• PLUK PTI comments on Montana ESSA state plan – 12/16/16

    PLUK is a Montana nonprofit founded in 1985 by families of children with disabilities and special health care needs. PLUK is a network of 50,000 families and friends (educators and other professionals) who share information and support one another for the benefit of all our children. PLUK receives funding to operate Montana’s Parent Training and Information Center through the US Department of Education as a required component of the Individuals with Disabilities Education Act. As a part of this grant, PLUK is responsible to provide input to policymakers on issues related to families and children, especially those groups identified by ESEA as marginalized by disability, low income, or other socioeconomic factors. The ESSA provides federal funding to schools, districts, and states to raise achievement for these identified marginalized group of students based on a fairer and more effective system of public education. This is based on policies and practises developed by states in their state plans. To achieve greater equity in schools, the state plans are required to address: accountability for the achievement of all students, robust parent and family engagement and consultation, easily accessible and user-friendly data, and resource equity.

    Federal guidance to states in developing their state plans includes the following:
    The final regulations require a broad, robust, and transparent consultation with a diverse, representative group of stakeholders (including parents, communities, civil rights organizations, tribes, and other community-based organizations representing underserved communities) at multiple points during the design, development, and implementation of a consolidated state plan, to ensure state and local voices are included in each stage.
    The final regulations give states flexibility to create their own holistic educational visions, working closely with stakeholders and evidence-based interventions, tailored to individual needs to improve academic outcomes and turn around struggling schools.
    The final regulations seek to ensure that states and districts meaningfully include parents and other stakeholders to develop report cards that include timely and essential information to inform educational improvement for all students.
    The final regulations require that states, districts, and schools meaningfully engage parents and community members in critical decision-making. 1% of Title I funds must be used to support families, disseminate information, and collaborate with community-based organizations to increase family engagement.

    The Montana ESSA State Plan appears to be compliant in all areas, but is missing a significant number of stakeholder groups, especially the marginalized communities and other systems that serve them that are the focus of ESSA. Therefore, we would describe the plan as addressing the needs of the stakeholder group that participated, but not the needs of the families and students that are supposed to be served by the plan. Further, we would state that decision-making that excludes these primary stakeholders is not evidence-based and violates the Principles of Effective Family Engagement published in policy by the US Department of Education. The first principle is “Create continuity and consistency for children and families across systems and programs.” The Montana State Plan excludes the voices of our underserved communities and other systems serving families and offers only a vague compliance activity for Parent and Family Engagement – “The OPI plans to create a unified agency vision and mission to assist all LEAs in engaging families and communities…” The first step, according to US Department of Education policy is “to establish a culture in which families are seen as essential partners in the systems and Programs that serve their children.” Excluding families from participating is, basically, violating a civil right. It just seems like common sense that if you are addressing Parent and Family Engagement that parents and families should be participating. And, including service systems outside the OPI is equally necessary to create the “holistic” vision to achieve meaningful results.

    We have the following suggestions for improvement to the ESSA MT State Plan based on standards, evidence-based practice, and published policy:
    Meaningfully include input from marginalized community representatives and other systems serving them in the state plan and stakeholder group.
    Consider integrating the Principles of Effective Family Engagement in the joint Policy Statement on Family Engagement of the US Department of Education and US Department of Health and Human Services.
    Integrate independent third party participation in accountability systems and feedback loops for implementing incremental improvements.
    Include meaningful activities to develop capacity of family organizations to support family engagement in all schools and to develop family leaders to spearhead efforts in each community.
    Include concrete methods for data sharing, including school libraries and librarians, and other proven methods for all stakeholder groups.

    Respectfully submitted,

    Roger Holt
    PLUK Executive Director