Dear Ms Dastugue and BESE Members:
I was disappointed by the lack of substance and accountability of BESE policy on choice courses as interpreted by Ms Pozniak in her answers to the questions. My major concern is that the application of BESE policy described does not seem to require students to attend a minimum number of hours of instruction in order to receive credit for a choice course. While Ms Pozniak states at the beginning of her response that the choice courses will emphasize achievement over attendance, her answers reveal that students may get full credit and the provider may get full payment for a choice course even if there is no evidence presented at the end of a choice course that adequate learning has taken place.
At the beginning of her response to my questions Ms Pozniak characterizes seat time or class time as archaic. I do not believe Ms Pozniak is qualified to dismiss school seat time as “archaic”. She states that choice courses will emphasize learning outcomes over length of instruction. If seat time were archaic, we would not need the mandatory school attendance law. If seat time were archaic BESE would not have a policy that denies course credit to students who have more than the minimum number of allowed unexcused absences. If seat time were archaic, our district attorneys and judges could call off all efforts to require parents to send students to school on a regular basis. The fact is that the lack of accountability by some parents and poor student attendance is one of the greatest root causes of under-performance by many of our students. There is a direct relationship between students who miss many days of school and the low performance of such students. In addition, Act 2 specifies that quality course providers in their application to BESE must specify the length of each course. That implies that students are expected to attend or participate for a particular number of hours specified for a course.
I believe the interpretation of BESE policy relative to choice courses by Ms Pozniak if implemented in the way she described will result in a lowering of standards and a decline in student performance by many students who participate in such courses. I believe such a policy will encourage fraud and abuse in the use of MFP funds by some of the choice course providers. Such abuse could dwarf the abuses seen recently in the chaotically implemented voucher program this school year. I respectfully request that BESE carefully consider the issues raised in my questions on choice courses and adopt policies that will insure safeguards of taxpayer dollars and insure that students receive adequate instruction from each choice course.
In her response Ms Pozniak seems to assume that BESE will not require minimal instructional time for any of the choice courses. Apparently BESE will simply take the provider's word that students have completed their assignments for the course as adequate evidence to award credit for a course. Since the law allows course providers to receive the remaining 50% of their funding based on students completing a course on time, taxpayers can expect that many students may not be held to minimal standards for completion. If regular attendance or participation for a certain number of hours will not be required, who in the Department of Education will check to see if a student who has sporadically participated in a choice course has actually completed the required assignments of a choice course?
Ms Pozniak's responses verify my fears that the course provider can stipulate that a student has completed a course and receive full payment even if the student cannot demonstrate reasonable knowledge of the course or even if the student fails to pass the end of course exam. How would such a system reward achievement over attendance? In such a case, how can BESE justify full payment for the course? How does this system emphasize learning outcomes over length of instruction?
In addition, Ms Pozniak's responses gives no assurance that any part of the 50% initial course payment will be refunded to the state and the local school system even if the student drops out or is expelled soon after enrollment in a choice course. This creates an incentive for choice course providers to use aggressive promotions to get students to register for such courses even if the student may drop out with minimal participation in the course.
Ms Pozniak indicates that if a student takes a choice course for which end of course testing is required by BESE and then fails the end of course test, the state will still make full payment to the provider based upon the provider's claim that the student has completed the course. Does this system reward achievement? BESE should not waive minimum course attendance and also waive minimal performance.
I must recommend that BESE, consider adopting a strict policy relative to choice courses that require the standard number of hours of instruction in order for the student to receive course credit and for the provider to receive full payment for a choice course. This rule is particularly important if the student does not pass the end of course test required by BESE. Otherwise there is insufficient accountability for use of our taxes.
Ms Pozniak dismisses the question about choice course providers being required to document attendance or participation of students by simply stating that choice courses comply with the objectives of the compulsory attendance law. I believe this is an incorrect interpretation of the law and is not acceptable to me as a taxpayer. Since Act 2 stipulates that each choice course must have a length, BESE should have a firm policy that requires choice course providers to actually document the number of hours of student attendance or participation for each choice course whether it be an on-site course or a virtual course. I believe that even in the case of a virtual course delivered over the Internet, it is possible for the provider to monitor the participation time of students.
Ms Pozniak also states that when a student takes a credit recovery course from a choice provider and that provider reports to the student's home school that he/she has passed the course, the home school must grant the student credit even if the student does not pass the end of course test for that course. This is not acceptable. What is the point of taking a credit recovery course if the student still does not have satisfactory knowledge? How does this reward learning outcomes? BESE should not award full payment to a choice course provider for a credit recovery course if the student cannot pass an approved end of course test.
I believe that any lesser requirements by BESE will result in the raiding of critical MFP funds allocated to local school districts and will make a mockery of accountability. I will be happy to appear before BESE and further clarify my concerns and recommendations on the issue of choice course regulations.
The response to my questions from Ms Pozniak are reprinted below.
I am sending this response on behalf of Penny Dastugue.
Board of Elementary and Secondary Education
Course Choice will provide families with unprecedented choices – down to the
course – to prepare students to succeed in college and careers. Courses will be
aligned to the expectations of post-secondary education and the jobs that await
students after high school. Under the program, the measure of quality will be
student achievement, not just attendance.
* Will choice course providers be required to deliver a certain number of
clock hours of instruction in order for a student to receive one Carnegie unit
of credit and for the provider to receive the agreed upon tuition for one
* Could choice course providers offer courses that require different amounts
of instruction time for different courses that earn one Carnegie unit of credit?
* Will there be a certain number of hours the student in a virtual class
must participate in order to receive credit for the course?
* Could a virtual choice course provider substitute an end of course test as
validation that a student has completed a virtual choice course instead of
requiring the student to “attend” or participate in a certain number of hours of
Course Choice uses a performance-based funding model and providers have the
option to implement a competency-based model to award credit. Course Choice
moves beyond the archaic “seat-time” model, which rewards attendance over
achievement, to a new model which emphasizes learning outcomes over length of
instruction. School districts also have the opportunity to waive
“seat-time/clock hours” (Bulletin 741--Louisiana Handbook for School
Administrators with the exception of §907, Secondary--Class Times and Carnegie
To earn credit, students must demonstrate mastery of the grade-level
expectations, just like traditional schools. Also like traditional schools,
students can demonstrate mastery by earning a passing score on a standardized
statewide assessment or end-of-course exam, providing a portfolio of work or
completing the required assignments of the course.
Students who are behind in credits can accelerate their progress toward
graduation by completing blended courses, which combine online and face-to-face
instruction. Students will be able to progress through a course at their own
pace, moving through the content as they master standards grouped into modules,
clusters, or units. Providers can use multiple conventional methods, including
assessments, research projects, and presentations, to demonstrate mastery of
course standards or competencies to earn credit toward graduation,
Unlike traditional schools, providers are only paid when a student completes a
course. Providers are paid 50% upon enrollment of the student and 50% upon
completion of the course by the student.
* Could a choice course provider be approved for accelerated choice courses
where students who can demonstrate mastery of a course by taking a test would be
allowed to complete the course in a shorter period of time than what is normally
required for a Carnegie unit of instruction? If the answer to this question is
“yes”, would the Choice course provider still receive the same tuition as if the
course required a standard number of hours of instruction.
The same funding model applies to Course Choice providers and school districts.
Both Course Choice providers and school districts earn funding when a student
demonstrates mastery in an accelerated course.
* Suppose a student taking a choice course drops out soon after starting the
course and no longer participates in a choice course. Will the choice course
provider be required to reimburse the state for any of the initial funding?
* Suppose a choice provider expels or otherwise terminates a student enrolled
in a choice course soon after the course begins, will there be provision for
return of any portion of the tuition?
Under the law, Course Choice providers will receive 50% of funding for the
course upon successful enrollment and 50% of funding upon successful, on-time
completion of the course. Course Choice providers are penalized 10% if a
student completes the course late, receiving just 40% of the second installment.
Course Choice policy will allow an introductory period which allows students to
register for the class, review course materials and start initial coursework.
* Suppose a student takes and completes the required number of hours of
participation in a choice course and receives a failing grade from the choice
provider, will there be any provision for refund of any of the tuition?
* Suppose a student takes and receives a passing grade for a choice course
for which the state requires end of course testing and the student fails to
receive a passing score on the state test. Will there be any provision for any
refund of tuition?
The same policy applies to Course Choice providers and school districts. Like
school districts, Course Choice providers receive funding when a student
completes a course. Also like school districts, students do not have to earn a
passing score on a standardized end-of-course exam to receive full funding for
* Suppose a student takes and passes a credit recovery course from a choice
provider, and the student is tested on the course by his home school following
the completion of the course and fails to make a score that is acceptable to his
local school system for receiving credit for this course. Is the student's local
school system still required to give the student credit for such a course? Will
the choice course provider be allowed to keep the tuition?
Under state law, school districts must award credit for courses completed by
students through Course Choice and those credits must count toward the
requirements of a diploma.
* Will choice course providers be required to take attendance roll for
students attending choice courses, particularly when the student is attending a
course provided at a site provided by the course provider? If roll is taken and
the student is found to be absent without excuse for more than the minimum
number of days required by BESE for public school attendance, will the student
still be allowed to receive a passing grade on the choice course?
* In the case where a choice course provider is providing a virtual or
internet delivered course so that the student participates in a choice course
from his/her home, will the choice provider be required to take a participation
roll each day the student is supposed to be receiving instruction?
Course Choice complies with the objectives of Louisiana’s compulsory attendance
* What action would the DOE take in a case where there is no evidence
provided by the virtual provider that the student actually participated in a
minimum number of hours of instruction in a virtual course?
Under state law, the Board of Elementary and Secondary Education will conduct a
thorough review of the Course Choice providers after one year in the program.
If the academic performance of students enrolled in a provider’s course does not
meet rigorous standards, the provider will face consequences, including
probation and/or removal from the program.
* Are choice course providers allowed to refuse admission of any students to
a choice course when the enrollment limit has not been reached who have been
classified by their local school system as eligible to take the choice course in
Course Choice providers must accept students who meet the pre-requisites for the
course (such as, Latin I before Latin II). Providers cannot refuse eligible
students if space is available in the course.
* Would a choice course provider be allowed to test a student wanting to
enroll in a choice course and by that means find that the student is not
qualified for or prepared to take the choice course in question and thereby deny
the student admission even if the student has met all other prerequisites for
admission to a course?
Course Choice providers must accept students who meet the pre-requisites for the
course (such as, Latin I before Latin II).
September 4, 2012
Questions about new choice courses: