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Graduation Competency Assessments Update: Thank you to those who contacted the Independent Regulatory Review Commission (IRRC) and local legislators with comments on the proposed Graduation Competency Assessments (GCAs). The public comments regarding the GCAs were instrumental in influencing lawmakers to carefully consider the impact that the proposed law would have on local school districts. The IRRC issued its comments on the State Board of Education's proposal to implement Graduation Competency Assessments. IRRC bases its comments on several regulatory review criteria, which include statutory authority; legislative intent; protection of the public health, safety and welfare; fiscal impact; whether the regulation represents a policy decision of such a substantial nature that it requires legislative review; reasonableness; need and implementation procedures. IRRC's comments reflect many of the same points that have been made by PSBA and other organizations opposed to the proposal. IRRC also indicated the need for the State Board to collaborate more closely with the Legislature and the regulated community on issues such as their authority to propose and implement the regulations and costs to school districts. Specifically, IRRC addressed three areas that have been prominent in PSBA's statements about the proposal. Regarding the need for the proposal, IRRC noted "Before the board moves forward with this proposal, we ask for a more thorough explanation of why the current system is not adequate to address the problem the proposal seeks to address. If the Board determines that regulatory changes are needed, it should consider administering those changes on a case-by-case basis, not as a statewide mandate." IRRC also questioned the Board's fiscal impact statement on the Regulatory Analysis Form, which was submitted with the proposal. The form indicated that the proposal would have no fiscal impact on school districts. IRRC stated, "While the RAF addresses costs related to state government, the RAF does not estimate the costs to local school districts for such procedures as validating the local assessment, administering and scoring the tests, record keeping and compliance with federal law (with respect to special education students). Therefore the RAF does not fully reflect the overall fiscal impact to school districts and the Commonwealth. The Board should consult with the regulated community to gain a more accurate understanding of how this proposal will affect them fiscally. Those findings should be included in the RAF submitted with the final form regulation." IRRC also expressed concerns about the proposal's impact on various categories of students and the potential for an increase in the drop-out rate. The Commission asked the State Board to more clearly state how the proposal adequately protects the health, safety and welfare of all citizens of the Commonwealth. Somewhat surprisingly, IRRC's comments lent some credence to the argument that the proposal is of such a substantial nature that it might require legislative action. Pointing to the GCA language in Act 61, recently signed omnibus School Code bill, the passage by the Senate of SB 1442 and the introduction of HB 2452 in the House, IRRC urged the State Board to work closely with the two legislative chambers and its education committees to ensure that final form regulations are consistent with the intent of the General Assembly. While the IRRC comments closely reflect the arguments that PSBA and others have been making, it is important to note that they are not a formal approval or disapproval of the proposal; however, they do serve as notice to the State Board that the regulatory review criteria have not been met. IRRC's comments are available at www.irrc.state.pa.us.
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7/08, ccb |
