We encourage the N.J. Department of Education and the State Board of Education to reconsider the following definitions:
“Accuracy” – There should be a provision for inter-rater reliability and consistency, but each research-based evaluation model should provide the characteristics associated with each rating. Is every district going to have a master coder? Does simply completing a training program make one a master coder? This is unrealistic.
“Annual performance report” – Why does this definition state it is used “as part of the evaluation of the teaching staff member’s effectiveness?” It should, in fact, sum up the the evaluation. The annual summative evaluation rating should be included as part of this report.
“Appropriately certified personnel” – This definition should mirror the new tenure/evaluation law (P.L. 2012, Ch. 26), which states that evaluations and observations shall be conducted and prepared by an individual employed in the district in a supervisory role and capacity and possessing a school administrator certificate, principal certificate, or supervisor certificate.
“Concurrent Validity” and “Construct Validity” – How does the Department intend to guarantee these measures?
“District educator evaluation rubric” and “Educator practice evaluation instrument” – The use of these two terms is confusing, as they overlap as used in the proposed regulations. The term “rubric” means the implementation of criteria; the instrument is also a rubric. A district’s evaluation program is more than just a rubric, but these definitions do not clarify this.
“Evaluation” – This definition should mirror the new law (P.L. 2012, Ch. 26) as the process of evaluation described in the legislation will result in a written annual performance report.
“Evaluation means a process based on the individual’s job description, professional standards and Statewide evaluation criteria that incorporates analysis of multiple measures of student progress and multiple data sources. Such evaluation shall include formal observations, as well as post conferences, conducted and prepared by an individual employed in the district in a supervisory role and capacity and possessing a school administrator certificate, principal certificate, or supervisor certificate.”
“Educator practice evaluation instrument” – This definition should be put in clear concise language that is easily understood by anyone reading it. Just because an instrument is evidence-supported does not mean it is high-quality or that its use will improve student achievement.
“Expert judgment” – What criteria are used to determine expert judgment? Why is the Department using a definition from a website about project management? [When originally posted on the Department’s website, there was a link to http://project-management-knowledge.com/definitions/e/expert-judgment/]
“Indicators of student progress and growth” should be replaced by the definition of “Multiple objective measures of student learning” as defined in PL 2012, c. 26.
“Multiple objective measures of student learning means the results of formal and informal assessments of students. Such measures may include a combination of, but are not limited to: teacher-set goals for student learning; student performance assessments, including portfolio projects, problem-solving protocols, and internships; teacher-developed assessments; standardized assessments; and district-established assessments.”
“Master coder” – This definition is unnecessary. (See comment under definition of “accuracy.”) Definitions should be self-contained and not require other definitions to explain them.
“Observation” – The term “evaluation event” should be replaced by the clear language in the current regulation, which reads “a visit to an assigned work station.”
“School improvement panel” – This definition should mirror the language in PL 2012, c.26, to fully describe composition of the panel.
“The principal’s designee shall be an individual employed in the district in a supervisory role and capacity who possesses a school administrator certificate, principal certificate, or supervisor certificate. The teacher shall be a person with a demonstrated record of success in the classroom who shall be selected in consultation with the majority representative. An individual teacher shall not serve more than three consecutive years on any one school improvement panel.”
“Scoring guide” – This definition is unnecessary and is provided through the “Educator practice evaluation instrument.”
“Skills assessment” – This definition is not necessary since “proof of mastery” is defined in the definitions and the reference to the term later in code is clear.
“Student growth percentile” – Use of student growth percentiles is an unfair measure of student achievement. Value-added models fail to take into account the multitude of factors that affect student learning and achievement.