Back in April, Dropout Nation reviewed Pennsylvania’s proposed plan to participate in the Obama Administration’s effort to eviscerate the No Child Left Behind Act’s accountability provisions and found it wanting. As it was noted back then, the Keystone State’s proposal — including the Plessy v Ferguson-like Cut the Gap in Half approach used by states such as Tennessee and Florida — would do little more than set back the state’s already half-hearted effort at advancing systemic reform.

wpid-threethoughslogo.pngSo it wasn’t all that surprising that the peer review panel reviewing Pennsylvania’s waiver plan also found it to be wanting. It was even less surprising that in spite of those concerns, U.S. Secretary of Education Arne Duncan went ahead this week and blessed the mess anyway. Once again, the peer review notes, along with the decision by Duncan to approve the plan anyway shows how sloppy the Obama Administration has become on the education policy front. And this sloppiness, driven by the administration’s arrogant goal of placing its own stamp on federal education policy, is already having terrible consequences for the futures of children.

As with most of the 39 other states and the District of Columbia, the Keystone State did as little as possible to vet its plans with families, civil rights groups, and others. Peer reviewers raised concerns that the Pennsylvania Department of Education “submitted limited evidence specifying the organizations involved” in developing the plan. Considering that the state didn’t even share its proposal until Dropout Nation and other outlets called out the state (along with the Obama Administration) for lack of immediate disclosure, the unwillingness of the state to actually discuss its plan with the public is hardly surprising; the state’s own “stakeholder group” working on the new teacher evaluation system didn’t include any families or community leaders.

Pennsylvania’s plans to implement Common Core reading and math standards was also found to be problematic. Even before Gov. Tom Corbett moved in June to temporarily halt implementation of the standards, peer reviewers were concerned that the state didn’t provide information on implementation strategies and other “action steps” needed to make the effort a success. The fact that Pennsylvania didn’t offer specifics on how English Language Learners and children condemned to special education ghettos would be provided comprehensive college-preparatory coursework also showed how “underdeveloped” the state’s plan is. Add in Pennsylvania’s decision to develop its own Common Core-aligned exams instead of using those developed by the PARCC and Smarter Balance consortia, along with the lack of information on how it would set test proficiency cut scores, and one can conclude that the Keystone State is just winging it on the implementation front. Given the political pressure on Gov. Corbett to ditch Common Core altogether, the Obama Administration’s approval of the waiver without having the state address peer review concerns is another case of Duncan and his staff approving plans without actually looking at what is happening on the ground within states. Sloppy, careless, and thoughtless policymaking.

Meanwhile Pennsylvania’s proposed accountability system — including the supposedly “ambitious yet achievable” Annual Measurable Objectives the Obama Administration wants states to set — isn’t worthy of the name. As already mentioned, the state says it looks to cut achievement gaps — in the case, the percentage of poor and minority children who are not scoring proficient on the state’s battery of exams — by 50 percent by 2018-2019. But as peer reviewers pointed out, the state “doesn’t adequately describe whether its gap closure measure sets the expectation that a 50 percent gap closure will be achieved after six years” even after a phone call with state education officials in April to discuss their concerns. Even that low bar of addressing achievement gaps only accounts for 10 percent of a school’s performance rating. By the way: The fact that Pennsylvania’s proficiency cut score targets are inflated — 35.4 percent of fourth-graders read Advanced on the state’s reading exam in 2011, four times greater than the eight percent of all students reading Advanced on the National Assessment of Educational Progress that year — makes it difficult to buy into any target the state sets.

It gets worse. One of the AMO targets districts must meet is ensuring that 95 percent of students take the Keystone State’s battery of exams, which is hardly ambitious (though certainly achievable). Graduation rates only account for 2 percent of a high school’s rating. Even worse, the state will also add a five-year graduation rate (based on ninth-grade enrollment instead of eighth, as it should be) alongside the more-accurate and honest four-year graduation rate, which the state will use to see if a district graduates 85 percent of its ninth graders.  This essentially allows districts to cheat the accountability system because the state will defer to the five-year graduation rate if it meets the 85 percent goal and if the district doesn’t meet the goal as it is supposed to within four years.

The worst part of Pennsylvania’s accountability system is that it includes a form of the super-subgroup subterfuges used by states such as Indiana and New Mexico. This version, called Historically Underperforming Students, lumps special ed students with kids in ELL programs and poor children. As with other super-subgroup efforts, the problem with the Historically Underperforming Students subgroup is that the performance of each student subgroup within it (and, in fact, the performance of all of these students) can end up being obscured because of the structure of the accountability system itself. A school or district can be ranked high-performing and still do poorly in educating poor children and kids trapped in special ed. This was a particular concern of the peer reviewers. And yet, it not only did Pennsylvania officials not address it, the Obama Administration approved the proposal anyway.

Considering Pennsylvania’s woeful record on systemic reform — especially that of Corbett, whose proposals to expand school choice has fallen to seed because of his unwillingness to use his political capital and bully pulpit — the shoddiness of its No Child waiver plan is no shock at all. Nor is it stunning that the Obama Administration has approved it. Duncan and his boss, President Barack Obama, have proven over and over — most-recently with its approval of the waiver plan submitted by the eight-district California Office for Reform Education — that they are far more concerned with their arrogant goal of putting their stamp on federal education policy than about pursuing their goals sensibly with the futures of children in mind.

Yet the administration has garnered little in good results. As seen last week with the administration’s move last week to put the approved plans from Kansas, Oregon, and Washington State in “high risk status” (and thus, threatening to cancel the waivers) because of their lack of follow-through on promised reforms, the administration’s penchant for approving half-baked waiver plans in spite of questions raised by its own reviewers about whether states would even fulfill them is rearing its ugly head. By allowing states to focus on the worst five percent of schools (along with another 10 percent or more of schools with wide achievement gaps), the administration is also letting districts not under watch off the hook for serving up mediocre instruction and curricula. As University of Southern California professor Morgan Polikoff and graduate student Andrew McEachin have pointed out in a study released last year, focusing just on the lowest-performing schools may not work as a reform approach unless states put the right accountability systems in place.

The controversy over A-to-F grading systems approved by the administration is a reminder that moving away from the Adequate Yearly Progress accountability approach developed under No Child has grave consequences for the credibility of accountability overall. Moves by the administration on other fronts — including the continuing effort to shut down D.C.’s school voucher program, and the U.S. Department of Justice’s lawsuit filed yesterday against Louisiana for expanding high-quality school options by providing vouchers to poor and minority kids because those kids attend schools in districts under school desegregation court orders — runs contradictory, both intellectually and in terms of policy, to its own efforts on advancing reform. Bayou State Gov. Bobby Jindal is right to call out President Obama for “trying to keep kids trapped in failing public schools against the wishes of their parents”.  Amid growing evidence — especially from Harvard professor Paul Peterson — that the Obama Administration’s efforts may have led to a halt in the improvements in student achievement made under No Child, there is little about the waiver gambit that deserves praise.

In just two years, President Obama, with the help of Duncan, has managed to gain the unenviable legacy of being the first black president to support plans that essentially subject poor and minority children who look like him to the soft bigotry of low expectations. Even worse, the president has damaged the very systemic reform efforts he helped sustain with smarter policies such as Race to the Top. Obama, along with his education secretary, should be ashamed of himself.