Over the past year, Ohio lawmakers have been mulling revisions to the state’s teacher evaluation policies. The leading proposal, put forth in similar provisions in Senate Bill 240 and Senate Bill 216, would replace the state’s current evaluation framework, known as the Ohio Teacher Evaluation System (OTES), with a framework sketched out by the Educator Standards Board (ESB).
If passed, the new evaluation system would continue to require annual teacher evaluations (with some exceptions); protocols calling for at least two thirty-minute observations; and ratings assigned along four categories. The major difference between OTES and the ESB recommendations is how they incorporate student performance data in teachers’ evaluations. Controversially, OTES prescribes certain weights that student growth measures must receive in the rating system. However, ESB proposes that “high quality data” be embedded as “sources of evidence” that evaluators can use to justify their ratings along various dimensions of Ohio’s performance rubric.[1] While an updated rubric has yet to be unveiled, it would likely follow a national pattern that is now weakening the use of student data in teacher ratings.
Replacing OTES with the ESB approach may or may not end up being an improvement. But Ohio lawmakers shouldn’t be the ones to decide which framework to use, or other matters of teacher evaluation. Rather, they should follow the advice of an older but still relevant RAND Corporation paper that contains the timeless recommendation: “states should not impose highly prescriptive teacher evaluation requirements.”
Scrapping mandates would reverse a decade-long national effort to bolster teacher evaluations through various policy levers. These well-intentioned efforts aimed to solve several problems in evaluations, including perfunctory classroom observations and systems that deemed nearly all teachers as satisfactory. Unfortunately, these efforts have been largely in vain. Evaluation systems continue to deem almost all teachers as competent, and many evaluators continue to sleepwalk through the process. The only things that changed were the incredible amounts of time that administrators have been forced to spend meeting state requirements and the additional testing needed to generate data for evaluations. Hence the calls to change course once again.
Instead of searching for blanket solutions, a superior approach would simply restore the rights of school leaders to manage delicate and context-dependent matters of personnel policy. By removing evaluation mandates, legislators would shift a central management task to the district and school level—where it rightfully belongs. School leaders bear the responsibility for their schools’ performance; have direct supervision over staff; can best judge what approaches are feasible within their internal political environment; and understand their own schools’ time and resource constraints. Due to considerations such as these, Ohio lawmakers should allow school leaders to undertake, without regulatory interference, the hard but essential work of managing people.
To press this idea further, let’s return to the aforementioned RAND report and apply its insights to specific evaluation mandates: conformity to the ESB (or OTES) framework and annual teacher evaluations.
Evaluation framework: One of RAND’s key insights is that “the school district should decide the main purpose of its teacher evaluation system and then match the process to the purpose.” Behind this statement is the notion that evaluations serve multiple purposes. On the one hand, they aim to help teachers improve their practice through feedback. On the other hand, they also try to hold teachers accountable by informing high-stakes personnel decisions. Yet a singular framework won’t match the main purpose of evaluations as understood in various contexts. For instance, OTES tends to veer more into accountability territory with its use of hard data that can be used to defend decisions such as teacher retention or dismissal. This type of approach might be warranted when leaders oversee struggling schools or face reductions in force due to enrollment declines. But an accountability focus may not be needed in districts that see evaluations as a way to help teachers go from good to great. Flexible, feedback-oriented frameworks might be more appropriate in those contexts.
Evaluation frequency: An equally important conclusion from the RAND paper is that “top-level commitment to and resources for evaluation outweigh checklists and procedures.” The first part of this statement deals with the unmistakable need to commit to evaluations, lest they become mindless routines. But the other key idea is that schools need to devote resources—time especially—to conduct purposeful evaluations. Under state law, schools must evaluate all teachers on an annual basis, though exceptions are made based on teachers’ prior ratings.[2] In schools with twenty or thirty teachers, undertaking this many evaluations per year could yield superficial reviews as resources are stretched thin. To conduct rigorous evaluations within constraints, schools might need to consider strategies other than annual reviews. For instance, to allow time for deeper evaluations, some schools might want to review teachers on cycles—perhaps humanities instructors in even-numbered years and STEM in odd. Other schools might need a targeted approach in which struggling or inexperienced teachers are evaluated more frequently, maybe each quarter. Such reasonable strategies, however, are disallowed or discouraged when the norm is to evaluate all teachers annually.
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Delegating authority to school leaders on evaluations would raise concerns for some. Will evaluation practices worsen without regulations? Will it be more difficult to root out teachers who cannot demonstrate minimal competence? Both are possible, but there are ways to mitigate these risks.
- State policymakers should continue to require school boards to conduct annual superintendent and principal evaluations. Formally holding these individuals responsible for implementing teacher evaluations, as delineated by local boards, would ensure they occur on a regular basis. A reasonable case could be made to require schools to evaluate non-tenured teachers on an annual basis, and require use of those results in tenure decisions. However, in principle, evaluating non-tenured teachers and conditions of continuing employment should be determined by local schools, with minimal state regulation.
- Ohio lawmakers should maintain robust, transparent school report cards that put pressure on local leaders to produce solid academic outcomes and adopt practices, like purposeful evaluations, that can raise achievement. In cases where schools are chronically failing to perform, the state could then consider top-down requirements.
- The legislature should consider restoring other management rights to school leaders, including the ability to remove low-performing teachers with less red tape. While this approach delves into challenging issues such as “just cause” statutes, bold legislators should work on removing structural barriers that make dismissal difficult or that discourages principals from even trying. Lawmakers could also prohibit evaluations from being subject to collective bargaining so that management is not tempted to compromise its right to review staff performance.
- Ohio legislators should continue to promote healthy competition among schools. The discipline of the market often compels companies, under no legal coercion, to implement robust HR practices lest they lose customers or top-notch employees. Schools should likewise be incentivized to adopt strong personnel policies, including evaluation, that cultivate the talent needed to attract and serve families and students.
- To build the capacity of schools committed to rigorous evaluation, legislators should appropriate funds to train independent evaluators, perhaps employed by regional ESCs. These individuals would have the expertise to make sound judgments about teacher performance and offer clear suggestions for improvement. Although some principals may be effective evaluators, others may not be for various reasons. Some might lack the subject-area expertise to evaluate certain teachers; others might withhold uncomfortable feedback to teachers they don’t want to offend; and still others might be overwhelmed by the sheer number of evaluations to complete. Policymakers would promote stronger on-the-ground practices by encouraging the use of independent experts who can assist principals in carrying out evaluations.
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On certain issues, state lawmakers need to insist on uniform rules and regulations. They include things like standard assessment and school accountability systems, uniform financial reporting, and health and safety rules that apply to all. But the legislature should embrace differences in the way that schools organize and manage themselves. Rather than imposing requirements onto all schools, they should allow local management to make decisions about personnel practices, including teacher evaluation.
[1] “High quality student data” is defined differently under SB 216 and 240. The former defaults to local boards to select assessments to generate these data; the latter is more prescriptive, with ODE defining the term and also requiring the use of teachers’ value-added data when applicable.
[2] The exceptions were enacted after the initial law implementing OTES passed. Though they reduce administrative burdens, the exceptions create problems of their own, including issues of fairness to all teachers and perverse incentives for principals who might be tempted to inflate ratings knowing they could be relieved of this responsibility in the next year.
