. Most administrators, with the exception of the high school principal, stated they embrace NCLB’s values, with some advocating quite passionately for it. Patricia Fitzwell expressed several philosophical conflicts with NCLB, including a belief that “No Child Left Behind is a wonderful thought, but I really believe that sometimes in our zeal to give every student every opportunity, we have taken the opportunity to choose.” She does not believe “all students can learn the same material, let alone at the same pace. . . . We’re not talking about a factory, where you have this little piece and you produce this piece, and at the end if the specs aren’t right, 198 you melt it down and start over. Our guys get one chance through.” She believes forcing all students into the same mold will increase drop out rates. In addition, she expressed frustration that while she thinks the community embraces NCLB’s values, “I think that our clientele is not representative of what they look at overall . . . I’m not sure that they have realistic expectations considering our demographics.” In general, administrators seem to believe their own values, which largely mirror NCLB’s, are represented in the district and community as a whole. Perhaps this is a case of wanting to see what one values. Those who did see past their own values compared the values they heard espoused in the district with what they observed in action. In the end, they reflected that as doubts still run high about whether children with disabilities can learn the same content, district values don’t necessarily support trying to ensure all students meet proficiency standards. As Superintendent Edmonds questioned, “What are the hidden values of [the] district?” He concluded that a “compartmentalized” system for special education students is one of the district’s values, “I think sometimes just by the overwhelming nature of the people we have to help, [so] sometimes that value is a very difficult one to get in.” Nila Taylor summed up by saying, “I think [the district] really likes doing things the way we’ve always done them here.” Disconnect between district work and NCLB. This is a theme that is interwoven in most of the interviews. It is apparent that Steele has made significant strides toward institutionalizing most practices that comply with NCLB standards regarding assessment, teacher qualifications and professional development, curriculum standards and research- based interventions to support student achievement, etc. There have been improvements in student achievement, to be sure, and most administrators appear to have embraced 199 NCLB as a means to leverage change they believe is important for students. However, there is also a recurrent note of concern regarding response where it matters the most, which is at the classroom level. Having 65% of teachers on board with doing everything they can to ensure the success of students still implies that a third of them are in the parking lot, along with their students. The “Focused Monitoring Report” (Appendix E) cites concrete data that indicates a significant number of students have been inappropriately labeled with specific learning disabilities, and excluded from working alongside their general education peers. The heavy lifting of school change is enacted within classrooms; it appears Steele may be on its way to putting systems in place to support classroom change, but still has significant work ahead. Capacity and resource issues. In terms of both financial and human resources, all Steele administrators agreed resources are insufficient to realize the goals of NCLB. Bob Hilliard noted his office is so busy with compliance issues, they don’t have time to do “more financial analysis of trends, or things like how much we’re spending per student or per building, or things like that. You just do your work and go on to the next, where you don’t have a chance to sit back and say, ‘Oh, what direction are we headed in? or Does this make sense?” This makes dealing with the deficits the district has faced in the last seven years extremely challenging. It was noted previously that declining enrollment has had a negative impact on Steele’s budget, but Steele has also experienced shrinking resources in other areas. Loss of the Reading First grant and changes in allowable uses of Title I schoolwide funds has cut the kinds of supports available to students. In addition, special education funds have 200 decreased, as noted by the high school principal, and Nila Taylor, Director of Student Support Services. Ms. Taylor reported You’re sitting in one of the counties that has always been able to reimburse at a pretty high rate for special education. A lot of that is based on our millage. Our millage is based on our home taxes, okay? The taxes, the level is going down, is decreasing so therefore those monies are decreasing as well, which then puts another strain on the budget. Reduced special education funding does not equate to reduced special education programs and services, as most of these are required and regulated through IDEA 2004. When special education funds are insufficient to meet all of the programming needs, the money then comes out of the district’s general fund. Furthermore, Mr. Edmonds noted state monitoring has pushed Steele’s human resources to their limits. Everybody wants to monitor NCLB, and so we’ve been through these monitor people. Personally, I think they’re trying to keep their jobs during a very desperate crisis time. . . . Why do you want to spend their time and our time working on a monitoring situation when our scores are going up? That part, I find absurd. And as the money has become tighter and tighter, they make the reins tighter and tighter, and so I’m just like, ‘What are you trying to do, kill us? Are you trying to get rid of us, or what? . . . We’ve been monitored to death, so I don’t worry about it. . . . There’s just . . . human resources are taxed with keeping up with the monitors.” Beyond not having adequate administrative resources, other human resources have also been affected. Staying on top of teacher qualifications, while also having to cut back staff in a district of declining enrollment, has been difficult. While I was interviewing Dr. Hughes, a young man walked in to speak with her. After he left, she explained to me that he was the kind of teacher she would “go to the mat to keep” because of his exemplary ability to work with “at-risk kids,” but unfortunately, as he was a new hire last year, he was one of the first teachers to be cut. She still hoped to be able 201 to recall him before the start of the school year, but worried he would be hired by another district before he came up on the seniority list. Nila Taylor mentioned trying to staff appropriately in particular programs based on teacher certification and endorsements, and having to avoid placing staff in positions until the last minute to ensure enrolhnent is sufficient to cover the costs. Finally, without Title I funds approved for school nurses and social workers, it is unlikely these supplemental services will be available in buildings. In a district with a disproportionate number of “high needs” students, it is perhaps the decreased human resources that hit the hardest. Steele ’s Response to PA 1 65-166 As described in the External Context section summarizing Michigan’s sex education legislation, PA 165-166 has highly specific requirements. Data fiom interviews reveals Steele’s responses to PA 165-166. This includes Steele’s work to establish a Coordinated School Health program, which serves as an umbrella for sex education in the district; a period of focused work on compliance following passage of PA 165-166; early implementation; and challenges in implementing and monitoring PA 165-166. Steele’s Coordinated School Health Program Steele is fortunate to have a full time Health and Human Services Coordinator, Lucy Miller, as well as a nurse in every school. Ms. Miller is a family nurse practitioner who has worked in Steele for over eleven years. She has been integral in bringing the Coordinated School Health Model (CSHM) to Steele, recently adopted as part of the Strategic Plan approved by the Board. Though the Centers for Disease Control introduced CSHM in 1984, as Ms. Miller noted, “There’s a lot of political layering that 202 takes awhile for change to happen.” She has been working with the Superintendent and other district administrators for years to educate them about the importance of school health, commenting, “I’ve been a proponent of it for quite awhile, and the neat thing is that Superintendent Edmonds said, ‘I finally got it, Lucy,’ a couple of years ago, and he’s been very involved with training for CSHM.” In 2003, Steele was awarded a grant funded through multiple agencies, and trained intensively in the model. Because of inroads they’ve made with grants in nutrition programs and other school health initiatives, she believes this has helped to establish a higher priority for children’s health education in general within Steele. When the changes in sex education law were passed in 2004, she was able to work with existing structures in the district to address compliance issues. Focused Compliance Work Along with the Assistant Superintendent, Lucy Miller has been the guiding force for bringing Steele into compliance with PA 165-166 requirements. The first layer of response involved gathering information and assessing the requirements. Ms. Miller indicated when the legislation was first enacted, “Everyone was inundated in the school districts . . . but we have a very good working relationship with the Safe and Drug Free School Comprehensive Health Coordinator at the Intermediate School District.” He has helped Ms. Miller stay “abreast of things that are coming down the pike,” and also served on her Sexuality Health Committee in the district. The sex education consultant from MDE has been another resource for Ms. Miller, as well as the MDE website. In addition, Ms. Miller worked with the County Abstinence Partnership; this agency received a grant, “so they were able to have three educators that came into [Steele],” who worked with 203 Lucy on curriculum and ongoing classroom education in the district. Dr. Hughes also reported she was involved in working with Ms. Miller “to develop reproductive health curriculum that teaches what it is that needs to be presented to the students.” Initially, this work required a great deal of time to bring the district into compliance. We really hit it hard, and at that time it was probably . . . three or four months, trying to make sure we met the June 30th deadline. I probably spent sometimes 50% of time just trying to get meetings and . . . get everything done, and then you know; now it’s maybe only 25%, or 10% sometimes. When that new legislation came out, I think most schools spent quite a bit of time and then you put it up on the shelf, some people forget about it. Ms. Miller further observed some districts have chosen not to teach sex education because of the amount of work involved, but they don’t always understand that in order to do so, the law requires the district to get Board approval to drop sex education first. She believes Steele is committed to the importance of sex education. Steele conducted a parent and community survey a few years ago, which provided evidence of the community’s commitment. Ms. Miller also worked to establish the Sexuality Health Committee (SHC) in compliance with membership requirements set forth in PA 165-166. Having served on various regional committees for adolescent health, she has many contacts to help with in- district work. This includes her Coordinated School Health Council, “which is a movement that we’ve had for three years,” including about fifty people. Thus, she was able to get the SHC together “without too much problem.” Nila Taylor indicated one of her special education supervisors sits on the SHC, as she wanted someone “to give voice to what we need to do for our students who may not have the same kinds of abilities . . . 204 so that they receive the same information, maybe in a different way.” In fact, Dr. Hughes indicated this is “A strong advisory committee that is not in name only. And all of these different organizations are part of that, and the vast majority of the people on that committee are not employees of the district . . . so we get lots of input in that particular area.” Ms. Miller did note there were times she needed to remind committee members of the role in making recommendations to the Board, rather than establishing mandates for district practice. However, she reported that generally the committee “really works very collaboratively, I’ve been surprised. . . . I’ve heard horror stories from other [districts], so I would say that it has really been a success.” Ms. Miller described the curriculum recommended by the SHC, and approved by the Board, at each level. HIV education begins at fourth grade, and is included in lessons at fourth through sixth grade on puberty. Seventh and eight grades are “abstinence only,” and then the high school uses an “abstinence-based” curriculum. She noted, “When the new requirements came out, the difficulty that we really had, is we had to add the A-K requirements . . . but we worked that out, too. I think the process was fine; I think it went well.” Early Implementation Dr. Hughes shared information about classroom implementation of the approved sex education curriculum. We have a nurse in every building in the district, and some of those nurses are health educators, some of it is done through our collaboration with organizations in the community that come in and do our training. Some of it is throughout PE and health teachers; some of it is through Michigan Model; it’s done various ways depending on the grade levels. 205 When asked whether she was concerned about consistency of instruction due to the number of people involved, and the different configuration of people teaching at the various grade levels, she indicated she did not see this as an issue. In fact, Mr. Edmonds reported he has tasked the physical education and health teachers with greater responsibility for implementation, saying I wanted our PE people throughout our [health] curriculum, because I think all this legislation has just piled it on the science and the math, and everybody’s got their jobs and they’re really working their tails off. And the PE have kind of sat on the sideline without that, and I’ve kind of been a pusher like, I want the PE people to handle the health part and the Sex Ed and all that. I just think they need as difficult a task as everybody else. . . . I see an opportunity here for that to become embedded in that part of our cuniculum and become a long-term thing, but I also see resistance. I mean we’ve gone through many trials with our PE department. . . .You’ve got to stay on top of that and monitor, monitor, monitor, and so we do. However, Lucy Miller reported that implementation plans have only recently been established at the secondary level, in contrast to what was shared by Dr. Hughes. She indicated at grades seven through twelve, “There was no implementation, so that’s a big problem, because teachers change. There was no home, there has been no place to put it.” The recent MDE graduation requirements paved the way for a required health education class, “so what we did last year is spend quite a bit of time getting a high school curriculum.” Teachers were trained over the summer, “So I am believing that it’s going to be taught and I know the teachers, so I’ll be over there to kind of see that things are done.” In contrast, she is now concerned about implementation at the elementary and middle school levels. When the County Abstinence Program “lost their funding” at the end of last year, this meant the CAP educators would no longer be available to teach classroom lessons, so she tried to bring the classroom teachers on board to assume responsibility for teaching it themselves. She commented, “Some of them are ready to 206 take it on, but what I’ve heard through the grapevine is, they’re not going to teach it.” The middle school is also problematic: “I was crying to Dr. Hughes the other day, so we’re going to try to work out some things in our middle school. Again, it’s not consistent, because they can’t find a home for it.” Thus, there is a contradiction between what is reported by the Superintendent and Assistant Superintendent about sex education implementation, and what was shared by Lucy Miller. Information on building implementation was not particularly helpful in clarifying sex education practices. When asked about sex education implementation and monitoring, the high school principal stated her responsibilities include Making sure I have highly trained in the right spot and I feel very strongly even though it’s not part of the mandate, that I have female and male instructors teaching the different areas. If they teach together that’s fine. Our girls have someone speak to the boys the same way, and the opposite perspective is very good. My responsibility is to make sure they have the tools necessary to teach it appropriately; to make sure our parents are informed and follow through. We had a pass or consent form sent out today, as a matter of fact, on that very piece. I guess mine is to make sure I can facilitate their ability to teach the materials. If she has specific questions, she knows she can call Lucy Miller, whom she reports is “really on top of things. . . . She meets with all of us to make sure we’re all up to snuff on what happens.” Ms. Fitzwell did not clearly confirm whether all high school students receive sex education through their coursework. Elementary principal Sam Hanson had even less information about sex education in the district. I haven’t had that much experience with it at this point. To be honest with you, what I could tell you about the Michigan Sex Ed legislation is that I handled forms from parents that said that they didn’t want their children to have it, and I just put those into a table to make sure that we didn’t educate those students in that. . . . It’s ironic. Today . . . I had to do some moving of the new office I’ll be in, and right there is the Sex Education Handbook 207 for the district. So I do know that each school has one, so I’ll be responsible for going through that and educating myself on that. He did not appear to be aware of what teachers are responsible for teaching, much less that there is apparent resistance about their responsibility for teaching lessons formerly delivered by County Abstinence Program educators. Challenges in Implementing and Monitoring PA 1 65-1 66 Overall, it appears Ms. Miller’s concerns about district implementation of Board approved sex education content are justified. There have been significant shifts in approved content and curricula, as well as who is assigned to teach what at the various levels. Ms. Miller believes that consistent implementation of sex education is inhibited by teachers’ reluctance to devote instructional time to it. She noted, “Teachers may agree with it, but you also know about the MEAP, you also have all this other No Child Left Behind, all those mandates, and so sometimes teachers are not willing.” Rather than seeing it as a priority, they view sex education as “an add-on.” In‘addition, she is not an administrator, and is keenly aware of her limited ability to enforce or monitor implementation. She has been presented with a paradox by the district and the Assistant Superintendent, who has washed her hands of monitoring sex education. When asked what she does to monitor implementation, she replied, “Um, I am not responsible for any of that, and Lucy Miller does all of that.” She acknowledged she is “much more careful with the implementation of the NCLB.” From Ms. Miller’s perspective, she reports, “The job description is I am not out policing to make sure that it’s done.” In addition, as she is still in the teachers’ union, “it makes it very difficult.” She also indicated she’d had recent discussion with Dr. Hughes on the topic of 208 monitoring: “1 said, ‘Now this is trained up, we’re getting ready for our new curriculum, and so how do we know they’re going to do it?’ She said, ‘Well, we don’t really know.”’ It makes sense that monitoring would be facilitated at the building level. However, Ms. Miller finds communication of requirements is different than ensuring building follow-through. She stated, “We go to the Admin which is all the principals, and we say, ‘Here’s the new thing, this is what we’ve done, we let them know.” She offers to attend staff meetings to share information, and some will take her up on it, while others say they don’t have time on the agenda. “So then that filters down and gets weaker and diluted more and more as you go.” She senses the principals sometimes tire of her “being a cheerleader” for various health-related programs, understanding that her priorities are not necessarily shared or supported in the buildings. She also finds MDE requirements and available district resources are sometimes in conflict. This relates to the new health endorsements required for teaching sex education at the secondary level. “Some PE teachers were not high qualified in Health Education, so that was a challenge,” especially as the district has tried to figure out where to assign sex education within the courses offered. Overall, despite Dr. Hughes’ claims the district is in “full compliance” with PA 165-166 requires, Ms. Miller believes that while there may be good intentions, the district is not in complete compliance, finding implementation to be complicated and messy. Nonetheless, she welcomed PA 165-166, “because it opened up an opportunity to really look [at sex education]. . . . I think that was refreshing and I think it was needed.” 209 Summary of Themes in Steele’s Response to Legislative Mandates There were a few similarities, as well as distinct differences in Steele’s responses to NCLB and PA 165-166. The initial stages of response to both legislative mandates were similar, including relatively intense periods of information gathering, discussion, and decisionmaking about district implementation. In both cases, administrative and staff resources were marshaled to assess requirements. There was significant collaboration between district educators and External Partners, with other stakeholders included later on in the process. Thus, both mandates induced a period of preoccupation with district response to compliance requirements. This is where the difference in district responses to NCLB and PA 165-166 became apparent. The preoccupation with compliance requirements was expressed differently with NCLB. Dr. Hughes’ significant knowledge of NCLB, stemming from her MDE experience, helped to install her as the district authority on compliance requirements. Superintendent Edmonds entrusted her with making sound recommendations for implementation. Dr. Hughes was instrumental in educating Steele staff members, which suggests she and Superintendent Edmonds recognized the importance of collective responsibility and accountability for Steele’s work on NCLB goals. Requirements were assessed, and responsibilities were assigned to various administrators and staff members. However, Dr. Hughes’ approach also appeared to establish a tone of “letter of the law compliance.” It is not entirely clear whether this helped to leverage district change, or whether it has created greater preoccupation with the “busy work” of compliance requirements, rather than making the deep changes necessary to improve student achievement. Certainly, the challenges of deep change are 210 significant in a district with high rates of economically disadvantaged students and families. Though compliance with NCLB was expected, there were apparent issues with its implementation at all levels. Perhaps most significantly, there was evidence of inconsistencies in building implementation and monitoring, and insufficient evidence to suggest widespread support of NCLB’s ideals and goals in Steele’s classrooms. Without knowing whether school and classroom practices have really changed, it is nearly impossible to measure the effectiveness of Steele’s response to NCLB. What can be said with some confidence is that responsibilities were assigned, and mostly carried out on paper, particularly at the Central Office level. It was less clear what took place “out in the district.” And given traditional district values, enacted through the practice of “compartrnentalizing” special education students, as evidenced in Steele’s “Focused Monitoring Report” (Appendix B), it seems likely Steele has a long way to go in fully realizing the goals of NCLB. With PA 165-166, responsibility for the work of assessing and implementing the requirements appeared to be handed off fairly quickly to the Comprehensive Health and Human Services Coordinator, Lucy Miller. While Dr. Hughes had a role in working on curriculum alignment, she assigned monitoring of implementation to Ms. Miller, indicating she believed there was less likelihood of the state coming down with a “hammer” if things were not implemented correctly. Responsibility for PA 165-166 did not appear to be broadly shared by Steele administrators, unlike NCLB. Without the authority to truly monitor, nor accountability mechanisms at either the district or building levels to provide feedback on classroom implementation, Ms. Miller was hard pressed to 211 ensure effective implementation. In fact, sex education did not appear to have “a home” at the secondary level, until the state graduation requirements helped to create a place. At the elementary level, future implementation of sex education may be inconsistent, as responsibilities have returned to classroom teachers following loss of grant-funded sex educators to deliver lessons. One has a sense of sex education being banished to the dark comers of the classroom, overshadowed by increased academic expectations under NCLB. Hence, while cabinet level administrators asserted the district was fully compliant with both NCLB and PA 165-166, it appeared far greater importance was assigned to NCLB compliance, both in terms of administrative resources dedicated to it, and how it was implemented and monitored. While the Board and district administrators expressed the importance of sex education, their actions, other than those of Lucy Miller, did not match the rhetoric. Instead, the district has invested the bulk of its resources in responding to NCLB. Comparison of Patterns and Themes from F airview and Steele Pilot and case study data was presented in previous sections to describe and explain the responses of F airview and Steele to NCLB and PA 165-166. In this section, a comparison of patterns and themes from the districts is presented. This includes discussion of contributing factors stemming from each local context, as well as similarities and differences in the study districts’ responses to NCLB, PA 165-166, and then across the two legislative mandates. 212 Diflerent Local Contexts and Contributing Factors The study districts were selected for their differences on a number of variables, including student enrollment and setting. As a mid-sized district in a university setting, F airview has the advantage of higher per-pupil funding, a more educated parent population, and significant cultural and economic diversity amongst its students. While all districts have local politics, F airview’s context has been described as “highly politicized,” with parents and community members often bringing competing demands to the table. Steele, in contrast, has about double the enrolhnent in an urban setting, fewer dollars per student (though with more federal grant firnds), more students within its economically disadvantaged subgroup, and a less educated parent population, with different community pressures. As the studies commenced, a clear picture of factors contributing to each district’s response to legislative mandates emerged. They have challenges in similar areas, including leadership, decreasing revenues, community context and reputation, and district capacity and resources. Within the areas, the particular challenges differ somewhat. A comparison of these findings is presented in Table 5. In the area of leadership, both districts have experienced significant reductions in leadership positions, as well as some support positions. However, in Steele, these reductions were primarily addressed through retirements, leading to greater stability of leadership over time. In Fairview, there was an additional, marked pattern of turnover in leadership positions, through a combination of forced resignations, attrition, and retirement. The reduction of positions in both districts has resulted in administrators taking on additional responsibilities, sometimes outside of their area of expertise. In 213 Table 5. Comparison of contributing local factors to Fairview and Steele’s responses to legislative mandates. Contributing Factors in Contributing Factors in Steele Comparison of Contributing Fairview Factors in Fairview & Steele Leadership I Significant turnover in all I Significant reductions in I Steele has had greater Central Office leadership leadership positions stability of leadership. positions since 1999 I Reductions in I Redefined leadership I Both districts have administrative and support responsibilities consolidated many staff positions leadership responsibilities into fewer positions. I Consolidation of I Consolidation of I Leadership responsibilities responsibilities within responsibilities within for mandates in both remaining positions remaining positions districts require increased collaboration between positions District Revenue I Declining enrollment and I Declining enrollment and I Decreased revenue available revenues, partially offset by revenues in both districts. increased Schools of Choice I Loss of a federal grant I Both districts have closed a students I Decreased flexibility of school and “downsized” Title I schoolwide funds administration I Decreased reimbursement in Special Education Community Context and Reputation I “Highly politicized” I Low student achievement I Both have community community: high and graduation rates pressures, expressed in expectations and competing I Poor public reputation different ways demands I Desire to improve I Perceived urgency around NCLB in Steele District Capacity and Resources I Insufficient capacity and I Insufficient capacity and I Common finding in both resources resources districts: work has increased, while financial and human resources are fewer I Decreased capacity constrains districts’ response I Discretion is exercised about how to implement legislative mandates addition, the nature of mandate requirements has increased the need to collaborate across positions, with administrators in curriculum and finance working together on 214 programming and budgets for Title I, for example. Perhaps more significantly, the expectations of NCLB make it nearly essential for administrators at all levels to collaborate and share responsibility for increasing student achievement, at the same time fewer people are available to do the work. Decreasing revenues was a common factor in both F airview and Steele, contributing to how they responded to the legislative mandates. Both are districts of declining student enrollment; Fairview has partially ameliorated this trend through increasing its enrollment of Schools of Choice students. Steele, on the other hand, as a district with lower per-pupil funding, is more reliant on federal and state grants to do some of the work they find important, particularly with a higher proportion of economically disadvantaged students fiom families with less education. Loss of the Reading First grant, along with decreased flexibility in Title I schoolwide funds, has been perceived as a blow to Steele’s ability to respond to students’ needs, as well as expectations under NCLB. Steele is also experiencing decreased special education firnds, as the reimbursement for its services to students is declining. Contributing factors in the area of community context and reputation highlights some of the differences in Fairview and Steele. Fairview’s context has been described as “highly politicized.” Student achievement is relatively high, parents tend to be involved, and the district often faces competing demands from the community. In contrast, Steele has been dogged by low student achievement and graduation rates, though evidence indicates a trend of improvement. There was concern expressed in Steele about their poor public reputation, and a perceived need to pull together to improve things for its 215 students. Though the nature of the community’s concerns differed, it was apparent there was significant pressure experienced in both districts. Finally, both districts experienced capacity and resource issues as they responded to NCLB and PA 165-166. Fairview and Steele administrators alike reported increased responsibilities, more work to do, and less administrative and staff resources to get the work done, effectively constraining their responses. In this context, it is apparent district administrators made choices about where to focus their time and energy, as described in the next sections. F airview and Steele ’s Responses to No Child Left Behind Many of the contributing factors to Fairview’s and Steele’s responses to legislative mandates, described in the previous section, reverberated in the stories emerging from the interviews and document analysis. The tenor of Steele’s response, perhaps related to its lower student achievement and its reputation as a “coming from behind” district, appeared to be marked by more urgency. Fairview had perhaps less at stake and may have perceived it had less to gain under NCLB, as its student achievement was generally higher. In addition, Fairview had experienced so many leadership changes; it was more difficult to construct its response to legislative mandates as enacted through its administrators. Differences notwithstanding, similar patterns surfaced in comparing the data and findings from F airview and Steele. Both districts appeared to have a better handle on bureaucratic responses to basic compliance standards than leveraging NCLB values and purposes to implement deep changes in educational practice. 216 Bureaucratic Responses to NCLB Compliance Standards Both Fairview and Steele managed an effective bureaucratic response to concrete compliance requirements. In the early months following NCLB’s passage, their responses were marked by information gathering through parallel channels and resources for technical assistance, including MDE and/or the US. Department of Education, their ISDs, professional associations, and colleagues in like positions. Thus, they relied heavily on external partners to provide and synthesize key information. Based on data from the external partners, MDE and ISD consultants also developed a more extensive, mutual support system as they collaborated to provide technical assistance to districts. In Steele, as the Assistant Superintendent and her administrative assistant had both worked at MDE, they may have substituted locally for MDE in some ways as transplants to Steele, bringing with them a top-down, compliance-based response model. Before implementing NCLB locally, both districts entered an intense period of internal communication, assessment of how to implement various requirements, assignment of responsibilities to individuals and groups of individuals, and collaboration to bring district expertise and resources. In both Fairview and Steele, while the superintendents played a role in discussion and decision making, it appeared they relied heavily on administrators with specialized knowledge and expertise related to their positions. While superintendents may have made decisions about assignment of responsibilities and resource allocation, other central office administrators took up the daily work of implementation and monitoring. This pattern may have negatively affected building level responses, as these administrators appeared to have much more limited authority to supervise NCLB implementation by building administrators. 217 Thus, implementation of requirements appeared to be cleaner and more consistent at the cabinet level in both F airview and Steele, with the central bureaucracy responding effectively to basic NCLB compliance requirements. And in many ways, concrete compliance tasks are easier than the long-term work involved in significant educational reform, leading to more immediate, predictable results. The central office bureaucracy in F airview and Steele appeared well-equipped to handle superficial compliance work. Inadequate Connections between NCLB Core Purposes and District Work Both Fairview and Steele struggled to effectively connect the core purposes of NCLB to their educational practice. NCLB aims to achieve equality in educational opportunities and outcomes for students, representing a significant shift in purpose, away from the traditional practice of simply keeping kids safe and in school, while providing plenty of pathways to graduation. Fairview and Steele administrators did not consistently report these values were embraced throughout their districts, either by administrators or teachers. This lack of connection between NCLB and important district work was evidenced by uneven understanding and implementation of NCLB requirements at the building level, as well as administrators’ expressed views of NCLB. As responsibilities for NCLB were diffused beyond Central Office to building administrators, understanding and implementation were markedly less consistent. In both districts, there was confusion about the nature of building level responsibilities for NCLB, as well as how effective school implementation might look like. This raised questions about how clear, systematic, and consistent the superintendent and Central Office administrators had been in defining principals’ roles and responsibilities under NCLB, as well as whether accountability structures were sufficient to ensure good 218 implementation. Furthermore, NCLB is but one factor in a series of changes to how building leaders’ roles are defined, shifting the focus over time from management to instructional leadership. Thus, building leaders’ understanding and implementation appeared quite inconsistent. Given these factors, it is not surprising that administrator and teacher accountability under NCLB seemed to be lacking. Administrators in both districts described varying perspectives on NCLB as well. While a few key administrators welcomed NCLB as a lever for work they regarded as important, some viewed it as far more problematic than helpful. Out of all administrators interviewed, one explicitly mentioned NCLB as a policy framework for school improvement. While most realized its inherent value, the majority of building principals, leaders for improved building and classroom practices, did not seem to make the connection to its role in school improvement. Thus, it is apparent that both F airview and Steele have work ahead to create deeper meaning around NCLB beyond bureaucratic efforts to comply. Under NCLB, success is defined by improving student achievement scores. However, it seems clear that small gains in improvement in Fairview and Steele may “hit the wall” unless they are able to move behind the “low-hanging fruit” of relatively easy fixes. The work of NCLB requires long-term, deep changes in district, school, and classroom practices. F airview and Steele ’s Responses to PA 1 65-1 66 Local contributing factors from F airview and Steele were also manifested in their responses to PA 165-166. Rapid turnover of administrative responsibility for sex education from F airview’s former special education director and nurse, to the former curriculum director, to me, likely inhibited F airview’s response. Steele had a significant 219 advantage in having a Health and Human Services Coordinator, a family nurse practitioner, to champion sex education in the district. As an educator with eleven years of experience in her position, working within an established Comprehensive School Health framework, Steele benefited from Lucy Miller’s expertise. In addition, the Superintendent and Assistant Superintendent helped to marshal district resources to align curriculum, provide training, and monitor implementation. Despite these differences, there were sufficient similarities in Fairview and Steele’s responses to develop clear patterns and themes. Early Compliance Work The initial phase of response in both districts was characterized by a flurry of information gathering about PA 165-166 requirements and consultation with external partners. Internal discussion and collaboration resulted in breakdown of tasks and responsibilities. In both districts, these responsibilities were handed off rather quickly to a couple of key individuals. In F airview, the curriculum director, nurse, and/or curriculum chairs began to work on curriculum alignment, identifying individuals in need of training, and formulating the Sex Ed Advisory Board. In Steele, the Assistant Superintendent worked periodically with the Health and Human Services Coordinator, Lucy Miller, but Lucy was primarily responsible for getting the work done with her nurses and external consultants, and overseeing implementation and monitoring. In both districts, the Advisory Committee of staff, parents, and other community members undertook theirlassigned roles under PA 165-166. Perhaps because of leadership shifts and a politicized community context, the Advisory Committee process in Fairview was marked by more turmoil and questioning than in Steele. However, Fairview and Steele 220 both appeared to complete administrative tasks of learning about and assessing mandate requirements, assigning responsibilities, forming their sex education advisory boards, aligning curricula and materials and getting them approved, and providing appropriate teacher training. Inconsistent Implementation in Schools and Classrooms It was also clear that implementation and monitoring in Fairview and Steele was inconsistent and fraught with problems. Trying to “find a home” for sex education at the secondary level, in both districts, frustrated consistent, effective implementation. New MDE teacher certification requirements for sex education also contributed to these issues. Principals’ understanding of the legislation, as well as their responsibilities for implementation and monitoring, varied significantly. And in both districts, there was expressed reluctance to devote instructional time to sex education. The one interesting difference between the districts related to PA 165-166 had to do with their underlying values. Several Fairview administrators verbalized frustration over having to teach sex education, wishing it could be turned back over to parents, even when they realized that might not be realistic or effective. In contrast, this was not mentioned by even one administrator in Steele. The difference in expressed attitudes may stem from a belief, though erroneous, that economically disadvantaged youth are at greater risk for early sexual activity and its attendant problems, resulting in a somewhat higher commitment to sex education in Steele. Weak Monitoring Finally, the monitoring of actual implementation is fairly weak in both districts. While the districts ensure teachers have the appropriate certification and training, they do 221 not monitor classroom practice to any significant extent. Teachers may complete the online Michigan Model logs, but unless parents express complaints, this is about as far as it goes. There were limited exceptions of a principal co-teaching lessons, and a couple of principals mentioned doing walk-throughs, but this was not consistent at each building. In addition, it appeared that large numbers of Steele middle and high school students may not have received any sex education, until the state graduation requirements leveraged a change in local course requirements. Thus, while Fairview and Steele adequately responded to concrete compliance requirements of PA 165-166, their implementation and monitoring was flawed and inconsistent. Various factors appeared to influence this pattern in both districts, including the perception that the state was not actively monitoring implementation, allowing districts to satisfy basic compliance tasks, while flying under the radar in terms of actual implementation. Summary of Patterns and Themes in Responses to Legislative Mandates NCLB and PA 165-166 are quite different in their breadth, specificity of requirements and accountability structures, and generally understood or perceived consequences for noncompliance. F airview and Steele provided an interesting opportunity to study response to the different mandates, mediated by individual organizational characteristics and community contexts. In spite of the different contexts, common findings emerged, including the processes facilitated by the bureaucracy in response to mandates, problems with implementation and monitoring, differences in intentionality toward the two mandates, and the exercise of administrative discretion in response to mandate requirements. 222 Observed Bureaucratic Processes in Response to Legislative Mandates In response to both NCLB and PA 165-166, the districts each participated in a period of information gathering, consultation with external partners, and assessment of mandate requirements. Both districts went through a process of internal discussion, scrutiny, and assignment of responsibilities. In fact, even when posed with issues of administrative capacity and turnover, as well as instances of having to reassign responsibilities to ensure completed work met compliance standards, both Fairview and Steele had their bureaucratic responses to NCLB and PA 165-166 under control. Problems with Implementation and Monitoring Both experienced similar challenges in consistent implementation of NCLB and PA 165-166 requirements at the building and classroom levels. There seemed to be various factors affecting implementation. It was clear not all administrators understood or had defined how to implement and monitor the requirements in their buildings. In addition, there were conflicts in values and beliefs between those embedded within the mandates, in contrast to the underlying values and beliefs enacted in the district and by its educators. Given these conflicts, it is not surprising Fairview and Steele were less successful at connecting the purposes of the legislative mandates with the work considered important in each setting. Furthermore, Fairview and Steele administrators appeared to be quite preoccupied with the work involved in meeting compliance requirements. There may be a number of contributing factors to explain this pattern. It is possible that early compliance work is a necessary “stage” in a district’s response to legislative mandates, and that completion of these tasks “clears the way” for deeper, long-term work. It is also possible that 223 compliance work is exactly what the educational bureaucracy is designed to handle: while messy, it is easier to understand and complete, whereas deeper reforms of educational practice are notoriously difficult to achieve. Thus, administrators may choose to focus on what they believe they can control. And finally, it seems apparent that Fairview and Steele have decreased administrative capacity to respond, at the same time their workloads have increased because of mandate requirements. Ensuring basic compliance work is completed allows districts to maintain federal and state funding. They can hold their public reputations relatively intact while trying to sort out long-term issues over time. Differences in Intentionality in Response to Legislative Mandates The intentionality with which Fairview and Steele responded to NCLB and PA 165-166 was strikingly different. Both spent more resources, financial, human, and time, responding to NCLB than PA 165-166. And both appeared to be more concerned about effective implementation of NCLB, perhaps because they see it as more closely tied to what they perceive as the core purposes for schooling. Moreover, PA 165-166 provides an opportunity for local school boards to “opt out” of teaching sex education, other than HIV/STIs education. NCLB does not offer this flexibility. The consequences of noncompliance and failing to make AYP under NCLB are widely known, with districts reluctant to surrender any more local autonomy, or funds, to the government. The consequences of noncompliance with PA 165-166 are not as well known. For these reasons, districts may find it easier to “ignore” PA 165-166 requirements. Furthermore, it may be hypothesized that what stakeholders value is monitored more closely than things they deem less important. In this case, the federal government, 224 MDE, ISDs, as well as F airview and Steele, appear to place greater value on NCLB, as it is certainly monitored more closely, with regular, public reports of school and district performance. Exercise of Administrative Discretion Given decreasing capacity and resources in both F airview and Steele, it appears they have exercised administrative discretion, either overtly or covertly, to pay greater attention to NCLB than to PA 165-166. Limited resources, not the least of which is instructional time, have compelled districts to choose between competing demands and values. It appears Fairview and Steele administrators have chosen in favor of NCLB and its focus on improving student achievement. A final, important point about the exercise of administrative discretion in Fairview and Steele concerns the nature of organizations and how they respond to external demands for change. In this study, these demands are imposed through federal and state legislative policy mandates. However, the mandates pose K-12 districts with an interesting paradox: while the educational bureaucracy appears to be well-equipped to satisfy concrete compliance requirements, bureaucratic action does not appear sufficient to produce the deeper changes in practice needed to fulfill the spirit of the law. Thus, Fairview and Steele appear to be struggling to apply bureaucratic solutions to change that may require a response outside the realm of bureaucratic control. This thesis will be explored more fully in the last chapter, through a model presented to describe and explain districts’ responses to legislative policy mandates. 225 CHAPTER V CONCLUSIONS Introduction The purpose of this study was to describe and explain the response by K-12 districts to policy mandates introduced through federal and state legislation. To inform the study, I reviewed the literature to examine the historical evolution of educational purpose and values in the United States; the relationships between the economic, political and educational systems and how they have influenced purposes for K-12 education; how society attempts to resolve perceived social and economic problems in its schools; and theoretical concepts that predict how K-12 districts might respond to legislative mandates. Contributions from the research literature were summarized in Chapter I. A conceptual framework and exploratory questions, informed by the literature, were presented in Chapter 11, along with the research methodology guiding the study. Information and research on the two legislative mandates included in this study were outlined in Chapter 111. Chapter IV presented data from interviews and document review collected from the External Partners, or representatives from the Michigan Department of Education and two Intermediate School Districts; and two K-12 districts. Data collection in the K-12 districts was conducted in two phases, including the pilot and case studies. Through within-case and comparative analyses of the data, I developed conclusions to describe and explain how two K-12 districts respond to legislative mandates. The conclusions are elucidated in this chapter. Study evidence and arguments are presented in support of the conclusions. The conclusions are based on the underlying 226 thesis, which is that legislative policy mandates pose K-12 districts with an interesting paradox: while the educational bureaucracy appears to be well-equipped to satisfy concrete compliance requirements, bureaucratic action does not appear sufficient to produce the deeper changes in practice needed to fulfill the spirit of the law. Thus, districts appear to be struggling to apply bureaucratic solutions to change that may require a response outside the realm of bureaucratic control. The organization of this chapter includes six sections. The first section returns to the exploratory research questions and initial conceptual framework, presenting a modification of the conceptual framework. The modified framework examines organizational relationships and responses to legislative mandates, and allows for presentation of findings related to the External Context and External Partners. The second section describes and explains K-12 districts’ responses to legislative policy mandates, elaborated through an abstract model, with study evidence used to support the claims made in the model. The third section summarizes study conclusions and reflections, examining the connections between the research literature and conclusions. Alternative explanations for study findings are offered in the fourth section. The fifth section outlines recommendations for additional research, while the sixth section considers significance of study findings. Exploratory Research Questions and Preliminary Conceptual Framework In presenting the conclusions, it is necessary to consider how the evidence measures up against the research questions and preliminary conceptual framework that informed development of the study. The study was designed to gather information relative to three exploratory research questions: 227 1. How do K-12 administrators learn about and assess mandate requirements? 2. How do K-12 administrators respond to mandates and monitor district implementation? 3. What administrative challenges are created by these mandates? What conflicts do they pose for districts? As illustrated in the preliminary conceptual fiamework (Appendix A), legislative mandates are “passed down from above” at the federal and state levels, channeled through intermediate school districts, and presented to K-12 districts for implementation. Through data collection and analysis, the conceptual model was modified to reflect some of the research findings more peripheral to this study, represented in the Conceptual Framework of the Educational System (Appendix F). These findings revealed related information about the workings of the educational system, pertinent to how legislative mandates are “passed down” through the External Context and External Partners: I The language in legislative policy mandates is not always clear and specific. Depending on the particular mandate, a great deal of time may be required to further define mandate requirements at all levels. This may involve significant collaboration between representatives of the federal and state governments, External Partners, and local districts. I The language in legislative policy mandates is often subject to interpretation. At times, it appears there is “bargaining” between representatives of the federal and state governments and External Partners over interpretation of the language and what to actively enforce. I State representatives and External Partners may exert discretion about particular requirements to push or deemphasize, relative to its perceived importance, state and local capacity issues, and whether it is perceived noncompliance will be discovered and punished. I In Michigan, intermediate school districts are increasingly called upon to help MDE interpret and disseminate information relative to mandate requirements, as well as provide technical assistance. 228 I K—12 districts also exercise discretion in how they choose to respond to mandates. This finding adds to prevailing organizational theory. In the current context of increased administrative responsibilities related to mandate requirements, as well as increased financial constraints, fewer people are available to due more work. Thus, the bureaucracy has been reduced, forcing administrators to exercise increased discretion about what mandate requirements to actively respond to and which to ignore. This will be further explored in the next sections. The primary focus of the study was the response of K-12 districts to legislative mandates. It was beyond the study parameters to fully examine all of the interrelationships and dynamics within the educational system in moving legislative mandates into local districts. Thus, in order to describe and explain the response of K—12 districts to legislative mandates, it was necessary to develop a more detailed model of districts’ responses, providing a expanded view of the lower sections of the Conceptual Framework of the Educational System. To this end, a four stage model, “Stages of K-12 Districts’ Compliance with Legislative Mandates” (Appendix G) is elaborated in the next section. Stages of Compliance Model The “Stages of K-12 Districts’ Compliance with Legislative Mandates,” more simply referred to as the “Stages of Compliance” model, is presented as an abstraction of the stages K-12 districts exhibit in their response to legislative mandates. As I was analyzing the emergent patterns and themes in the data, there appeared to be a significant correlation to the model developed by Hall and others, the Stages of Concern and Levels of Use from their Concems-Based Adoption Model, more commonly known as CBAM (Hall and Hord, 2001). The Stages of Concern (SoC) model was advanced to show the “developmental pattern to how feelings and perceptions evolve as the change process unfolds” (2001, p. 57), starting with how an innovation affects individuals personally, 229 moving to implementation issues, and in the end stages, a focus on the impact of the change. Furthermore, Hall and Hord’s “Levels of Use” (LoU) was developed to explain the behavioral side of change, or “how people are acting with respect to a specified change” (2001, p. 81). These levels of use range from nonusers (Nonuse, Orientation, and Preparation) to users (Mechanical Use, Routine, Refinement, Integration, and Renewal). Thus, their work developed a cogent framework for describing and explaining individuals’ affective as well as behavioral responses to innovation. Hall and Hord’s work further focuses on the magnitude of innovation, noting that “change initiatives are not typically centered around a single innovation, but rather a bundle of innovations” (2001, p. 8). The Hall Innovation Category (HiC) Scale “rates innovations by the amount of effort required to achieve successful implementation and the number of changes produced in people, organizations, and systems” (pp. 8-9). Recognizing the complexity of many legislative mandates helps to keep the magnitude of change required in perspective. It also concentrates attention on the interplay of individual and organizational responses to change, which is worth examining in the context of K-12 districts’ responses to legislative mandates. This is a critical perspective when weighed against my thesis. If deep change at the classroom level requires a response mediated by the organization, but is outside the realm of traditional bureaucratic action, it is essential to then understand how changes are both perceived and effected at the classroom level. Jus as discretion is exercised at other levels within the educational system, it seems apparent it is also exercised at the classroom level; thus, for changes consistent with the spirit of policy mandates to be reflected in classroom practice, an 230 approach to change that touches individual teachers, influencing them to practice differently, is needed. It is important to note that while thoughts about the 80C and LoU were in the back of my mind as I developed my “Stages of Compliance” model, I was not actively referring to it or seeking a fit between CBAM and the data from this study. Rather, I endeavored to let the data tell its own story and develop an internal logic from emergent patterns and themes, seeking correlations afterwards. In retrospect, I believe this was a sound decision, enabling me to focus on the data with fewer constraints imposed by existing models. Thus, the Stages of Compliance outline four stages of K-12 districts’ compliance with legislative mandates, incorporating multiple layers of factors that mediate district response, characteristic responses or behaviors of individuals and groups at each stage, local reactions or characteristics that either enable or inhibit the district’s work at a particular stage, and the resolution of each stage, which defines the hallmarks of satisfactory conclusion of each stage. Significantly, the first two stages center on bureaucratic responses to mandates, while the latter stages address deeper layers of change. In the next sections, each stage will be described and explained using study data outlining Fairview and Steele’s responses to NCLB and PA 165-166. The conclusion section generalizes study findings to K-12 districts responding to other legislative mandates. Stage 1: Building Awareness & Understanding Similar to Hall and Hord’s early SoC and LoU, Stage 1 focuses on how districts build awareness and understanding of legislative mandates. Available resources and 231 experts mediate district work, both internally and externally, pertinent to the mandate and areas affected within the organization. The district responds by gathering information through various channels, including correspondence, online resources, e—mail, professional associations, and conference participation. The district’s response may be enabled or inhibited by those within the organization. Resolution of this stage depends on the district developing a working understanding of the legislative mandate and its components. It is noted that if the district does not perceive negative consequences may ensue from noncompliance, or benefits may not be incurred through compliance, the district’s response may end at this stage as it exercises discretion or “opts out” of further compliance efforts. Stage I through the Lens of F airview and Steele '3 Responses Fairview and Steele’s early responses to both NCLB and PA 165-166 were quite similar in many respects, and reflect the primary tasks of Stage I. In response to each mandate, F airview and Steele built their awareness and gathered information through comparable channels, including MDE representatives and conferences, websites and online resources, ISD resources, professional associations, and the written legislation itself. External Partners appeared to be a critical resource to both districts as they learned about NCLB and PA 165-166. With NCLB, the main difference was that Steele had Ruth Hughes as its Assistant Superintendent for Student Achievement, a transplant from the MDE Office of Field Services. As such, she represented MDE itself within her own district. As she reported, however, she lost her “expert status” fairly quickly, with other administrators reluctant to accept her word at face value without confirmation from 232 MDE. Steele also had greater internal resources for responding to PA 165-166, with Lucy Miller in a specialized role as Health and Human Services Coordinator. The districts also displayed similar enabling and inhibiting reactions to NCLB and PA 165-166, based on administrator and district values and beliefs relative to the mandates. It was apparent there were administrators in both Fairview and Steele who “bought into” the values underlying NCLB and PA 165-166, as well as those who avoided or resisted mandate requirements. NCLB Stage I compliance. Pertaining to NCLB, central office administrators in both districts appeared to embrace the values of universal proficiency for students and reducing achievement gaps between subgroups. However, there also seemed to be inhibiting reactions demonstrated by avoidance of mandate requirements in both districts. In Steele, some of the resistance appeared to partially stem from frustration over certain requirements, for example, the highly qualified teacher piece, or funding constraints. However, both districts displayed an undercurrent of doubt about whether universal student proficiency in core areas is achievable or even desirable. And if administrators were less likely to share personal reservations, both districts certainly represented resistance at the classroom level, citing the failure of many teachers to practice behaviors consistent with the belief that all children can meet proficiency standards, as well as a reported tendency in Steele to “compartmentalize” and isolate students in special education settings. Nonetheless, at least at the district level, both F airview and Steele have appeared to resolve the primary task of Stage I compliance with NCLB, as evidenced by the working knowledge of responsible central office staff of the legislation and its 233 components. This is primarily a bureaucratic task and response. It was less clear that building level administrators all had a significant working knowledge of NCLB, beyond the basics of recognizing the threat of the “hammer” if schools failed to make AYP. While the belief might linger that NCLB would be significantly altered in the future, administrators at least seemed to recognize that they were “stuck with it for now,” and would have to continue their efforts to comply. PA 165-166 Stage I compliance. Stage I also helps to explain F airview and Steele’s responses to PA 165-166. Both spent time on Stage I tasks gathering information from MDE, their respective ISDs, and the written legislation. Steele had the advantage of an internal “expert,” a Health and Human Services Coordinator, Lucy Miller, who had significant tenure in this role, and had networked within the community to develop a Comprehensive Health model in the district. Fairview appeared to have more issues with early PA 165-166 compliance, perhaps partly because it had less internal capacity for responding effectively. Without an expert administrator with specialized knowledge of health education, it was met with greater early resistance, both at the administrative and advisory board level. In addition, Fairview administrators verbalized more conflicting beliefs about the value of the legislation, stating they often wished responsibility for sex education could be returned solely to parents. However, as they did not actively pursue the necessary steps to have the school board drop sex education in Fairview, and as it did appear they had a working knowledge of mandate requirements, they proceeded to Stage 11. Similarly, Steele central office administrators satisfactorily resolved Stage I tasks as well. 234 Stage 11: Focusing on Internal Management Issues: “The Letter of the Law ” Stage II compliance focuses on internal management issues that arise as districts respond to mandate requirements. It is noted these issues are roughly analogous to the “task” concerns of Hall and Hord’s 80C, and the LoU characteristics of early use. Compliance at this stage appears to be flavored by adherence to the “letter of the law” and bureaucratic actions to regulate its response. Districts’ responses at this stage are mediated by several factors, including the availability of external partners to help with assessment of mandate requirements, implementation decisions, and problem solving. Internal factors also mediate district response, including availability of human and financial resources; district history, such as its leadership history and past patterns built up in response to other innovations; and its deep-seated cultural beliefs and practices about educational purposes and the nature of teaching and learning. Districts’ responses at this stage include breaking down compliance requirements, examination of consequences of noncompliance, exploration of internal resources that can be tapped to assist with tasks, assignment of responsibilities to administrators, and additional training and communication for responsible parties. This work is enabled by purposeful attempts to organize and facilitate the district’s response, and harnessing external resources to assist the district. The work may also be inhibited by a kind of reactionary panic that can interfere with work completion, as well as too much preoccupation with rules, regulations, and details, instead of keeping legislative intent as the driving focus. Thus, this stage is characterized by an emphasis on “letter of the law” compliance with specific requirements, while deeper structures and practices related to schooling continue 235 unexarnined. Traditional bureaucratic practices assist with completion of compliance tasks in Stage II. It is apparent that districts may remain in this stage for a long time, particularly if it is perceived that either superficial compliance may satisfy external requirements, or that there will be a lack of external monitoring or consequences from the external context. However, resolution of concrete management issues may be necessary before districts’ attention can be turned toward addressing deeper issues of change. Stage 11 through the Lens of F airview and Steele ’s Responses Similar patterns were observed in both districts relative to Stage II. For both NCLB and PA 165-166, Fairview and Steele administrators spent time breaking down compliance requirements for their districts. This involved a great deal of time spent with External Partners, mostly MDE and ISD consultants, to dissect and interpret the requirements, as well as possible consequences of noncompliance. Administrative attention then turned inward to assessing internal district resources and assigning responsibilities for compliance with various portions of the mandates to district staff. In both districts, this involved a sequence of central office or cabinet level discussions to sort through local implications of the mandates, and to assign responsibilities appropriately, followed by meetings with building level administrators. Further trainings were often sought to build administrator capacity for responding effectively, along with continued participation in ISD meetings and inservices. NCLB Stage II compliance. As a more complex and comprehensive legislative mandate, it appeared NCLB commanded many more administrative resources, both in the number of administrators and the amount of time involved in both Fairview and Steele 236 than PA 165-166. Both districts appeared to exhibit enabling and inhibiting reactions related to NCLB. It seemed there was both purposeful activity, but also reactionary panic at times, depending on the particular compliance requirement and the quality of support available to address it. For example, the highly qualified requirement in Steele met with early resistance in the Human Resources Office, where things got “bogged down,” according to the Superintendent. Once they identified the problem and reassigned the responsibility to the Student Achievement Department, it was gradually resolved. However, this office was also criticized by one building administrator for overly rigid adherence to the “letter of NCLB,” which may have inhibited communication and district implementation in other areas. In F airview, NCLB tasks related to Stage II were reportedly resolved more easily, perhaps because it is a smaller district. PA 1 65-1 66 Stage II compliance. Both Fairview and Steele appeared to resolve the tasks of breaking down compliance requirements and considering consequences of noncompliance, assessing internal resources and assigning responsibilities to administrators, and getting additional training as needed. They both successfully met the “letter of the law” in meeting compliance requirements, at least on paper. However, both met significant challenges in implementation. In F airview, there were challenges with the advisory committee process, as well as issues of inconsistent classroom implementation that became apparent through the teacher survey. Following episodes of reactionary panic and changes in leadership, the district utilized some external consultants to work with the advisory committee, and to a lesser extent, with teachers, to address identified issues. The work of the district still focuses on basic compliance, however. There are concrete issues of committee process, 237 district capacity, and teacher qualifications that may need to be resolved before the district can substantively address its sex education curricula and improve consistency of instruction. In Steele, the district worked very effectively for a couple of years with external consultants who assisted with classroom sex education instruction at the elementary level. However, sex education did not “have a home” at middle and high school until this year, which inhibited consistent classroom instruction for students. In addition, due to loss of grant funds, the elementary sex education program is facing new challenges, with general education teachers resistant to accepting responsibility for sex education in their classrooms. Thus, in spite of more capacity at the district level, Steele is also facing significant internal management issues that hinder its implementation of sex education. Therefore, while both districts appear to have mostly resolved Stage 11 tasks relative to NCLB, internal management issues for implementation of PA 165-166 in both Fairview and Steele have stalled progress at Stage II. In addition, there is an undercurrent in both Fairview and Steele that superficial compliance with PA 165-166 may be “good enough.” Without rigorous monitoring in place, and fewer perceived consequences for noncompliance, district energy in Fairview and Steele appeared to be focused away from PA 165-166. Stage III: Confronting District Barriers to Change Stage III marks a shift from tasks the district has traditionally managed through bureaucratic practices to dealing with internal sources of resistance to change. It is important to recognize how districts are affected by the relative size of innovation mandated through legislative policies. In cases where the innovation is relatively minor 238 in scope, involving work that may be handled at the bureaucratic level, the district may resolve these issues in Stage II, and never need to address Stage 111 work. However, when the innovation represents changes that are both complex and deep, Stage III compliance work may be initiated by districts committed to more significant change. Stage 111 work may be compared to Hall and Hord’s focus on the impact of innovation reflected in the latter SoC. In Stage 111, districts struggle with the notion that deeper changes in organizational and classroom practices are required; as such, the LoU is complicated, as bureaucratic practices have stabilized, while use of deeper changes in practice is largely undeveloped. Thus, increased understanding and appreciation of mandate requirements mediate Stage 111. At this stage, districts may have experienced either positive or negative consequences related to early compliance work. Districts who have seen initial gains relative to mandate requirements may think their work is done, or may instead be motivated to continue additional work. Districts experiencing negative consequences may be either preoccupied with the consequences, or recognize their previous responses were inadequate to achieve mandated expectations. If the consequences include increased public reporting or scrutiny of district performance, this may influence the district’s Stage 111 work as well. Thus, a growing recognition that “business as usual” will not suffice to meet mandated outcomes mediates Stage 111 work, as well as available resources for leveraging change. In Stage III, district responses involve a shift of focus beyond bureaucratic compliance to internal barriers to change. This engages the district in examining its cultural beliefs and practices relative to the mandates; identification of “gaps” between district practices, outcomes, and mandate requirements; greater collaboration across roles, 239 departments, and grade levels to brainstorm potential responses; increased efforts to align district resources to meet perceived needs; and increased accountability of district leadership. These responses are enabled by objective examination of evidence related to district performance and mandated expectations, along with efforts to change practice to meet requirements. Responses are inhibited by the inertia of past practices, structural constraints, deflecting responsibility by blaming others for negative outcomes, and a “wait and see” attitude, marked by a belief the external mandate will change. Stage 111 may be resolved by the increased collective will and commitment to the “spirit” of mandate requirements by a critical mass of individuals. This increased commitment is reflected by a change in espoused beliefs and values held by district and teacher leaders, with greater alignment to values embedded within the legislative mandates. The district also undertakes planning to support deep changes in practice relative to mandates. Stage III through the Lens of F airview and Steele ’s Responses Similar responses were observed in both districts relative to Stage III. Both districts seemed to be more focused on Stage 111 work pertinent to NCLB. This appeared to reflect differences in the legislative policies and district discretion about where to focus their energies. NCLB Stage III compliance. In meeting internal challenges to NCLB implementation, both F airview and Steele exhibited problems with developing the collective will and commitment to its spirit. While most of the central office administrators embraced the values, principals expressed conflicting values and levels of commitment to NCLB implementation in their buildings. Furthermore, they were unclear 240 about their responsibilities related to NCLB or effective building implementation. Bureaucratic action in Fairview and Steele seemed inadequate to the task of getting others to “buy into” NCLB. Both districts recognized these challenges and demonstrated responses that attempted to refocus district attention on internal issues. Fairview adopted a new strategic plan for 2007-2011 (Appendix D), containing goals and strategies to improve educational practices. Steele’s assistant superintendent discussed her efforts to achieve a “laser focus” on meeting individual students’ needs. Work in each district included analysis of student performance data, work to align curricula to state standards, and efforts to improve classroom practice. However, both districts also reported the lack of accountability at both the administrative and classroom levels, as well as educators’ tendencies to blame students and families occupying certain subgroups for low achievement scores. In addition, Steele noted a long-standing practicing of “compartrnentalizing” and isolating special education students. Thus, neither district has resolved Stage III tasks, as there is insufficient evidence of widespread commitment to NCLB’s spirit and expectations. It is more accurate to say they are addressing Stage 111 issues. As it has only been five years since NCLB was enacted, and educational practices are widely noted for their resistance to change, more time may be needed for districts to demonstrate more developed responses to NCLB. PA 165-166 Stage III compliance. As noted previously, both F airview and Steele appear to have stalled at Stage II. There may be a variety of reasons for this. Both districts still have concrete issues to resolve, including teacher certification and where sex ed will be taught at the secondary level. Furthermore, they appear somewhat hampered 241 by resource issues. While Steele appeared to have successful implementation for a time, at least at elementary, loss of grant-funded consultants have disrupted consistent practice. Not having the benefit of an internal comprehensive health expert, Fairview does not appear to have approached Stage 111, except perhaps in its work to examine gaps between classroom practice and PA 165-166 requirements. In addition, the issue of what is valued by Fairview and Steele, and the specter of mandated outcomes and consequences under NCLB, has erected a protective shield around instructional time that a weaker mandate such as PA 165-166 may find difficult to penetrate. Thus, the issue with Stage III compliance with PA 165-166 is less an issue of whether the district can achieve mandated expectations, but whether it will choose to do so. Stage IV: Institutionalizing New Practices Relative to Mandates Stage IV represents an even filrther shift from tasks typically managed by the district bureaucracy, to institutionalization of new practices that stretch beyond bureaucratic control. Stage IV work also parallels latter SoC stages focusing on the impact of innovation and reflects a high LoU in refinement and integration of implementation. Whereas Stage III is characterized by districts’ struggles to address internal barriers to change, Stage IV builds on Stage 111 resolution to deepen intentional focus on implementation and evaluation of new practices. Stage IV work is mediated by increased attention to mandated outcomes, either positive or negative. Positive outcomes may further shift beliefs and values to align with the inherent values of the mandate, while negative outcomes may result in increased confirsion, restructuring, or disengagement. Available resources to support change also mediate district response, including expertise, time, and money. These factors influence 242 whether the district is successful in moving toward Stage IV resolution. Characteristic responses include an ongoing focus on implementing and evaluating new practices; increased accountability for students, teachers, school and district level administrators; and reformulation of departmental and district structures and functions to support mandated change. This work may be enabled by an increased emphasis on collective responsibility and accountability practices, and an increased willingness of the organization to change core practices. Reactions that may inhibit district response include inconsistent leadership, inconsistent accountability standards and practices, and an inability to leverage changes to support mandates systemically across departments and classrooms. Stage IV work may never be fully resolved. The work is characterized by deep changes in educational practices. However, additional change introduced through legislative mandates, shifts within the national, state and local context, and available resources contribute to dynamic instability of schools. This instability may help leverage district work, but also creates risk that districts may return to familiar, “old ways,” or find themselves facing new problems and dysfirnctional responses. Ultimately, it appears that districts are unable to mandate deep changes in educational practice through bureaucratic action; deep change may require innovation in response, as well. Stage I V through the Lens of F airview and Steele ’s Responses Stage IV work seems to be relatively uncharted territory in both Fairview and Steele. As neither district successfully resolved Stage III tasks relative to either NCLB or PA 165-166, there is little to describe relative to Stage IV responses. This leads to a critical question: do districts have the capacity to actually implement deep changes in 243 educational practice in response to legislative policy mandates? Further, do they know how to accomplish significant reform, have adequate resources, and will they choose to do so? These questions will be discussed in depth in the next sections. Conclusion and Reflections The previous sections presented a modified conceptual framework of the educational system and explicated a detailed model to describe and explain K-12 district’s responses to legislative policy mandates. This section examines the connection between the research literature and the overall conclusion of this study, which is that legislative policy mandates pose K-12 districts with an interesting paradox: while the educational bureaucracy appears to be well-equipped to satisfy concrete compliance requirements, bureaucratic action does not appear sufficient to produce the deeper changes in practice needed to fulfill the spirit of the law. Therefore, conclusions and support from the literature are presented in response to the exploratory questions, elaborating how K-12 districts learn about and assess mandate requirements, how its administrators respond to mandates and monitor district implementation, and administrative challenges and conflicts mandates pose for K-12 districts. As these conclusions lead to new questions, summative reflections are presented at the end of this section. How do K—12 administrators learn about and assess mandate requirements? Contributions from research literature offer predictions of how K-12 administrators tackle initial issues of building knowledge and assessing mandate requirements. Weber (1947) aptly observed that administrators wield power through application of knowledge; power is further developed by increasing a specialized 244 knowledge base “growing out of experience in the service” (p. 339). Thompson (1967) also noted that increasing knowledge is essential when administrators are confronted by a dynamic, heterogeneous task environment. Weber and Thompson’s theoretical concepts were validated through study findings on the behaviors of Fairview and Steele administrators as they learned about and assessed the requirements of NCLB and PA 165-166. It was clear they spent a great deal of time fulfilling these tasks through reading the legislation, attending MDE conferences and ISD inservices and meetings, and poring over information offered through a variety of sources. In keeping with Thompson’s theory, district administrators formed coalitions with knowledgeable, influential external partners from MDE and their ISDs, and relied heavily on them to help with defining, clarifying, and interpreting key mandate requirements. Preliminary work between External Partners at the federal, state, and ISD levels took place in preparation for partnering with districts. External Partners worked to develop consistent messages to share with local districts, and also appeared to engage in bargaining over interpretation of policy language and which standards to actively enforce. Furthermore, as predicted by Thompson (1967), increased task environment demands, introduced through legislative policy mandates, induced greater monitoring of the task environment, both by External Partners and K-12 administrators. One of the External Partners referred to “constant vigilance” and monitoring of federal and state websites. Fairview and Steele administrators maintained fi'equent contact with External Partners through multiple channels, sharing information with other district administrators. Local discussions at the central office level provided a venue for developing plans for district response. 245 Thus, in F airview and Steele, traditional bureaucratic practices appeared to effectively meet their needs for learning and breaking down essential information related to mandate requirements. These practices were reflected in districts’ structural and functional responses in Appendix F, and Stage 1 responses in the “Stages of K-12 Districts’ Compliance with Legislative Mandates” model (Appendix G). Work at this stage did not appear to involve insurmountable challenges to organizational practice. How do K-12 administrators respond to mandates and monitor district implementation? It is important to recognize that mandates introduce an element of change and uncertainty within local districts. The literature elaborates theoretical concepts to explain organizational responses to change. In the area of district implementation and monitoring of mandate requirements, the ideas of Weber (1947), Thompson (1967), Rowan and his colleagues (Meyer and Rowan, 1997,1978; Rowan, 1982; Rowan and Miskel, 1999), and Cusick (1992), help to explain how districts might respond. These theoretical ideas support conclusions drawn from the data, corresponding to Stage 11 internal management tasks. Overall, Stage 11 tasks reflect bureaucratic action to regulate organizational action, aimed to comply with mandate requirements, as predicted by Weber (1947). Thus, administrators in the study districts used central office bureaucratic structures and procedures to break down compliance requirements, assign related responsibilities to individuals, communicate internal policies and rules, and monitor implementation. Responses at Stage 11 required a great deal of administrative resources. Thompson (1967) noted that the primary firnction of an organization is to reduce uncertainty. As policy mandates such as NCLB increase district accountability for 246 meeting proficiency standards, Thompson’s theory predicts districts would tighten internal norms to ensure outcomes are met. This characterized the work of Fairview and Steele in responding to NCLB standards related to curriculum, instruction and assessment, and teacher certification requirements under both NCLB and PA 165-166. Furthermore, Thompson’s work also explains the amount of coordination required in F airview and Steele to complete this work. As Thompson noted, when the organization deals with “soft” inputs, technology, and outputs, and also requires complex interdependencies between various organizational layers, increasing amounts of administrative time are required to coordinate organizational responses. For example, Stage II NCLB work in Fairview and Steele involved significant collaboration between departments, such as federal grant programming and budgeting coordinated through administrators overseeing cuniculum and instruction, finance, and human resources. Thus, specialized responsibilities were diffused across multiple positions. Thompson also asserted that administrators exert discretionary judgment using their knowledge base and position of power in response to uncertainties in the task environment. This explains decisions made by district administrators about what to attend to and what to ignore related to mandate requirements. Using their knowledge and power, Fairview and Steele administrators found it relatively easy to meet superficial PA 165-166 requirements of ensuring they had a sex education supervisor logged at the state level and ensuring they had Board approved sex education advisory boards and district curricula, but also knew they could skirt issues of inconsistent classroom instruction as it was not monitored by MDE. This allowed them to focus more district resources in response to NCLB. Thus, while they experienced decreased local control under 247 legislative policy mandates, this was offset by administrative discretion in selectively complying with various compliance requirements. When Fairview and Steele elected not to spend much time monitoring PA 165-166 implementation, it was apparent that classroom practices were loosely coupled to mandate requirements. Finally, the work of Rowan and others explains why these two districts were so preoccupied with NCLB compliance. Districts gain legitimacy by incorporating “institutional myths” and structures as they seek to become isomorphic with the institutional environment. Related to NCLB, this includes institutional myths related to curriculum, instruction and assessment, student achievement, teacher certification, professional development, etc. As Meyer and Rowan noted, schools “survive precisely because they are matched with—and almost absorbed by—their institutional environments” (1977, p. 352). Under NCLB, failure is clearly defined by consequences such as failure to meet AYP and loss of federal funding. Further, schools lose credibility or “face” when failures are publicly reported. In summary, Fairview’s and Steele’s responses to legislative mandates primarily involved bureaucratic action, centering on Stage I and II processes of building a working understanding of mandate requirements and conducting internal assessment of requirements, assignment of related responsibilities, and resolution of concrete tasks. However, significant change at the building and classroom level was less apparent. Once responsibilities were diffused to building administrators, practices became inconsistent and unpredictable. Building leaders did not appear to have a clear understanding of how to implement and monitor related practices to comply with mandate requirements and expected outcomes, nor did they report consistent changes in classroom practice. Thus, 248 Fairview and Steele appeared to struggle with application of bureaucratic solutions to change that may require a response outside the realm of bureaucratic control. What administrative challenges and district conflicts are created by these mandates? As Tyack and Cuban explain, the educational bureaucracy and “basic grammar of schooling” tends to resist deep change (1995, p. 85). Overall, bureaucratic structures promote stability rather than innovation, dealing much more effectively with task management than educational reform. This was reflected in the difficulties experienced by F airview and Steele administrators as they tried to promote change beyond Stage 11 work. Attempts to implement work on mandate requirements within buildings and classrooms brought them squarely up against Stage III tasks, confronting district barriers to change. This involved challenges related to administrative expertise, learning, and accountability; connecting policy and practice at all levels; value conflicts; and resource issues. Administrative Expertise and Ongoing Learning Administrative expertise and ongoing learning are critical in responding effectively to legislative mandates. Complex mandates such as NCLB require significantly more expertise and effort. If measured against Hall’s HiC Scale, the change required by NCLB ranks at approximately a Level 7-8, putting it in the “transforming” range. In contrast, PA 165-166 might rank at approximately a level 3-4, placing it in the “talking” range (Hall and Hord, 2001, pp. 8-9). Thus, mandates such as NCLB challenge district administrators, requiring considerable expertise. Further, as noted by Cohen and Hill, the more a policy departs from current practice, “the more implementers have to learn” (2001, p. 6). 249 Administrative learning arguably involves meaningful collaboration with other educators. A pattern exhibited in both F airview and Steele relative to both mandates was that while district administrators had adequate knowledge of requirements, this was not true of building administrators. In addition, it didn’t appear that effective building implementation was firlly understood, begging the question of whether policy requirements and implementation actions at the building level had been clearly articulated. As noted by Cohen and Hill, “When the objectives of policies and the actions that implementers need to undertake are thus elaborated, policies are more likely to wor ” (2001, p. 6). Darling-Hammond also commented, “Directives are not enough. . . . meaningful discussion and extensive professional development at all levels of the system are critical components of such communication” (1990, p. 346). This appeared to be lacking in both Fairview and Steele. Weak Accountability Practices Furthermore, it was not clear whether accountability practices were sufficient to ensure good implementation and monitoring at the building level. Data from Fairview and Steele indicated that superintendents were only peripherally involved in NCLB and PA 165-166 implementation; this work was primarily delegated to others. Steele’s superintendent noted he required a certain percentage increase in student achievement each year, with building performance reflected in principals’ evaluations. However, this is a blunt tool for monitoring implementation of a complex, demanding mandate. Indeed, most monitoring fell to other central office administrators with little clout to ensure appropriate action in buildings. This appeared to be problematic in Steele, where more than one administrator noted a lack of accountability, reporting that principals were able 250 to skirt issues by “running to Daddy” if they were unable to get the response they wanted from lower level administrators. Connecting Policy and Practice Another challenge in implementing legislative mandates involved creating a deep sense of connection and meaning between the requirements and district work. Administrators in this study who appeared to understand this described using the requirements as a “lever” to get work done that “we should be doing anyway.” However, connecting policy to practice involves learning that penetrates all layers of the organization. Cohen and Hill state Policies that aim to improve teaching and learning depend on complex chains of causation. Making the policies work depends both on their elaboration and on connecting the links in those chains. One crucial element in many of those links is their instructional content: policies that offer professionals suitable opportunities to learn and coherent guidance for teaching and learning increase the opportunities to connect policy and practice. Establishing those links requires time and opportunity to learn, along with leaders’ expertise to facilitate appropriate learning. Value Conflicts Key F airview and Steele administrators expressed conflicts, either at the district level or personally, with values embedded in NCLB. In addition, they noted these values did not widely reflect classroom practices. Hall and Hor ’3 “change principles” speak to the difficulty of trying to mandate change from the top down, which is how legislative policy mandates are enacted (2001, pp. 2-19). They state, “Although everyone wants to talk about such broad concepts as policy, systems, and organizational factors, successful change starts and ends at the individual level. . . . There is an individual aspect to 251 organizational change” (p. 7). Hall and Hord elaborate comprehensive means for effecting change with individuals based on their Stage of Concern. Thus, it appears that facilitating broad changes in individual beliefs and values relative to policy mandates takes time and expertise. Resource Issues The most frequent challenge cited by Fairview and Steele administrators in responding effectively to NCLB and PA 165-166 concerned inadequate resources. Resource issues included administrative capacity, funds to meet students’ needs, and time and funds to support professional learning. Data from both districts indicated that Fairview and Steele had experienced significant budget deficits and administrative reductions. Since 1999, Steele had experienced a twenty-five percent reduction in its administrative force. Between the late199OS and 2007, Fairview and Steele lost two to three administrators respectively in the instructional area alone, collapsing these responsibilities into one position. Cuts were also noted in other departments, including both administrators and support staff. In contrast, Rowan’s work in 1982 found that district positions in curriculum were added when there was “institution building” at the state and federal levels. When new state and federal curriculum requirements were added, positions tended to be added at the district level. This pattern reversed itself in the 1990s to present; with additional mandated expectations at the federal and state level (with NCLB and PA 165-166 representing only two examples of increased expectations) and declining district revenues, fewer people are left to do more work. 252 This is a significant point, and one worth emphasizing, as it adds a new element to organizational theory. In reexamining the study’s theoretical foundations, including the work of Weber (1947), Thompson (1967), and Rowan (1982), it is apparent that the fiscal constraints experienced in Fairview and Steele prevented bureaucratic growth at a time when administrators’ workloads were increasing. This is in direct contrast to what prevailing theory might predict. While theoretical concepts related to bureaucratic specialization and exercise of administrative discretion generally held true, data fiom this study demonstrates that in fiscally lean times, the districts’ strained budgets actually forced increased administrative discretion. Their smaller administrative staffs spent time assessing the requirements to discern what they absolutely had to do, thus concentrating their energies on the reforms’ most visible and compelling elements. Thus, while the conservative response to change may be specialization (Cusick, 1992), particularly in times of plenty, lean times demand increased administrative discretion. The decline in district funds also had an impact on schools and classrooms as well. Both F airview and Steele closed schools and maximized classroom enrollment to reduce costs. With increased awareness of achievement gaps and students’ needs, districts struggle to maintain programs, at a time when teachers are requesting additional services to support students. Federal and state funds sometimes address these needs; however, recent changes in state monitoring now prohibit Title I schoolwide funding of supplemental services such as nurses and social workers. A final note regarding insufficient resources concerns the need for appropriate professional development. Cohen and Hill observed that this is an overlooked element in policy implementation. 253 Most reformers, including many governors, President George W. Bush, and many business officials concerned with schools, have argued that schools need to be shaped up with stronger academic standards, stiffer state tests, and accountability for students’ scores. Our research shows that these efforts are unlikely to succeed broadly by themselves. . . . [They] are more likely to succeed if they are accompanied by extended opportunities for professional learning that are grounded in practice. . . . (pp. 10-11) Administrators from Fairview and Steele acknowledged insufficient time to discuss policy implementation and needed changes in educational practices. Furthermore, a critical aspect of changing educational practice involves teacher learning. As noted by Darling-Hammond, “teachers teach from what they know. If policymakers want to change teaching, they must pay attention to teacher knowledge” (1990, p. 346). Without time and money to support professional learning, these needs may continue to be overlooked. Summary of Findings The modified conceptual framework presented in this chapter demonstrates how legislative mandates are passed down from the federal and state levels to local K-12 districts. As these mandates are often quite complex, a great deal of time is often spent to define and clarify mandate requirements at all levels, involving collaboration between federal and state government representatives, external partners, and local districts. The mandates are open to interpretation, and at higher levels, specific mandate requirements may be subject to bargaining regarding which aspects to enforce. Study from this study indicates that exercise of discretion at the federal and state levels may be a key function of the educational bureaucracy. Some might argue that discretionary decision making is limited to higher levels of the educational system, citing constraints over local control posed by legislative 254 mandates. However, study data indicates that K-12 districts are not passive puppets as they respond to mandates. While there may indeed be decreased local control, in Fairview and Steele, this was partially offset by their selective compliance with mandate requirements. There are two primary explanations for the discretionary decision making of Fairview and Steele administrators in response to mandate requirements. The first explanation is that while the conservative response to change is bureaucratic expansion, current financial constraints in the state of Michigan prohibit bureaucratic growth to handle increased administrative responsibilities. Thus, administrators in these two districts exercised discretion as they assessed mandate requirements, deciding what they could effectively respond to and how, often basing these decisions on elements involving public accountability and institutional reputation. The second explanation for administrators’ discretionary decision making in the study districts relates to the scale and organizational impact of the innovation. Darling- Hammond’s comment about teachers operating in their classrooms based on what they know may apply to administrators’ responses as well. The study data were clear that administrators were familiar and effective in handling the bureaucratic and operational routines of K-12 education. It appears less certain they possess the knowledge, expertise, and time to facilitate deep changes in educational practice. And it seems that when organizational survival is at stake, these administrators sought legitimacy within the educational system by institutionalizing bureaucratic practices embedded in the mandates. Thus, faced with two sources of uncertainty, stemming from a dynamic task environment and the unpredictability of effecting deep changes in educational practice 255 within the organization, administrators in F airview and Steele appeared to hedge their bets by concentrating on bureaucratic tasks. The purpose of this study was to describe and explain the response by K-12 districts to policy mandates introduced through federal and state legislation. Based on study evidence, when faced with new legislation, K-12 districts do what they can and what they perceive they have to do. Compliance decisions are influenced by public accountability and institutional reputation, and the result is that the reforms quickly become embedded in the districts' bureaucratic and operational routines. However, it is less certain that reforms facilitate the changes in classroom practice and student outcomes envisioned by their authors. Reflections Conclusions were drawn in response to exploratory research questions and further informed by the research literature. The chief finding of this study is that legislative policy mandates posed the study districts with an interesting paradox: while the educational bureaucracy appears to be well-equipped to satisfy concrete compliance requirements, bureaucratic action does not appear sufficient to produce the deeper changes in practice needed to fulfill the spirit of the law. As noted earlier, this raises new questions related to legislative policy mandates and the response of K-12 districts: Do districts have the capacity to actually implement deep changes in educational practice in response to legislative policy mandates? Further, do they know how to accomplish significant reform, have adequate resources, and will they choose to do so? 256 The answers to these questions are uncertain and require further research. Some might say that deep changes in educational practice are already underway in many districts. However, data from this study did not yield sufficient evidence to support this conclusion. Hence, a more pertinent question at this juncture is whether districts have the capacity to effect deep changes in practice. A critical component appears to be missing in Fairview, Steele, and arguably many districts, which is a focus on professional learning. Where deep change is a desired district outcome, it seems that “substantial professional learning is a key element in the implementation of instructional policy” (Cohen and Hill, 2001, p. 185). Given that schools exist to promote learning, it is somewhat paradoxical that effective professional learning appears to be such a rarity. However, enacting deep changes in teaching and learning appears to require a different kind of leadership than the traditional bureaucratic functions used to operate schools. Issues of district capacity lead to the second question, concerning whether K-12 districts even have the knowledge to facilitate deep changes in schooling. It would seem that if educational leaders knew how to effect such change, the changes would be well underway in K-12 districts across the country. However, research data informing the reauthorization of NCLB indicates that widespread, deep change is at best a work in progress. Furthermore, resource concerns have been vocalized at the district, ISD, professional association, and state levels, casting some doubt about whether large-scale change is possible without increased resources. This is especially significant given current policy discussion about NCLB’s reauthorization. If the federal government introduces new recordkeeping and reporting requirements, this will further increase the 257 demands on the educational bureaucracy at all levels. As noted by ASCD, this may have a detrimental impact on implementation, “leading to difficult decisions and making significant funding cuts,” (2007, p. 1), thus weakening NCLB’s potential impact. And finally, the question of whether districts will choose to do the work is also significant. District administrators in this study appeared to use discretion to decide where to focus their energies; in Fairview and Steele, the focus was on NCLB rather than PA 165-166. Thus, the answer to this question is “it depends.” During my dissertation defense and subsequent reflection on feedback received from committee members, additional thoughts emerged in response to these questions, outlined in Appendix H. Alternative Explanations Alternative explanations for study data are nearly limitless. Weber noted, “We are helpless in the face of the question: how is the causal explanation of an individual fact possible--since a description of even the smallest slice of reality can never be exhaustive?” (p. 78). However, this study does not assert causative relationships between indicants, but rather describes and explains K-12 districts’ responses to legislative policy mandates. Weber aptly observed that as the possible causes of an event are boundless, the researcher assumes the burden of determining what is important. Thus, research questions are asked and explored through the lenses of values, as described by Weber: “Order is brought into this chaos only on the condition that in every case only a part of concrete reality is interesting and significant to us, because only it is related to the cultural values with which we approach reality” (p. 78). Inevitably, readers judge the significance of a piece of research through their particular values, perspectives, and experiences. As Cusick noted, “It is the obligation of the reader to determine if the 258 descriptions presented in the account match his experience in different places” (1983, p. 1 34). Hence, there may be other plausible explanations for study findings. A reasonable conclusion is that insufficient time has elapsed since NCLB and PA 165-166 were enacted to allow for deep changes in practice to be evident. Furthermore, it is possible that with more time, traditional bureaucratic practices may be effective in producing changes in educational practice. However, given the work of researchers cited in Chapter I, the educational bureaucracy is set up for stability rather than innovation; thus, it seems more likely that innovation requires a nonbureaucratic response. Other explanations may also offer further insight. It may be possible that change will require a combination of bureaucratic and nonbureaucratic responses. For example, bureaucracies tend to be effective in establishing accountability structures and procedures, a measure that appeared to be lacking in both F airview and Steele. Improvements in financial planning and resource allocation may also create opportunities for change. Furthermore, it is possible that district performance is a straightforward matter of inadequate resources. With additional funds, more administrators could provide greater coordination and monitor more effectively, class sizes could be reduced and programs added to support student achievement, and more time could be provided for professional learning. However, it is unlikely that resources alone, without intentional work toward mandated goals, will produce needed improvements. Finally, other organizational theories might also posit alternative explanations. Kezar presented and discussed an array of organizational theories of change, which offer 259 competing explanations and inherent strengths and weaknesses (2001, pp. 25-56). For example, evolutionary change models might argue that K-12 districts gradually adapt to environmental changes; consequently, planned changes introduced through legislative mandates are doomed to failure. Life cycle theory would focus more exclusively on the leader’s role in creating a new organizational identity to support change. Kezar concluded his review by asserting his belief, “The strongest approach is to combine certain assumptions from various approaches” (p. 56). In fact, a combination of theoretical assumptions has informed study design, data analysis, and interpretation, thus strengthening the conclusions drawn here. This researcher has weighed and interpreted the data, read the research literature, and considered alternative explanations. Readers may make additional connections to enrich their understanding of these findings. Further connections in response to feedback received during the dissertation defense are elaborated in Appendix H. Recommendations for Additional Research Previous sections discussed the response of K-12 districts to legislative mandates, elaborating the thesis that while bureaucratic responses may satisfy concrete compliance requirements, they are insufficient to produce the deeper changes in practice needed to fulfill the spirit of the law. However, this study was relatively small in scope, holding to parameters established through the study design. As such, further research would be invaluable to increase understanding of districts’ responses to legislative mandates. For example, a study conducted ten years after the initial passage of NCLB would provide a basis for comparison over time, and would also shed insight on districts’ responses to new measures introduced in NCLB’s reauthorization. 260 Larger scale studies would also provide a more complete understanding of differences in districts’ local contexts and responses, and their potential impact on district outcomes relative to legislative mandates. A larger study might include interesting counterexarnples of predicted district responses and outcomes. This would allow testing and refinement of the Stages of Compliance model presented here. Lastly, rigorous studies of districts making significant, measurable progress pertinent to policy requirements would increase understanding of how they achieved these outcomes. This would help to test whether Stage IV responses lead to measurable improvement in student achievement, or if different district conditions and actions are necessary to create change. Thus, such studies would help enlighten educational policy development, increasing the likelihood of effective K-12 responses. Significance of the Findings The intent of this study was to contribute to the discourse regarding K-12 districts’ response to legislative policy mandates. Rather than asserting claims of causal interrelationships between legislative mandates and district responses, the narrative presented here aimed to describe and explain patterns observed in the study districts, and to use these patterns to develop an abstract model of districts’ compliance with legislative mandates. I believe the study contributes to the body of research on educational policy and practice in two ways. The first contribution was presented through the data in Chapter IV, offered on behalf of the districts included in this study and the administrators who generously made time to talk with me. They were honest and straightforward as they told of their successes, and fiequently unflinching as they shared tales of frustration and angst. 261 I have strived to report their stories accurately, without distortion, and with respect for the dilemmas and challenges they routinely face. My hope is that I have been successful in representing their responses in a meaningful manner, such that readers will find their observations helpful in providing a frame for understanding the work of districts’ responses to legislative mandates. Secondly, I would suggest the conceptual framework and stages of compliance model, along with the conclusions in the final chapter, contribute to the discourse surrounding connections between educational policy and practice. Successful educational reform enacted through legislative policy mandates appears to be relatively rare. Many research studies have described the intractability of schools to planned change. This study illustrates a significant challenge to the educational bureaucracy as it attempts to respond to legislative mandates, suggesting that changes in leadership practices at the district level are needed to facilitate deep changes in teaching and learning. 262 APPENDICES 263 APPENDIX A Organizational Response of K-12 Districts to External Mandates in Curriculum, Instruction, & Assessment APPENDIX B *Semi-structured Interview Protocol *Note: the primary questions are identified with a “Q,” and will be asked of each person interviewed. F ollow-up probes are listed beneath the primary questions, and will be used as needed to yield additional information. Introduction: (at beginning of taped interview, identify date, time, informant, and location). We are meeting today to discuss your administrative responsibilities and actions relative to two legislative mandates: No Child Left Behind (N CLB) and Michigan Compiled Laws (MCL) Public Acts 165 and 166 (mandated Human Immunodeficiency Virus/Auto Immune Deficiency Syndrome (HIV/AIDS, otherwise known as PA 165 and 166). We’ll start first with some general questions, and then discuss three basic questions: 1) how your district learns about and assesses mandate requirements; 2) how administrators respond to mandates and monitor district implementation; and 3) administrative challenges and conflicts posed by the mandates. Q: What is your position within this organization? (district, ISD) How long have you held this position? Concerning How Districts Learn About and Assess Mandate Reguirements: Q: How do you learn about the requirements of NCLB and PA 165/166? _ a. How does initial and subsequent information about mandate requirements come to your attention? b. What information resources do you access to learn about mandate requirements? Q: What is involved in assessing the various requirements? a. Are there others you consult either internally or externally to assess requirements? b. How much time is involved in assessing mandate requirements? Q: What are your responsibilities with regard to No Child Left Behind? What are your responsibilities with regard to Michigan Compiled Laws (MCL) Public Acts 165 and 166 (mandated Human Immunodeficiency Virus/Auto Immune Deficiency Syndrome (HIV/AIDS, otherwise known as PA 165 and 166)? Q: How were these responsibilities assigned to you? a. Have there been changes in assigned responsibilities for mandates to administrators over time? b. What prompted the change in assigned responsibilities? 265 Concerning District Response to Mandates and Monitoring of Implementation: Q: Who is involved in implementation and monitoring of NCLB? What do they do? Who is involved in implementation and monitoring of PA 165 and 166? What do they do? a. Do you share assigned responsibilities for mandates with other district administrators? b. Do you organize and assign work to others? How does this work? Q: Are there others outside of the district who assist you with your assigned responsibilities? a Who assists you and what is their role? b. Are special interest groups involved in implementation and monitoring of the mandates? Q: How does communication of mandate requirements take place within the district? a. Are there specific structures for communication? How do they work? b. Please describe the purposes of these communications. Q: How do you monitor implementation of NCLB and MCL PA 165 and 166? a. What are some different ways you monitor implementation? b. Are there others who help you with this? What do they do? Q: What percentage of your time do you spend in responding to NCLB and monitoring district implementation? What percentage of your time do you spend responding to PA 165 and 166 and monitoring district implementation? Q: Do you monitor implementation of the two mandates closely? Please explain. a. What accounts for the differences in the way you monitor implementation of the mandates? b. Do you feel implementation of the mandates is scrutinized to a greater or lesser extent by others inside and outside the district? Concerning Administrative Challenges/Conflicts Posed by Mandates: Q: Are district resources adequate to address the mandates? a. Have the available resources changed over time? b. Are the resources dedicated to responding to the mandates commensurate with resource allocation to implementation of other federal and state mandates (i.e., IDEA, finance and pupil accounting)? Q: Are the mandates congruent district values? Are they congruent with your values and beliefs? 266 Q: Would you say the district implements the two mandates with fidelity, or with less than firll compliance? How is this represented to others within and outside of the district? Q: Do you perceive the policy mandates as unbending institutional structures that regulate your daily work, or do you generally ignore the mandates and create your own structures and rules to guide you? Q: What is the role of special interest groups in district planning, implementation, and monitoring of mandates? a. What are your beliefs about the involvement of special interest groups? b. Do special interest groups create challenges for you relative to the mandates? Q: Are there things you are unable to do because of mandate requirements and your workload? Thank you for your time and participation in this study. 267 APPENDIX C CONSENT FORM A Study of the Response of K-12 Districts to Policy Mandates Introduced Through Federal and State Legislation You are invited to be in a research study of how K-12 districts respond to policy mandates through federal and state legislation. You were selected as a possible participant for one of the following reasons: I You are a K-12 administrator in a district whose superintendent has agreed to permit access to the investigator. I You are a consultant with an Intermediate School District or the Michigan Department of Education who assists local school districts in responding to selected policy mandates. We ask that you read this form and ask any questions you may have before agreeing to be in the study. This study is being conducted by: Ms. Kellie Terry, Doctoral Student Educational Administration, Michigan State University Background Information The purpose of this study is to describe and explain the response by K—12 districts to policy mandates introduced through federal and state legislation. Specifically, the investigator will study district responses to No Child Left Behind (2001) and Michigan Compiled Laws (MCL) Public Acts 165 and 166 (mandated Human Immunodeficiency Virus/Auto Immune Deficiency Syndrome, otherwise known as PA 165 and 166, 2004). Study questions include the following: 1. How do K-12 administrators learn about and assess mandate requirements? 2. How do K-12 administrators respond to mandates and monitor district implementation? 3. What administrative challenges are created by these mandates? What conflicts do they pose for districts? Procedures: If you agree to be in this study, you will be asked to do the following things: 1. For K-12 central office administrators and intermediate school district and Michigan Department of Education consultants, you are requested to participate in a sixty minute audio taped interview with the investigator. In most cases, each participant will be interviewed once, but it is possible that a follow up interview will be requested with some individuals. Interview tapes will be transcribed into written form by a transcription Interview transcripts will be made available to participants for review and feedback. This consent form was approved by the Social Science/Behavioral/Education Institution Review Board (SIRS) at Michigan State University. Approved 02/27/07 - valid through 0226/08. This version supersedes all previous versions. IRB # 07-032. 268 2. For K-12 building administrators, you are requested to participate in a ninety minute focus group discussion with the investigator. Interview tapes will be transcribed into written form by a transcription service. Interview transcripts will be made available to participants for review and feedback. Risks and Benefits of Participation in the Study The study has two possible risks. First, it is possible that participation in interviews and request for district documents will create stress for administrators juggling busy schedules. Second, it is possible that participants may become more aware of professional issues and conflicts during the interview process that have implications for his/her work and career decisions. It is unlikely that these possibilities pose serious risks to interview participants. If participants find involvement in the study problematic, they may withdraw from participation at any time. The benefits to participation are twofold. The topic of policy mandates is of central concern to many educational administrators and consultants. Participants may benefit from the opportunity to share their thoughts and experiences in a confidential interview. In addition, the opportunity to read interview transcripts and case study analyses may provide helpful insights to participants, and give them the satisfaction of contributing to educational research. It is hoped that the study will contribute to a deeper understanding of districts' responses to policy mandates, as well as the particular challenges experienced by educational administrators. Confidentiality: Participation in the focus group will disclose to other participants any information you offer there; and those participants may also know you professionally or personally, so privacy in that setting cannot be guaranteed. However, all records of the focus group will be destroyed upon successful completion of the dissertation, and no information identifying you will be published. The records of this study will be kept private. In the published dissertation, information that will make it possible to identify participants will not be included. Research records will be stored securely and only Ms. Terry and her Dissertation Committee members will have access to the records. Interview tapes and transcripts will be kept confidential and in a secure place by the investigator. The investigator and Dissertation Committee members are the only individuals who will have access to audiotapes and transcripts. Interview tapes and transcripts will be destroyed after successful completion of the dissertation. Your privacy will be protected to the maximum extent allowable by law. Publication: It is possible that the study results may be published in an educational research journal or professional publication. As with the dissertation itself, information that will make it possible to identify participants will not be included. This consent form was approved by the Social Science/Behavioral/Education Institution Review Board (SIRB) at Michigan State University. Approved 02/27/07 - valid through 02/26/08. This version supersedes all previous versions. IRB # 07—032. 269 Voluntary Nature of the Study: Participation in this study is voluntary. Your decision whether or not to participate will not affect your current or future relations with Michigan State University or the investigators. If you decide to participate, you are free to not answer any question or withdraw at any time without affecting these relationships. Contacts and Questions: The doctoral student conducting this study is Ms. Kellie Terry. You may ask any questions you have at this time. If you have questions later, you are encouraged to contact either Ms. Terry (517-333-7463/work; 517-332-3459/home; terrykel@msu.edu), or her advisor, Dr. Philip Cusick, at Michigan State University (517-355-4539; pacusick@msu.edu). If you have any questions or concerns regarding your rights as a study participant, or are dissatisfied at any time with any aspect of this study, you may contact - anonymously, if you wish - Peter Vasilenko, Ph.D., Director of the Human Subject Protection Programs at Michigan State University, by phone: (517) 355-2180, fax: (517) 432-4503, email: irb@msu.edu, or regular mail: 202 Olds Hall, East Lansing, MI 48824. You will be given a copy of this information to keep for your records. Statement of Consent: I voluntarily agree to participate in the study. Signature: Date: Signature of Investigator: Date: This consent form was approved by the Social Science/Behavioral/Edumtion Institution Review Board (SIRE) at Michigan State University. Approved 02/27/07 - valid through 02/26/08. This version supersedes all previous versions. IRB # 07-032. 270 APPENDIX D F airview Community Schools Strategic Plan, 2007-2011 Environmental Scan, Critical Issues, and Strategic Directions and Strategies ENVIRONMENTAL SCAN The planning participants reviewed the organizational strengths and weaknesses in the areas of resources, processes and performance. The external environment was reviewed for social, political, economic and educational trends that have potential to act as opportunities or threats. The following are major strengths, weaknesses, opportunities and threats identified by participants that formed the context for developing strategic directions (goals) and strategies. Internal Review STRENGTHS perceived were: Talented, motivated student body Highly qualified, motivated, committed faculty and staff Strong community support that advocates for excellence in education and school support Diverse student body, parents and community Administrative leadership and Board of Education Strong, challenging curriculum High expectations among internal and external stakeholders School community values its cultural, economic and educational diversity Reputation and tradition of excellence Academics, fine arts, athletic programs Outstanding high school and middle school facilities Commitment to strategic planning and continuous improvement Many successful graduates Fairview Community Schools Educational Foundation WEAKNESSES perceived were: Financial limitations: unpredictable, limited and in cycle of reductions Increasing mandates from state and federal government Technology seriously lagging in elementary schools Aging and poorly equipped elementary (K-4) facilities Lack of trust and communication between key stakeholder groups Some poorly performing faculty with lack of a process for improvement Lack of effective, strategically determined external collaborations Lack of K-12 vision and alignment 271 Funding decline in fine arts, athletic programs Limited foreign language programming in elementary schools Lack of programming for gifted and talented students prior to high school Lack of focused attention to achievement gap issues Lack differentiated instruction for every student Lack long term focus and evaluative outcomes Environment of dwindling resources and pressure to do more with less At times lack of defined, clear processes, policies and procedures Enrollment trends External Review OPPORTUNITIES perceived were: 0 Strong community support for education and the PCS system 0 Reputation of the F CS for excellence - Funded government mandates 0 Educational competition offers F CS challenge to differentiate itself 0 Community demographics with diverse, international presence 0 Collaboration with other school districts 0 Potential strategic collaborative endeavors with University, Community College, City and businesses 0 Parents as resources at every level 0 Fairview Community Schools Educational Foundation offers possibility for growing relationships and funding support from graduates and community 0 High school reform calls for innovation and future thinking 0 Schools of Choice Program 0 Technology explosion and impact on education 0 State and federal mandates THREATS perceived were: Budgetary realities: increasingly unpredictable, inadequate funding Uncontrollable external expenses such as health care, retirement Political, social, economic trends that require more resources than can be provided 0 State of Michigan economic challenges 0 Educational competition from other districts, private and charter schools 0 Declining enrollments o Unfunded government mandates 0 Proposal A o Diverse student learners’ needs/abilities (ELL, autism and more) challenge the capacity to respond appropriately Retirements among teachers and administrators 272 Rapidity of technological development and change Competition for children’s minds and energies via television, computers, video games Taxes in Fairview and taxpayer fatigue External policy-making at the federal and state levels Real estate market: land-locked; lack of affordable housing and ability to grow; university student housing challenges Schools of Choice Program Rapid pace of change and proclivity to foster reactive environments CRITICAL ISSUES The following are the critical issues that have the greatest strategic importance to the long-term well being of Fairview Community Schools: TEACHING FOR LEARNING CURRICULUM INSTRUCTION ASSESSMENT TECHNOLOGY PERSONNEL AND PROFESSIONAL LEARNING PERSONNEL QUALIFICATIONS PROFESSIONAL DEVELOPMENT LEADERSHIP ORGANIZATIONAL LEADERSHIP: BOARD AND ADMINISTRATION RESOURCE MANAGEMENT FINANCES FACILITIEs/TRANSPORTATION COMMUNITY RELATIONS COMMUNICATION WITH FAMILIEs/COMMUNITY ENGAGEMENT WITH FAMILIES/COMMUNITY DATA AND INFORMATION MANAGEMENT DATA COLLECTION AND ANALYSIS INFORMATION MANAGEMENT SYSTEM FOR COMMUNICATION 273 STRATEGIC DIRECTIONS AND STRATEGIES 2007 — 201 1 Goal 1: Ensure all students participate in an academically challenging curriculum. Strategies: 1.1 Implement differentiated instruction with real-world applications to support the diverse academic needs and learning styles of students. 1.2 Develop and provide academic preventions and interventions for students based on current research. 1.3 Develop a systematic plan to continuously examine all curricula areas working through a pre-K-12 learning community. Goal 2: Provide a safe learning environment for students. Strategies: 2.1 Ensure respectful, safe and orderly classroom and school environments. Goal 3: Prepare students for learning and working in a global community. Strategies: 3.1 Explore pre-K-12 World Language programming options and learning experiences. Goal 4: Strengthen the PCS District’s assessment program. Strategies: 4.1 Study current assessment program and determine future needs. 4.2 Implement balanced assessment program for the District. 4.3 Increase assessment literacy in the interpretation and use of data for teaching and learning. Goal 5: Enhance teaching and learning through technology. Strategies: 5.1 Continuously explore, evaluate, and implement emerging technologies that promote District operations. 5.2 Expand efficiency of all operational software applications supporting classroom and professional responsibilities. 5.3 Integrate technology at all levels into teaching. Goal 6: Support staff in accomplishing the PCS vision and mission. Strategies : 6.1 Align professional development areas with curriculum, instruction, technology, state and federal mandates, and staff identified areas. 6.2 Strengthen the staff evaluation system to encourage continuous improvement. 6.3 Maintain highly qualified staff based on NCLB. 274 Goal 7: Provide excellence in governance to assure achievement of mission and vision. Strategies: 7.1 Support an ongoing process for Board of Education development to assure stability in governance. Goal 8: Develop effective leadership at all levels of the F CS. Strategies: 8.1 Insure that leadership decisions are based on long-term desired outcomes for students. 8.2 Establish and maintain an environment of trust at all levels of the F CS District. Goal 9: Manage finances to support teaching and learning. Strategies: 9.1 Facilitate processes that assure efficient use of resources/dollars. 9.2 Explore and evaluate revenue sources. 9.3 Develop greater local financial control. Goal 10: Provide high quality facilities, grounds, and bus fleet that enhance student learning and safety of students and staff. Strategies: 10.1 Develop and implement a short/long range plan for maintenance and improvement of facilities and grounds; maintenance and replacement of school buses. Goal 11: Strengthen community involvement in the realization of the FCS vision and mission. Strategies: 11.1 Determine community attitudes regarding teaching and learning. 11.2 Reach out to the community to better inform and involve all stakeholders. Goal 12: Improve data and information management to support the FCS mission. Strategies: 12.1 Increase use of software applications to support data collection, analysis, and communications. 275 APPENDIX E Special Education Focused Monitoring Report of Findings Public Schools Date of Report: April 5, 2007 On-site Visit Dates: January 16, 2007-January 19, 2007 Focused Monitoring Team: Janet A. Scheetz, Ed.D., Team Leader Shirley Young Chris VanderWall Darryl Petterson Julie Momber Focused Monitoring Priority: Identification Rate Least Restrictive Environment State Performance Plan: The State Performance Plan (SPP), as authorized by IDEA 2004, sets a context for Focused Monitoring. States are required under federal law to evaluate and report on its efforts to implement the requirements and purposes of IDEA 2004. This plan includes evaluating and reporting on specific indicators. The State is required to establish measurable and rigorous targets for each indicator. The performance of each local education agency will be measured against these targets and reported annually. The following SPP Indicator(s) have been selected by the State as a focused monitoring priority. Identification Rate The Identification priority is related to a number of SPP Indicators, including the Indicators addressing Effective Monitoring and Overrepresentation. It is important that all aspects of programs and services ensure that all students are appropriately identified and receiving a Free Appropriate Public Education in the Least Restrictive Environment and that all students with disabilities and their families are supported within special education. (20 U.S.C. 1416 (a)(3)(A)) Least Restrictive Environment Percent of children with IEPs age 6 through 21: A.) Removed from regular class less than 21% of the day; B.) Removed from regular class greater than 60% of the day; or C.) Served in public or private separate schools, residential placements, or homebound or hospital placements. (20 U.S.C. 1416(a)(3)(A)) District Demographics: The Public Schools District serves over 7,000 students in preschool through grade 12, of which 1,172 students receive special education programs and services. 54.5% of the population is White, 37.9 is Black, and 4.7% is Hispanic. 276 The district has two high schools, one of which is an alternative school, two middle schools, one of which is an alternative school, and nine elementary schools. The elementary curriculum emphasizes diversity and literacy. The middle school staff functions in teams in order to provide an effective transition between elementary and high school. High School is a school of choice option, which has resulted in an increased enrollment of several hundred students. With the exception of one elementary, last year the district’s schools made Adequate Yearly Progress for No Child Left Behind. The special education department consists of a Director, who is responsible for all early childhood programs and Section 504 plans, and two special education Supervisors. There are 13 Teacher Consultants (TC), one Adapted Physical Education teacher, 13 Speech and Language providers, and ten special education Social Workers. The district also employs a number of general education Social Workers. The district’s special education classes consist of: five classes for students with Specific Learning Disabilities (SLD); 32 Resource Rooms; six classes for students with Emotional Impairments (EI); six programs for students with Hearing Impairments; one Class for students who are Otherwise Health Impaired; twelve classes for students with Cognitive Impairments (CI); and, five classes for students with Autism Spectrum Disorder (ASD). In addition, Intermediate School District (ISD) provides a Severe Cognitive Impairments (SCI) program in one of the __ elementary buildings. sends 16 students to the Community Based Instruction program at the ISD Center: four EI students; eight ASD students; ten students in the SCI program; and eight students with Severe Multiple Impairments (SXI) at the ISD Center. Selection Criteria: The district was selected for Focused Monitoring during the 2006-2007 year under the Office of Special Education and Early Intervention Services' (OSE/EIS) priority areas of Identification Rate and Least Restrictive Environment (LRE). The district’s data for the previous three years (2003-2004, 2004-2005, and 2005-2006) were compared to other Michigan districts with similar enrollment. The results placed the district in the bottom quartile for the enrollment group. Hypotheses Related to Identification Rate (Focused Monitoring Team): The high identification rate of SLD students is due to: o The lack of application of systematic, research based general education interventions; o The inconsistent application of learning disability guidelines; and o The inconsistent use of the intervention process. Hypotheses Related to Identification Rate (School District): The high identification rate of SLD students is due to the fact that the area general population includes a larger than average number of families who: 0 Face economic challenges; . Lack resources to provide academic support at home; and . Experience a high rate of mobility, both within and into the district. 277 Areas of Strength Related to Identification Rate: 0 The intervention process framework, known in the district as the Student Support Team (SST), is formalized at most district elementary schools. a Building-wide positive behavior support programs are being implemented in several elementary buildings. School Social Workers serve both general education and special education. The referring teacher and grade level peers participate in the SST process. Description of Findings of Noncompliance Related to Identification Rate: The District’s process for identifying students as eligible for special education services as SLD is not compliant with the Individuals with Disabilities Education Act (IDEA) and the Michigan Administrative Rules for Special Education. Applicable Federal Regulations (IDEA): Evaluation Procedures §300.304(b)(1) “Conduct of evaluation. In conducting the evaluation, the public agency must - (1) Use a variety of assessment tools and strategies to gather relevant functional, developmental, and academic 1438 information about the child, including information provided by the parent, that may assist in determining--(l) Whether the child is a child with a disability under 5300.8; and (ii) The content of the child’s IEP, including information related to enabling the child to be involved in and progress in the general education curriculum (or for a preschool child, to participate in appropriate activities).” Overidentiflcation and Disproportionality §300.173 “The State must have in effect, consistent with the purposes of this part and with section 618(d) of the Act, policies and procedures designed to prevent the inappropriate overidentification or disproportionate representation by race and ethnicity of children as children with disabilities, including children with disabilities with a particular impairment described in §300.8.” Consistency with State Policies §300.201 “The LEA, in providing for the education of children with disabilities within its jurisdiction, must have in effect policies, procedures, and programs that are consistent with the State policies and procedures established under §§300.101 through 300.163, and §§300.165 through 300.174." Determination of Eligibility §300.306(c) “(1) In interpreting evaluation data for the purpose of determining if a child is a child with a disability under §300.8, and the educational needs of the child, each public agency must-- (i) Draw upon information from a variety of sources, including aptitude and achievement tests, parent input, and teacher recommendations, as well as information about the child’s physical condition, social or cultural background, and adaptive behavior; and (ii) Ensure that information Obtained from all of these sources is documented and carefully considered." 278 Applicable Michigan Administrative Rules for Special Education: R340.1701c(c) “ ‘Special education' means specially designed instruction, at no cost to the parents, to meet the unique needs of the student with a disability and to develop the student's maximum potential. Special education includes instruction services defined in R340.1701b(a) and related services." R 340.1713 Specific learning disability defined; determination Rule 13. (2) “The individualized education program team may determine that a child has a specific learning disability if the child does not achieve commensurate with his or her age and ability levels in 1 or mote of the areas listed in this subrule, when provided with learning experiences appropriate for the child’s age and ability levels, and if the multidisciplinary evaluation team finds that a child has a severe discrepancy between achievement and intellectual ability in 1 or more of the following areas:.... and (7) A determination of learning disability shall be based upon a comprehensive evaluation by a multidisciplinary evaluation team, which shall include at least both of the following: (a) The student’s general education teacher or, if the child does not have a general education teacher, a general education teacher qualified to teach a student of his or herageuu” R 340.1721a Evaluation procedure. Rule 21a. (b) Make a recommendation of eligibility and prepare a written report to be presented to the individualized education program team by the appointed multidisciplinary evaluation team member. The report shall include information needed to determine a student’s present level of educational performance and educational needs of the student. Information presented to the individualized education program team shall be drawn from a variety of sources including parent input.” Supporting Evidence: _ Public Schools’ identification rate as compared to State, I50, and peer averages: Rate of Identification (Overall) Year Public State ISD Peer Group Schools Average Average Average 2004 17.7% 14.2% 15.4% 13.2% 2005 18.9% 14.6% 16.3% 13.6% 2006* 16.7% 14.4% 14.8% 13.6% *2006 data is still in draft form Public Schools’ SLD identification rate as compared to State, ISD, and peer averages: Rate of Identification for SLD: Year Public State ISD Peer Group Schools Averagg Average Averfle 2004 37.6% 38.8% 43.7% 38.8% 2005 39.0% 37.8% 43.3% 37.8% 2006* 40.7% 37.2% 42.9% 37.2% *2006 data is still in draft form 279 Policy and Procedure A district-wide written procedure for SST is used at the elementary level. The _ Public Schools Professional Negotiations Agreement 2005-2007 contains language governing the implementation of Individualized Education Programs (IEP) and general education programs affecting intervention strategies. _ ISD has a procedure to identify SLD students that includes a discrepancy formula. Multidisciplinary Evaluation Team (MET) members throughout County use the SLD identification procedure. Practice The district-wide SST process has been implemented at the elementary level for ten years. It requires teams, consisting of the principal, parents, referring teacher, same grade level peer teacher, the building’s Instructional Specialist, Social Worker, and Psychologist, to identify intervention strategies, to monitor their implementation, and to reconvene to document success or identify new strategies. Principals are required to keep logs of the meetings and assure that the information regarding each student is available to all team members and that the information follows the student when the child moves to another building. The SST process also requires the principal to submit the information for entry into the district's computer SST code program, “Student Information Maintenance Inquiry." 0 Elementary principals report that they, the psychologist or the school social worker chair the SST meetings. Two psychologists indicate they chair the SST meetings and one general education teacher stated that the administrator occasionally attends the meetings. Logs of meetings and notes are kept at building but are not submitted to the SST code program and are not generally analyzed for district data purposes. The success of interventions is measured informally by teacher or parent satisfaction. . At the middle school level, general education teachers hold staffings on students as needed, without written procedures. Teachers and parents contact the building TC to begin the special education referral processes without documenting general education interventions. . High School students who are struggling academically or behaviorally are referred to the building TC for initiation of a referral to special education. . Twelve parents report they knew of no general education interventions implemented before their students were referred to special education. One teacher reported there is no follow up on referrals to SST and one psychologist reported that he is the SST process. When questioned about general education interventions that are used to address the learning and behavior problems of children, district administrators identified: Reading First, which is being implemented in two of the nine elementary buildings; after school tutoring, which will be initiated in February 2007 through Title I ; school- wide Title I assistance; and, in one building, a Fixit Room (for discipline). Several staff indicated that the Reading First program is not being implemented in their buildings because there is no money to fund it. Other administrators explained that 280 they were unable to implement this grant funded program in two eligible elementary sites due to language in the Agreement. There is no district-wide Positive Behavior Support system. The _ Agreement states that: “An innovative program will begin when all of the following have been satisfied: Note: “This Article shall not apply to District-wide changes in programming and curriculum... 2. If the program is adopted by at least 75% of the affected staff, in a secret ballot election, then the transfer procedure will be utilized by teachers who do not wish to participate." When establishing a recommendation for SLD, the MET does not consistently follow the requirement to draw information from a variety of sources, including parental input. The determination of SLD is not based upon a comprehensive evaluation that includes the student’s general education teacher. In addition, there is significant variance in the way the SLD Guidelines are implemented by the district’s psychologists. SLD MET reports generally consist of an evaluation by a psychologist and a check off on a MET cover sheet. Record reviews and interviews indicate that: 0 Fifteen of 27 SLD evaluation reports did not include parent input; . Seventeen of 27 SLD evaluation reports did not include general education teacher reports or comments from the teacher; . Four of six temporary placement files did not include the required MET data and there was no evidence that an evaluation was done to confirm eligibility; 0 Three psychologists state they use the ISD Guidelines to identify students with SLD, including the Guidelines’ discrepancy formula; 0 Six TCs and three psychologists gave different discrepancy rates and all indicated they use flexibility to establish eligibility; 0 One psychologist indicated he/she is supposed to follow the guidelines but doesn’t believe in them; . For psychological evaluations completed by the district’s psychologists during the period 2002-2004, one psychologist identified 70-160% more students for special education than the other three psychologists. (For the 2005-2006 school-year, data analysis of the evaluations completed by the district psychologists, indicates the same psychologist identified 40% of the total number of students identified in _, including 46% of the students identified as SLD.); 0 Five TCs and two psychologists report that SLD evaluations are done by the same psychologist; . Two psychologists report that many students are borderline ability and they cannot identify these students until 3rd or 4th grade, when the discrepancy begins to appear; and 0 Of the 25 files reviewed, 20 checked off the exclusionary clauses but did not include any documentation in the evaluation reports. Infrastructure The special education administrators indicate that the adoption of a site-based model has created variance across buildings, specifically with the implementation of the SST process in the nine elementary buildings. 281 The district uses the Excent Tera computer program for Individualized Education Programs. Two psychologists and six TCs report that initial IEPs are preprinted including Present Level of Academic Achievement and Functional Performance (PLAAFP) statements (written by the psychologists) and the goals (written by the TCs) and the amount of time (written by the TC). The preprinted IEP is presented to parents for consideration. Ten of 12 parents stated they do not believe they are part of the decision-making team process because the IEP is completed prior to the IEP Team meeting. Supervision The middle school general education teachers function in teams and autonomously refer students to special education. There is no administrative oversight, guidelines, or written procedures for staff to follow regarding general education interventions. The special education administration indicated that the elementary principals are responsible for delivering data to the Assistant Superintendent for Curriculum. An administrative representative from the Curriculum Department indicated there is no process in place to collect and analyze the SST data. Professional Development Two TCs provided training in differentiated instruction last August, but there is no evidence that the training is being implemented. Two TCs, ten general education teachers, and one special education teacher reported that there is a need for general education teachers to have training in special education related issues. None of the support staff or general education teachers interviewed reported receiving training in how to function as an interventionist on the SST, although most have participated in that role. Evidence of Correction: One calendar year from the date of this report OSE/EIS staff will verify that the _ has: Revised the SST process, establishing consistent procedures for all buildings to use, including training of staff in designing, implementing, and measuring the success of a wide variety of interventions; Established a consistent evaluation process for staff to use to identify students with SLD. The process will ensure evaluations are done by a team, that parental input is documented, and that general education teachers are part of the team and submit written reports. OSE/EIS staff will draw a sample of fifteen special education files for students newly identified or recently moved into the district within the previous six months to establish evidence of correction. Change will be measured by the implementation and documentation of the revised SST process and by METs which include the required inputs and reports. OSE/EIS staff will review the number of psychological evaluations completed and the number of students found eligible in each category, each year, by each psychologist in order to identify consistency of practice. 282 Evidence of Change: District data will show annual progress toward the 2010-2011 targets established for State Performance Plan (SPP) indicators that affect Identification Rate. Hypotheses Related to the Least Restrictive Environment (Focused Monitoring Team): Students spend more time in special education than the state average because of: . The lack of training for the general education staff on LRE issues; . Staff decisions at building transition IEPs based on the configuration of courses; Staff attitudes toward inclusion; and High academic expectation and standards required at the secondary level. Hypotheses Related to Least Restrictive Environment (School District): Students spend more time in special education than the state average because: 0 General education staff are reluctant to accept special education students; and . Special education staff want to provide a safe environment which assists students to be successful and to graduate. Areas of Strength Related to Least Restrictive Environment: . The district has recently transitioned from categorical special education rooms at the elementary level to Resource Rooms. The district operates center programs for the surrounding smaller districts. Special education teachers annually assess their students’ progress. The district has a full continuum of programs and services. Description of Findings of Noncompliance: The _ District does not ensure that the removal of students with disabilities from the general education classroom environment occurs only if the nature or severity of the students’ disabilities is such that education in general education classes with the use of supplementary aids and services, including accommodations and modifications, cannot be achieved satisfactorily. Applicable Federal Regulations (IDEA): LRE Requirements §300.114(a)(2) “Each public agency must ensure that - (i) To the maximum extent appropriate, children with disabilities, including children in public or private institutions or other care facilities, are educated with children who are nondisabled; and (ii) Special classes, separate schooling, or other removal of children with disabilities from the regular educational environment occurs only if the nature or severity of the disability is such that education in regular classes with the use of supplementary aids and services cannot be achieved satisfactorily." Placements §300.116 In determining the educational placement of a child with a disability, including a preschool child with a disability, each public agency must ensure that— 283 (c) Unless the IEP of a child with a disability requires some other arrangement, the child is educated in the school that he or she would attend in nondisabled; (d) In selecting the LRE, consideration is given to any potential harmful effect on the child or on the quality of services that he or she needs; and (e) A child with a disability is not removed from education in age-appropriate regular classrooms solely because of needed modifications in the general education curriculum." Consistency with State Policies §300.201 “The LEA, in providing for the education of children with disabilities within is jurisdiction, must have in effect policies, procedures, and programs that are consistent with the State policies and procedures established under §§300.101 through 300.163 and §§300.165 through 300.174." Applicable Michigan Administrative Rules for Special Education: R340.1722(1) The individualized education program team determines the educational placement of a student with a disability in programs and services from a continuum of alternative placements, such as instruction in general education classes, special classes or special instruction in general education classes, special classes or special schools, home instruction in hospitals and institutions, resource rooms, or itinerant instruction with general education class placements. Supporting Evidence: The LRE data for the shows a lower than average percent of special education students in general education for the majority of their school day and a higher than average percent of students placed in special education for the majority of the day. LRE Average Percentages for , the State, Peer Groups and the ISD along with State Targets: LRE State Peer ISD State Public Average Group Averages Target Schools Average 2005 <21% time in 44.0% 53.0% 61.9% 45.7% 46% Special Education 21-60% time in 16.6% 22.4% 22.0% 29.5% NA Special Education > 60% time in 39.4% 17.7% 14.2% 21.6% 21.5% Special Education The placements of CI and SLD students is displayed in the following table. The majority of CI students spend more than 60% of their time in special education beginning in 1St grade. For SLD students, there is a significant increase in the amount of time they spend in special education beginning in middle school, grades 7-8, and extending into the 9th grade. 284 LRE placements for CI and LD Students in Public Schools Disability LRE % K 1 2 3 4 s 6 7 8 9 1o 11 12 CI <21% 1 1 1 2 21- 1 1 1 3 1 1 1 2 60°/o > 60% 1 7 1o 12 6 12 1o 9 17 12 7 6 7 SLD <21% 1 15 18 14 18 9 7 7 26 17 7 41 21- 1 9 9 19 12 19 1 5 7 9 6 16 60°/o > 60% 1 4 11 11 9 1o 36 33 42 29 1o 10 Policy and Procedure A district-wide written procedure for SST is used at the elementary level. The Public Schools Professional Negotiations Agreement 2005-2007 contains language governing the implementation of Individualized Education Programs (IEP) and general education programs affecting intervention strategies. _ ISD has a procedure to identify SLD students that includes a discrepancy formula. Multidisciplinary Evaluation Team (MET) members throughout County use the SLD identification procedure. Practice The _ houses 12 classrooms for CI students (providing programming for 140 students). All but three of these students are residents of . Placements in these programs begin when students are initially identified CI. 83% of the CI students spend the majority of their day in the self contained CI classroom. General education placements are for non-academic activities only and are arranged in order to provide the special education teachers with planning time. The Middle School at _ (the district’s only middle school other than the Alternative middle school) is a grade 7-8 building. Teachers are assigned to teams. There are four general education teams and one special education team at each level. One of the general education teams includes a special education teacher. The middle school TCs arrange and attend all IEPs. The TC attends all level change IEPs for students moving up from 6th grade. At High School, the general education classes are leveled. Some of the SLD students are scheduled into the Level I (easiest) classes. The building based TCs recommend the amount of time and the courses students should take. Special education students who are experiencing behavior problems have their access to general education classes limited. A review of files of special education students who were suspended and or expelled last year revealed completed Manifestation Determination Reviews (MDR) that did not find behavior related to disability. All of the students had extensive histories of behavior problems and discipline referrals. All were identified as SLD. None had behavioral needs listed in their PLAAFP statements and none had behavior goals or Social Work service. 285 The general education teachers state they are providing the accommodations and modifications that are in the student IEPs but there is no evidence to substantiate this activity. Principals indicate that the teacher of record is responsible for ensuring the provision of accommodations and modifications, but they acknowledge that they are ultimately responsible. One general education and 2 special education teachers and 1 TC stated behavior issues limit amount of inclusion. Two special education teachers stated that IEP time is predetermined before the meeting and students are placed full time in a special education program. Students are only out for physical education when the teacher needs planning time. Two special education teachers stated that students are restricted from classes at MS because classes are too large and that they are asked to write goals for areas for which they are not identified. Special education teachers do not attend IEPs for students moving up to their classes. TCs attend level change IEPs for 6th graders entering the middle school and write goals and objectives for the teachers to implement and determine the amount of time the students will spend in special education. One School Social Worker and 1 TC said they increase student time in special education because they think the general education courses are too hard. Two administrators stated that special education students are graduating because the district is providing them with more time in special education. One psychologist stated that at the IEP the general education teacher literally “hands off the special education student to the special education teacher.” Three special education teachers reported they have difficulty securing general education materials. Seventeen general education teachers reported they do not log, record, or maintain evidence of the accommodations and modifications they provide. Infrastructure One Administrator, 1 TC, and 1 special education teacher stated the district has used co-teaching but the TC and teacher attitudes no longer permit or support the practice. One psychologist stated that there is no incentive to control the number of special education programs and staff because the district is reimbursed 98% of its excess costs from the County Act 18 millage. Two administrators expressed concerns about having large numbers of special education students in their buildings because of the effect of their performance on the schools’ Annual Report Card. Two support staff and five general education teachers stated they did not feel prepared or trained to address the needs of special education students. Supervision One School Social Worker, 1 special education teacher, and 2 support staff indicate there is a lack of support for inclusion practices by building and central office administration. 286 Professional Development Out of 36 staff interviewed, 31 indicated they have had no Professional Development in LRE and most indicated training is needed. The middle school categorical teachers stated they do not participate in the general education curriculum meetings. Evidence of Correction: One calendar year from the date of this report _ will present evidence that: . All general education staff received professional development and training in the legal requirements for LRE implementation, along with research based best practice models, including co-teaching. Data will indicate a decrease in the percentage of SLD and CI students in the >60% in special education category. Special education teachers are integrated into the middle school teams. . There is a system in place to ensure the provision of accommodations and modifications for special education students by general education teachers. . Parental consent will be secured if annual achievement assessments continue as a district practice. Evidence of Change: District LRE data will show annual progress toward the SPP LRE targets and will reach the SPP target by 2010-2011. The district will show progress in addressing language within the __ Professional Negotiations Agreement that is not in alignment with the IDEA and the Michigan Administrative Rules for Special Education. Improvement Plan: Within 60 days of the date of this report, the district must submit a Focused Monitoring Improvement Plan to the Office of Special Education and Early Intervention Services. A CIMS Technical Assistance support staff will be assigned to the district to facilitate development of the Improvement Plan. 287 APPENDIX F Conceptual Framework of the Educational System Organizational Relationships and Responses to Legislative Mandates interpretation Bargaining Discretion ‘ Interpretation Interpretation & Technical Assistance Discretionary Decisionmaking 288 APPENDIX G Stages of K-12 Districts’ Compliance with Legislative Mandates STAGE I: BUILDING AWARENESS AND UNDERSTANDING Traditional bureaucratic aractices resolve Stage I tasks. MEDIATED BY °2° Available resources/experts O 0.. RESPONSE Gathering information through various channels, including conferences, online resources, e-mail, professional associations ENABLING OR INHIBITIN G REACTIONS/ CHARACTERISTICS Enabling: 0:0 Response congruent with inherent values and beliefs underlying mandate Inhibiting :30 Willful avoidance. “This will never work. This too shall pass.” ’3' Subtle avoidance. Trying to “fly under the radar.” O 0.. O 0.0 *RESOLUTION *Movement to next stages builds on satisfactory resolution of each stage Working understanding of the mandate and its components If no perceived consequences for noncompliance, or benefits through compliance, district response may stall at this stage STAGE II: FOCUSING ON INTERNAL MANAGEMENT ISSUES “THE LETTER OF THE LAW” Traditional bureaucratic practices resolve Stage H tasks. MEDIATED BY External consultation to problem solve Available district resources . District history (including leadership history, past practices in response to innovation or change) Cultural beliefs about requirements (deep-seated beliefs about the purpose of RESPONSE Beginning breakdown of compliance requirements for the LEA Examination of consequences of non- compliance Exploration of internal resources (S, human resources, expertise) Assignment of responsibilities to schooling, the nature of teaching and adrrrinistrator/s 0:0 Additional training/ communication for responsible parties ENABLING OR IN HIBITING *RESOLUTION REACTIONS/ CHARACTERISTICS '3' May stay in this stage a long time. Enabling: °3° If it is perceived that superficial compliance is °3° Purposeful attempts to organize and facilitate district response 03° Harnessing external resources to assist Inhibiting: 03° Reactionary panic—how will we ever get it all done? 03° Preoccupation with rules/regs, and details Characteristics: '3' Emphasis is on the letter of the law .0 .0 Classroom practice—status quo “good enough” and there will be a lack of external monitoring or consequences, district response may end here. Resolution of concrete issues required before districts can move toward addressing deeper issues 289 STAGE III: CON FRONTING DISTRICT BARRIERS TO CHANGE Stage 111 represents beginning shift away from traditional bureaucratic practices. MEDIATED BY Internal and external community responses: increased understanding of mandate requirements 3 Experiences of either positive or negative consequences related to early responses to mandate requirements Increased public scrutiny and/or public reporting of district performance relative to mandates .° Growing recognition that “business as usual” will not suffice to meet demands of mandates Internal leadership capacity Resources for leveraging change, including research, external partnerships O 0.. O O 0.0 0.. RESPONSE Refocusing: shift of focus beyond compliance with structural requirements, rules, and regs to internal issues Increased focus on examining cultural beliefs and values relative to the mandates Identification in “gaps” between district practices, outcomes, and mandate requirements Greater collaboration across roles, departments, and grade levels to brainstorm potential responses Increased efforts to align district resources to meet perceived needs Increased accountability of district leadership for outcomes and consequences ENABLING OR IN HIBITING REACTIONS/ CHARACTERISTICS Enabling: 0 v Objective examination of evidence 92° Examining current practice and making efforts to realign to meet requirements Inhibiting: 02° Inertia Of past practices, structural constraints Blaming others for negative outcomes or consequences °2° Wait and see—the external mandate will have to change, because the system C‘Can9t9, O 0.0 O 0.. *RESOLUTION Increase in collective will and commitment to the “spirit” of mandate requirements Change in espoused beliefs and values by district and teacher leadership—greater alignment to values inherent in mandates Development of plans to change deeper practices of district relative to mandates 290 STAGE IV: INSTITUTIONALIZING NEW PRACTICES RELATIVE TO MANDATES Institutionalization of deep changes in educational practices requires action outside of traditional bureaucratic controls. MEDIATED BY Internal leadership capacity Attention to outcomes, either positive or negative 02° Positive outcomes shift beliefs and values to align with inherent values of mandate Negative outcomes may result in increased confusion, restructuring, and/or disengagement Available resources to support deep change in practice, including expertise, time, and money 0 O 0.. 0.. O O O O 0.. O 0.. *RESOLUTION Continued focus on implementation and evaluation of new practices Increased accountability across roles for student, classroom, school and district outcomes Reformulation of departmental/district structures and functions to support mandated change ENABLING OR INHIBITING REACTIONS/ CHARACTERISTICS Enabling: 02° Increased emphasis on collective responsibility and accountability °2° Increased willingness to change essential processes Inhibiting: 03° Inconsistent leadership support 0.0 Inconsistent accountability standards and practices 0.0 Inability to leverage change to support mandates systemically across departments, classrooms, levels. 0 *RESOLUTION Deep changes in classroom/educational practices Additional change is inevitable, so there is never really complete resolution. Change results in dynamic instability of organizations. Risk of returning to “old ways” with instability of the system. Further questions related to district capacity, resources, and discretionary choice make resolution uncertain. 291 APPENDIX H Additional Reflections in Response to the Dissertation Defense My esteemed Dissertation Committee members provided invaluable feedback during my defense. Their comments resonated with a number of concerns that periodically niggled at me during the writing process, fully surfacing during my defense. As I have reflected on these issues, it seems appropriate to share my thoughts in a final appendix, closing the circle between dissertation completion, defense, and concluding thoughts. This is not an exhaustive review; rather, it is intended to acknowledge and address the valid, constructive criticisms raised by Committee members. AS I considered the feedback, three significant issues emerged, worthy of additional comment. These include the relationship between theory, topic, and conclusions, the tension between the individual change process and legislative mandates filtered through the educational system, and the exercise of administrative discretion in response to mandates. First, the literature review incorporated theory that was both broad and comprehensive. While the theoretical underpinnings for the study lent a panoramic view of the evolving purposes Of K-12 education, connections between the economic, political, and educational systems, and the history of educational reform, the study itself utilized a zoom lens to explore the responses of two K—12 districts to specific legislative policy mandates, significantly influenced by both local factors and budget constraints unique to Michigan’s school finance system and economy. Given the limited sample size, it is very likely the findings generated by the study were biased by local district factors. This makes it inherently difficult to firmly establish connections between a theoretical base 292 1: that is sweeping and broad, and findings that are Specialized through a narrowly focused study. Weber himself noted The more comprehensive the validity,--or scope—of a term, the more it leads us away from the richness of reality since in order to include the common elements of the largest possible number of phenomena, it must necessarily be as abstract as possible and hence devoid of content. In the cultural sciences, the knowledge of the universal or general is never valuable in itself” (1949, p. 80). The “richness of reality” thus makes theoretical abstraction more challenging. Secondly, committee members noted it is problematic to query an organization about its response to legislative mandates, as questions can only be asked of individuals. However, behaviors of and between individuals acting in their roles at all layers of the system comprise the organizational response. Thus, it is critical to understand the behavior of individuals within organizations, and to some extent, to answer which is primary to the organizational response: individuals acting as personal agents of the organization, or organizational structure and function in influencing the behavior of individuals acting on the organization’s behalf. This is a complex question that surfaces issues related to individual behavior within organizations, as well as the apparent resistance of educational organizations to change. Even at the individual level, change can be difficult, as many organizational theorists have noted. Manis’ work on loss and change (1974) demonstrates the difficulty posed to individuals dealing with change, as it represents loss of familiar patterns of behavior and social attachments. Whereas organizational change introduced through legislative mandates works its way down from federal and state government, to central office and building administrators, down to the classroom, the waves of change have to be recognized and dealt with at each level. This evokes anxiety related to loss of the 293 familiar; according to Marris, “The process of reform must always expect and even encourage conflict” (p. 156). He aptly noted that while reformers have already constructed the purpose for change, and wrestled with the structure and process for change, “Changes can only be carried out by those who resist them” (p. 157). Furthermore, Weick’s (1996) work illustrates a variety of reasons why individuals resist altering their behavior in response to external threat or demands for change. These include lack of recognition change may be necessary, particularly when behavior has been “overlearned” through extended practice; a lack of familiarity with alternative behaviors; an unwillingness to admit failure; and identification with traditional “tools” of one’s profession. If change is difficult at the individual level, it is far more challenging at an organizational level. It again begs the question whether administrators know how to enact educational change in classrooms. Elmore (1996) argues that while administrators know how to deal with structural change, they have a much harder time with the notion of improvement, resulting in difficulties realizing educational reform on a large scale. He asserts leaders fail to understand “the conditions under which people working in schools seek new knowledge and actively use it to change the fundamental processes of schooling” (p. 3). As noted in Chapter V, it may be that faced with the uncertainty of how to promote deep changes in classroom practice to achieve mandated outcomes, K-12 administrators fall back on familiar, bureaucratic “tools” for approaching change. Thus, in the end, personal agency seemed to give way to bureaucratic structures and practices. My final point concerns the exercise of administrative discretion. At every layer in the educational system included in this study, consultants and administrators with a 294 knowledge base of legislative mandate requirements, developed through experience in their roles, appeared to exercise discretion about how to comply with legislative mandates. This harkens back to Thompson’s (1967) theoretical concepts. Discretionary decisionmaking had little to do with administrators’ work ethic or productivity; rather, it appeared to be a response to increased workloads and decreased administrative resources. According to Thompson, “Where work loads exceed capacity and the individual has options, he is tempted to select tasks which promise to enhance his scores on assessment criteria” (p. 123). Thus, the administrator not only “rations” where effort is exerted, but chooses “criteria for rationing” (p. 123). In Fairview and Steele, it seemed administrators chose to devote their energies to requirements involving public accountability and institutional reputation, and let other requirements fall to the wayside, where noncompliance would be largely unnoticed and unpunished. Furthermore, in keeping with Thompson’s observation that individuals in highly discretionary positions working in a dynamic task environment seek to build coalitions within the task environment, F airview and Steele administrators used their connections with external partners to figure out what they could reasonably set aside, and what requirements demanded strict compliance. Reflecting on concerns raised during the defense provided an opportunity to revisit study data, theoretical concepts, and to further elaborate connections between the two. While the closer view utilized in the study prevented theoretical generalizations, further examination of the findings relative to organizational theory enriched my understanding of the dynamics of Fairview and Steele’s responses to NCLB and PA 165- I66. 295 REFERENCES 296 REFERENCES Association of Supervision and Curriculum Development. (2007). Comments on the NCLB (Title I) reauthorization draft. [Electronic version]. Retrieved on September 21, 2007, from http://ascd.ogportal/site/ascd/menuitem.6f662ce249e8980edeb3ffdb 62108a0c/ Arsen, D., & Plank, D.N. (2003). Michigan school finance under Proposal A: State control, local consequences. Summary retrieved October 26, 2006, from Michigan State University, Educational Policy Center Web http://www.epc.msu.edu/ publications/proposal%20A/summary.pdf Center for Educational Performance lnforrnation. (2005). Number of school districts and Schools. Retrieved September 23, 2007 from http://www.michigan.gov/documents/ SCMFctS0905_140501_7.pdf Center on Education Policy. (2004). Makeovers, facelifts, or reconstructive surgery: An early look at NCLB school restructuring in Michigan. [Electronic version}. Retrieved July 12, 2007, fi'om http://www.cep-dc.org/index.cfm?fi.rseaction= Page.viewPage&pageId= 495 &parentID=481 Center on Education Policy. (2005). Hope but no miracle cures: Michigan 's early restructuring lessons. [Electronic version}. Retrieved July 12, 2007, fi'om http:wawcep-dcorfldex.cfin?fuseaction=Page.viewPage&pa eId= 495&parentID=48 1 Center on Education Policy. (2007). Choices, changes, and challenges: Curriculum and instruction in the NCLB Era. [Electronic version}. Retrieved July 12, 2007, from http://www.cep-dc.Org/index.cfin?fuseaction=Page.viewPage&pageI = 495& parentID=481 Center on Education Policy. (2007). Do state education agencies have the tools necessary to implement NCLB? [Electronic version}. Retrieved July 12, 2007, from http://www.cep—dc.org/index.cfrn?fuseaction=Page.viewPage&pageI = 495& parentID=481 Center on Education Policy. (2007). Educational architects: Do state educational agencies have the tools necessary to implement NCLB? [Electronic version}. Retrieved July 12, 2007, from http://www.cepdc.org/index.cfm?fuseaction=Page.view Page&pageld= 495&parentID=481 Center on Education Policy. (2007). Implementing the No Child Left Behind teacher requirements. [Electronic version}. Retrieved July 12, 2007, fiom http://www.cep- dc.org/index.cfin?fuseaction=Page.viewPage&pageI = 495&parent ID=481 297 Center on Education Policy. (2007). What now?: Lessons from Michigan about restructuring schools and next steps under NCLB. [Electronic version}. Retrieved July 12, 2007, from http://www.cepdc.org/index.cfrn?fuseaction=figke.view page&pageld=495&parent ID=481 Center on Education Policy. (2007). Reauthorizing the Elementary and Secondary Education Act of1965: Recommendations from the Center on Education Policy. [Electronic version}. Retrieved September 21, 2007, from http://www.cepdc.org[ index.cfin?fuseaction=Page.vieprage&pageI = 495&parent ID=481 Center on Education Policy Roundtable Discussion. (May 1, 2007). NCLB 's accountability provisions for students with disabilities. [Electronic version]. Retrieved July 12, 2007, fiom http://www.cep-dc.org/jndex.cfin?fuseaction= Page.viewPage&pageId= 495&parentID=481 Central Michigan University. (2007). School health in Michigan. Educational Materials Center. Retrieved April 22, 2007 from www.cmc.cmich/michigan/how.htrn Cohen, D.K. (1985). Origins. In Powell, A.G., Farrar, E., & Cohen, D.K. The shopping mall high school: Winners and losers in the educational marketplace. Boston: Houghton Miftlin. Cohen, D.K. & Hill, BC. (2001). Learning policy: When state education reform works. New Haven: Yale University Press. Cusick, P.A. (1983). The egalitarian ideal and the American high school: Studies of three schools. New York: Longrnan. Cusick, P.A. (1992). The educational system: Its nature and logic. New York: McGraw-Hill. Darling-Hammond, L. (1990). Instructional policy into practice: “The power of the bottom over the top.” Educational Evaluation and Policy Analysis 12(3), 339-347. Elmore, RF. (1996). Getting to scale with good educational practice. Harvard Educational Review, 66 (1), 3-17. Farrar, E. (1985). Specialty shops. In Powell, A.G., Farrar, E., & Cohen, D.K. (1985). The shopping mall high school: Winners and losers in the educational marketplace. Boston: Houghton Mifflin. Foster, W. (1986). A critical perspective on administration and organization in education. In Sirotrrik, K.A. & Oakes, J. (Eds), Critical perspectives on the organization of schooling and improvement of schooling. Boston: Kluwer-Hijhoff Publishing. 298 Foster, W. (1989). Toward a critical practice of leadership. In Smyth, J .(Ed.). Critical perspectives on educational leadership. London: The F ulmer Press. Friedman, T.L. (2005). The world is flat: A brief history of the twenty-first century. New York: F arrar, Straus, and Giroux. Hall, G.E., & Hord, SM. (2001). Implementing change: Patterns, principles, and potholes. Boston: Allyn & Bacon. Ingham Intermediate School District. (2007). Board of education. Retrieved September 23, 2007 from http://www.ingharnisd.org/board_of_education/index.htrnl Jennings, J ., & Rentner, D.S. (2006). Ten big effects of the No Child Left Behind Act on public schools. Center on Education Policy. [Electronic version]. Retrieved April 10, 2007, from http://www.cep-dc.orgfindex.cfm?fuseaction= pageviewPagQQ pageld= 495&parent ID=481 Kezar, A.J. (2001). Understanding and facilitating organizational change in the 21St century. ASHE-ERIC Higher Educational Report, 29(4), 25-58. Labaree, DP. (1997). Public goods, private goods: The American struggle over educational goals. American Educational Research Journal, 34(1), 39-81. McMurrer, J. (2007). Implementing the No Child Left Behind teacher requirements. Center on Education Policy. [Electronic version]. Retrieved September 21, 2007, from http://www.cep-dcorg/index.cfm?firseaction=Page.viewPage&pa eld= 495&parent ID=481 Marris, P. (1974). Loss and change. New York: Pantheon Books. Meyer, J .W., and Rowan, B. (1977). Institutionalized organizations: Formal structure as myth and ceremony. American Journal of Sociology 83 (September): 340-363. Michigan Association of Intermediate School District Administrators. (2001). Michigan’s Intermediate School Districts: Leaders for educational excellence. Retrieved September 23, 2007 fiom http://www.michiganedusource.<fl/ Intermediate /ISDS/essential_serv_fulldoc.pdf Michigan Department of Education. (2007). ISD annual website posting. [Electronic version]. Retrieved on September 22, 2007, from http://www.mi.gov/mde/ /0.1607,7-140-6530---.00.html Michigan Department of Education. (2007). MDE office descriptions, programs, and services. [Electronic version]. Retrieved on September 22, 2007, from hfip://W.mgov/mde//O.l607,7-140-6530---.00.html 299 Miles, MB. and Huberman, A.M. (1994). Qualitative data analysis: An expanded sourcebook (2"d ed.). Thousand Oaks, CA: Sage. Mishel, E.G. (1991). Research interviewing: Context and narrative. Harvard University Press. Mommsen, W.J. (1989). The political and social theory of Max Weber. Chicago: The University of Chicago Press. Odden, A.R., and Picus, L0. (2004). School finance: A policy perspective (3rd ed. ). Boston: McGraw-Hill. Ogawa, R.T., Crowson, R.L., and Goldring, EB. (1999). Enduring dilemmas of school organization. In J. Murphy and KS. Lewis (Eds.), Handbook of Research on Educational Administration. San Francisco: Jossey Bass, 1999. Parsons, T. (1947). Introduction to Weber, M. The theory of social and economic organization (Henderson, A.M. & Parsons, T., Eds. & Trans.) New York: Oxford University Press. Peters, W.L. (1997). The effects of state bureaucratic reform eflorts on the role of the local superintendent and the structure of local public schools. Unpublished doctoral Dissertation, Michigan State University, East Lansing. Powell, A.G., Farrar, E., & Cohen, D.K. (1985). The shopping mall high school: Winners and losers in the educational marketplace. Boston: Houghton Mifflin. Rothstein, R. (2004). Class and schools: Using social, economic, and educational reform to close the black-white achievement gap. Washington, DC: Economic Policy Institute. Rowan, B. (1982). Organizational structure and the institutional environment: The case of Public schools. Administrative Science Quarterly, 27: 259-279. Rowan, B. (1982). Instructional management in historical perspective: Evidence on differentiation in school districts. Educational Administration Quarterly, 18(1), 43- 59. Rowan, B., and Miskel, C.G. Institutional theory and the study of educational organizations. In J. Murphy and KS. Lewis (Eds.), Handbook of Research on Educational Administration. San Francisco: Jossey Bass, 1999. Rudestam, KB. and Newton, RR. (2001). Surviving your dissertation: A comprehensive guide to content and process (2“d ed.). Thousand Oaks, CA: Sage. 300 Scheerhom, D. M. (1995). The eflects of state bureaucratic reform efforts on the role of the local superintendent and the structure of local public schools. Unpublished doctoral dissertation, Michigan State University, East Lansing. Title I Monitor Roundtable Discussion. (May, 2007). Breaking through the fog of school improvement. Thompson 's Title I Monitor, 12 (5), 1-3, 7-12. Thompson, JD. (1967). Organizations in action: Social science bases of administrative theory. New York: McGraw-Hill. Tyack, D. and Cuban, C. (1995). T inkering toward utopia: A century of public school reform. Cambridge: Harvard University Press. US. Department of Education. (2002). No Child Left Behind Act of 2002. [Electronic version]. Retrieved April 15, 2007, from http://www.ed.gov/policy/elsec/legiesea02/ 107-1 1 0.pdf US. Department of Education. (2007). Building on results: A blueprint for strengthening the NO Child Left Behind Act. [Electronic version]. Retrieved September 21, 2007, from http://www.ed.gov/policfielsec/lgg/nclb/ buildingonresultspdf Weber, M. (1947). The theory of social and economic organization. (Henderson, A.M. & Parsons, T., Eds. & Trans.) New York: Oxford University Press. Weber, M. (1949). “Objectivity” in social science and social policy. In E. Shils & H. Finch (Ed. & Trans.), Max Weber on the methodology of the social sciences (pp. 49- 112). Glencoe: Free Press. Weick, K.E. (1996). Drop your tools: An allegory for organizational studies. Administrative Science Quarterly, 41 (2), 301-313. Wolff, K.H. (Ed. & Trans). (1950). The sociology of Georg Simmel. Glencoe, IL: The Free Press. Yin, R.K. (2003). Case study research: Design and methods (3rd ed.). Thousand Oaks, CA: Sage. Zald, M. (2003). Preface to Thompson, J .D. Organizations in action: Social science bases of administrative theory. New York: McGraw-Hill. 301 llililgilillljilliillllillliii