Testimony Before The New Jersey Department of Education

[Dollar$ and Sense]

Dollar$ and Sense is an organization that looks to provide constructive solutions. With this approach in mind, I actually read the 215 pages of Chapter 23A. When I finished, I was firm in my conclusion that our Department of Education (DOE) has become a Department of Regulations. Considering the goals of education and fiscal efficiency, the regulations are counterproductive. The degree of micro managing is contrary to successful organizational models. On the surface, it just doesn’t make sense.

I had to ask, what are they thinking, what are they trying to accomplish? We have been presented with 215 pages that maximize the DOE’s ability to intrude. Trenton has sent out so many conflicting messages that there has to be justification that isn’t clear.

We are being asked to grow and to shrink at the same time. The demands of our global world tell us to enrich the learning experiences for all students. The program called the “Personalized Student Learning Plan” was recently announced by our DOE . “A formalized plan and process that involves students setting learning goals based on personal, academic and career interests, beginning in the middle school grades and continuing throughout the high school with the close support of adult mentors that include teachers, counselors and parents.” (New Jersey Administrative Code N.J.A.C. 6A:8 – Standards and Assessment for Student Achievement). That sounds fantastic. How does this fit into a district’s ‘adequacy budget?” Within the cookie cutter district of 5,000 k-12 students how is this to be accomplished? Increased rigor brings with it the increased need for remediation. How will this be paid for when we are required to limit surpluses to two percent and second questions require a super majority?

I am asking these questions to understand what is behind the “Accountability Regulations.” What are they intended to accomplish?

If the impetus is to have accountability, there are other chapters of code, and legislation, which address those issues. Why do we need another 215 pages to regulate what is already regulated?

Could it be that the abuses of a few have created this need to thoroughly regulate? New Jersey has well beyond 90% of our districts where integrity is paramount and Boards of Education are efficient managers. We cannot assume that the bad behavior of the few justifies such thorough micro managing.

Fiscal efficiency isn’t the goal. For a district’s audited finances to be re-audited by our Executive County Superintendents is redundant. When reading this section I asked myself if the DOE wants do all of our bookkeeping. I wouldn’t think so, or would they? Why then would the regulations be so detailed and so intrusive? Why would the DOE want to create so much extra work for district Business Administrators and our county Business Administrators? At a recent Legislative interview of Executive County Superintendents, a common concern was, “Do you really need that full time County Business Administrator?” Does our Legislature know what our DOE is doing?

There isn’t sense to worrying about nickels when we are losing dimes. There is a waste that far exceeds the losses of the so-called “abuses”. I am referring to our Executive County Superintendents. We are asking some of the state’s leading educational talents to play the role of fiscal police. Do we remember our educational goals? We all know of magic done by our finest educational talents. Has the DOE forgotten that relationships matter? Relationships open the doors for those successes. The Executive County Superintendents are spending inordinate amounts of time re-examining and re-evaluating as if the first examination and the first evaluation couldn’t possibly have been accurate. Many are being asked “are we permitted” questions about such serious topics as can we provide sandwiches or can we celebrate a teachers successful career. We need educational leadership more than ever and yet we are not letting leaders lead. This is a huge waste of resources. I recognize that no single individual will make or break our schools, but the loss of Dr. William King is huge. Who else will be lost because we have top educators worrying about donuts and glossy paper?

We have defined “adequate” as what it takes to accomplish the minimum. Thorough and efficient is defined by the Core Curriculum Content Standards. Should we choose to reach higher, we must tell the public that we are proposing to spend more than the DOE recommends. Shouldn’t the department concerned with education be telling us that we must do the minimum, but if we can, we should maximize educational opportunities?

Perhaps my greatest concern is for our special needs families. Oversight is one thing, but the student-by-student decision making needs to stay close to home. The sharing of services, as provided currently in Bergen County, is a benefit all can appreciate. Guidance and referrals can only help. But when it comes to the development of an IEP, decisions of such a personal nature require the localized insights of district personnel. The development of an IEP, the need to provide for a child, and the importance of avoiding conflict cannot be compromised by a short-term need to reduce expenses. Waste is certainly not something we can permit, but proper care for our most challenged students must be our primary concern.

Not long ago, KPMG was commissioned to provide a performance audit of our Department of Education. They concluded that the Department was understaffed and under funded. Since then, the responsibilities of the Department have grown many times. Will sufficient staffing and funding be made available for our new Department of Regulations? Without that, there is no chance for success. Does the DOE have the fortitude to stand up to our Legislature and make the need for funding and staff known?

What is it that our Department of Education is hoping to accomplish by issuing such all encompassing and intrusive regulations? If all local work is going to be done again by the county extension of the DOE, why is there a need for local Boards of Education and Administration? I say this is penny wise and pound foolish.

We know that the success of education in New Jersey ties directly to the special attention we pay to the needs of our students. We know that all children are important and all learn in different ways. We provide support services on local levels and this accounts for our success. The development of our “Personalized Student Learning Plan” program proves that we know this. There are county-based systems that provide some fiscal efficiencies, but as always, there must be a cost. Are we willing to sacrifice our superior test scores and our nation leading graduation rate? In these areas, locations with county-based systems don’t measure up.

The vision I want to share has corporations and small businesses coming to New Jersey because we have the most educated and most qualified workforce in the nation, not because of a tax break we give up. The worker here will best allow for their success as a business, and after all, it is all a business decision, isn’t it?