Thursday, August 21, 2008

Proposed Rulemaking to amend the No Child Left Behind Act

National Governor’s Association

The nation’s governors have submitted comments to the U.S. Department of Education in response to the April 23rd Notice of Proposed Rulemaking to amend the No Child Left Behind Act.  The National Governors Association (NGA) comments focus on the proposed regulations as related to a common high school graduation rate and the use of that rate for accountability purposes.


While NGA appreciates the acknowledgment of gubernatorial leadership in establishing a voluntary state high school graduation rate, concerns remain about the implementation.


Governors focus on three specific areas in their comments:


1)      Interim Averaged Freshman Graduation Rate – NGA is concerned that proposed regulations would “require states to calculate an interim high school graduation rate.”  The Department “should not require an interim rate.”


2)      Alternate Definition of Standard Number of Years – “Governors believe additional discussion and clarity is necessary to ensure a clear, transparent process and timeline for states to use an alternative definition.” This is critical for state comparability and for the flexibility to promote “innovative education solutions to enhance student outcomes in high school.”


3)      Use of Common Graduation Rate for Accountability Purposes – The commonly referred to “NGA Graduation Rate” was created to “ensure transparency, accountability, comparability and, ultimately, to improve our nation’s high schools.” The NGA Compact was not created for “federal accountability purposes.” Governors believe that federalizing the NGA Compact and “attaching high-stake accountability measures” raises several challenges and requires further discussion and clarification.


To view NGA’s full comments, go to


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