by James C. Sherlock

“J. Out of this appropriation, $120,000 the second year from the general fund is provided for the Department of Education to develop and implement a pilot program to more comprehensively supervise school division compliance with a subset of key standards by requiring (i) the submission of more comprehensive compliance information, (ii) selective independent verification of compliance, (iii) monitoring of corrective action implementation, and (iv) analysis of compliance trends and issues.”

Those words, “selective independent verification of compliance” and “monitoring of corrective action implementation”, from the Governor and the General Assembly of Virginia, 2021 Appropriations Act.

I am reminded of words attributed to V. I. Lenin, the author of State Planning Commission (1922) and How We Should Reorganize the Workers’ and Peasants’ Inspection (1923).

“State control makes it possible to check systematically on the execution of the decrees of the central power, to strengthen state discipline and legality, and to study the validity of motives and feasibility of resolutions made by the central state bodies and help improve the practice of devising and adopting them.”

“Workers and peasants inspection” indeed.

Updated Jul 24 at 12:45 PM

If you ever wondered how heavy are the hands of the Governor, the General Assembly and the Virginia Department of Education on your local school board, I offer here the answer to that question.

As for the costs to the school districts, I don’t know because the state does not, and is not interested.

State administrative requirements are referenced in Questions in the 2020-2021 SOQ Compliance and Other Reporting Data Collection released as an attachment to Superintendents Memo #173-21 to school superintendents on June 21 of this year.

This is not a complaint about the Questions checklist, but rather a challenge to the breadth and depth of the underlying requirements. Parents, grandparents and others interested in K-12 education, meaning all voters, will find the memo very informative.

Questions is 31 pages long. Each question refers to a rule that itself can run to dozens or even hundreds of pages.

The list of questions in Section 1 of this memo have been seen before.

But Virginia’s governor, General Assembly and Board of Education have spent the past year “updating” the requirements referenced in Questions.

To what end? More state command and control of local education.

Changes to law. Many of the rules are complex and may require legal counsel for school boards to interpret, like the new Social-Emotional Learning curricula and the pending Revisions to Model Guidance for Positive and Preventative Code of Student Conduct Policy and Alternatives to Suspension that runs 197 pages long.

It represents a complete overhaul with 1,092 comments and changes of a student conduct policy last published in 2019. Many of the changes were mandated by new laws. Some examples.

Senate Bill 1020

“No principal shall report assault and battery with no injuries to law enforcement if the parties complete the established school disciplinary process”; and

House Bill 837

amends and reenacts § 22.1-276.01 and § 22.1-279.6 of the Code of Virginia.

In amending § 22.1-279.6 the bill permits any school board to include in its code of student conduct a dress or grooming code. For school divisions who do include dress and grooming standards for students, the amendment explicitly outlines parameters of those standards as they relate to religion, gender, equity, and privacy.

The bill also requires the Board of Education to include in its guidelines and model policies for codes of student conduct “(i) standards for reducing bias and harassment in the enforcement of any code of student conduct and (ii) standards for dress or grooming codes.”

House Bill 256

amends § 18.2-415 of the Code of Virginia to provide

that an elementary or secondary school student is not guilty (actually in bold in the law) of disorderly conduct in a public place if the disorderly conduct occurred on the property of an elementary or secondary school, on a school bus, or at any activity conducted or sponsored by any elementary or secondary school. The 2019 Model Guidance does not include “disorderly conduct” as a behavior for which students can be disciplined,

House Bill 257

and SB729

“eliminate the requirement that school principals report to law enforcement certain enumerated acts that may constitute a misdemeanor offense as outlined in subsection A of § 22.1-279.3:1.”

That should keep APs up burning the midnight oil.

School personnel cultural competency. Senate Bill 1196 passed in 2021 requires:

“teacher, principal, and division superintendent evaluations to include an evaluation of cultural competency. The bill requires every person seeking initial licensure or renewal of a license from the Board of Education (i) to complete instruction or training in cultural competency and (ii) with an endorsement in history and social sciences to complete instruction in African American history, as prescribed by the Board.”

Cultural competency training must be completed at least every two years.

Section 2 is entirely new courtesy of the Appropriations Act discussed earlier.

Below is a summary of the compliance questions. No fair just resubmitting last year’s answers.

Have a nice summer, school districts.

2020-2021 SOQ Compliance and Other Reporting Data Collection

Section One: Standards of Quality

• 46 questions about compliance with Standard 1: Instructional Programs Supporting the Standards of Learning and Other Educational Objectives;
• 32 questions about compliance with Standard 2: Instructional, Administrative, and Support Personnel;
• 8 questions about compliance with Standard 3: Accreditation, Other Standards and Evaluation;
• 10 questions about compliance with Standard 4: Student Achievement and Graduation Requirements;
• 18 questions about compliance with Standard 5: Quality of Classroom Instruction and Educational Leadership;
• 14 questions about compliance with Standard 6: Planning and Public Involvement;
• 13 questions about compliance with Standard 7: School Board Policies;
• then, wait for it, a question about compliance with Standard 8: Compliance.

Section Two – Other Reporting (We can call it the Lenin Doctrine). 

Section Two is new and is comprised of  questions supporting a General Assembly-directed pilot program related to Standards of Quality Compliance Data Collection.

“The supplemental SOQ questions below are part of the pilot program and designed to provide additional insight as to how divisions comply with certain standards. More detail on the pilot program can be found in Item 143.J of the 2021 Appropriation Act.”

More detail indeed.  I led with it.

Stuffed into the 2021 Appropriations Act was  $120,000 for pilot program design and implementation at VDOE. No estimate of the cost of implementation by 132 school districts.

One question is whether the curriculum of the local district is aligned to the Standards of Learning. Another is related to Prevention, Intervention and Remediation for students who are educationally at risk. A third on Gifted Student Identification. Another on Reading and Mathematics Assistance.

Then one on Data Collection and Analysis. This query may have been written with the City of Richmond Public Schools (RPS) in mind.

Then comes Special Education, Gifted, and CTE Staffing, Instructional Technology Resource Teacher; Special Education Accommodations; and Year-Round School Pre-Labor Day Opening.

Then a lengthy list of questions on School Accountability.  

First on that list is Prerequisite Conditions for Accreditation. Accreditation has been suspended suspended since 2018-19, so this represents perhaps a tune-up.

1. Promotion/Retention
2. Course Offerings
3. Program of instruction and learning objectives and programs for each of elementary, middle and secondary schools.
4. History/Social Science and English
5. Roles of the Principal, teaching staff, support staff and staffing requirements for each.
6. Facilities and safety.
7. Parental Notification
8. SOL
9. Comprehensive school plan

Then sections on:

1. Corrective actions taken over the past year, 
2. Comprehensive, Unified, Long-Range Plan,
3. Application of the School Quality Indicator Performance Levels to Actions, 
4. Compulsory School Attendance/Truancy,
5. Teacher Evaluations/Continuing Contract,
6. Length of School Term,
7. 140 Clock-Hour Waiver,
8. Charter Schools – Approval or Denial or revocation,
9. Textbook adoption,
10. Virginia Preschool Initiative (VPI) Programs,
11. Early Reading Intervention,
12. Algebra Readiness Payments,
13. Algebra Readiness Initiative Payments (this is not a repeat – these are separate programs in the Code of Virginia),
14. Math/Reading Instructional Specialists Initiative,
15. Early Reading Specialists Initiative,
16. Tuition Certification for Governor’s Schools and Foreign Language Academies, and, finally,
17. Acceptable Internet Use Policies.

Questions for candidates. 

All of this may not be necessary for the effective teaching of children, but it is nonetheless mandatory. All of it represents various ropes with which to hang school boards, division superintendents, principals, teachers and special staff .

The massive expansion of the cost and number of administrators in Virginia public schools is directly traceable from the Questions in the 2020-2021 SOQ Compliance and Other Reporting Data Collection and its predecessors.

A 31-page checklist of to-do items. It serves as exhibit A. The related exhibits run to more than a thousand pages.

As per the 2021 Appropriations Act, the school districts can look forward to yet more comprehensive supervision by the state  Which will need more employees.  Likely lots more.

The smallest districts will soon have more administrators than students. Even the biggest ones will have trouble wrestling this snake. More employees yet again.

Keep that in mind when you question gubernatorial and General Assembly candidates about education policy, especially the Lenin Doctrine.