February 11, 2013
Dear Members of the Colorado State Board of Education,
Once again, please accept our sincere appreciation for the hard work that the Department of Education has put into the rules-writing process for the administration of the Colorado READ Act (HB 12-1238). As members of a broad coalition of parents, educators, civic, and business leaders who supported the READ Act from its inception, we remain attentive to the critical role that the rules you adopt will play in the success of the vision behind the statute. We thank you and the department for your continued work on the thoughtful implementation of this legislation.
We write today to express our ardent support of the updated draft rules. We had previously expressed concern over several items in the initial iteration of the rules and are heartened to see that these concerns have been addressed in the most recent draft. We would like to draw your attention to several aspects of the draft rules that we believe are essential for the implementation of the law as it was originally envisioned:
Determination of a Significant Reading Deficiency (3.00) and Upon Determination of a Significant Reading Deficiency (4.00)
In the previous draft rules, there was a three-step approach that created a threshold that was unnecessarily high, unclear, and would have led to a loss of time for a child to receive interventions. The intent of the Colorado READ Act is for struggling readers to be identified early so that they will receive immediate reading interventions and support. The critical importance of early literacy, and the severe consequences of delayed action, led to the concern that under the previous draft rules students who needed interventions outlined in a READ Plan would not receive them until much later in the school year. The current rules are far clearer about both the identification of a significant reading deficiency and the appropriate steps to be taken to intervene appropriately to support a child’s particular needs.
By targeting any student who twice falls below the cut score on an assessment, schools, districts, and parents can be assured that there is likely an unmet issue with the child’s literacy ability. By requiring both of those assessments to occur within the first thirty days of enrollment, we will avoid delaying the interventions until later in the school year when a child will have struggled and could have received appropriate support at school and at home, as outlined in a READ Plan. It is our understanding that the interim assessments that will be used to screen children for reading deficiencies are not overly time-consuming (two or so minutes per child) and can provide teachers with the data they need to develop appropriate plans for supporting a child based on his or her particular needs.
If we wait to accumulate a body of evidence prior to placing a child on a READ Plan, we risk losing the early interventions that can remedy the specific needs a child has before a reading difficulty worsens. In the crafting of the legislation, the sponsors were clear that READ Plans are not punitive tools to be avoided, but rather a collaborative vision for how parent, teacher, and school can ensure a child with significant difficulties can get the early intervention he or she needs. While the decision over third grade retention may require a body of evidence to determine if advancement to fourth grade is a decision in the best interest of the child, determining if he or she needs extra support at home or in school through a READ Plan should occur at the first signs of a significant reading difficulty. There may be some who worry that we will place too many students on READ Plans. In our view, these plans are tools to support children who have demonstrated significant reading deficiencies and ones that keep parents informed about their child’s success in school. As such, we would prefer more students to receive such support rather than err on the side of failing to provide such interventions when a child needs them.
We see the changes made to these sections as the most significant improvement in the updating of the rules and essential to actually changing the culture of literacy in the early grades. Without an early intervention process that quickly responds at the first signs of difficulty with dramatic interventions, we worry that we will not see any differences from how we currently handle literacy instruction under the Colorado Basic Literacy Act. The quick diagnosis, targeted interventions, and progress monitoring required under a READ Plan represents a fundamental shift away from the Individualized Literacy Plans that failed to make substantial changes in children’s early literacy success.
Attributes of Effective Universal Instruction (Section 6.00) and Attributes of Effective Instruction and Intensive Instructional Intervention (Section 7.00)
Maintaining the inclusion of these guidelines is, in our view, essential guidance for districts who are working to meet the needs of all students in the acquisition of literacy skills. One of our highest priorities in supporting the READ Act was to shift the culture of early literacy in our state to one that provided all students with excellent Tier 1 instruction and provided the very best interventions for those students who struggled. By including the research-based attributes of effective universal instruction and intervention, the state is able to provide meaningful guidance for schools and districts. Including these attributes does not impose a mandate on schools or districts regarding their early literacy programming for all students or struggling readers. Rather, the rules provide the essential guidance that we had hoped schools and districts would receive regarding the first and best early literacy instruction. We strongly support the inclusion of this guidance.
We encourage you to maintain these sections as they are in the most recent iteration of the rules as they represent a substantial shift toward early identification, intervention, and support. We thank you again for your efforts to see this piece of legislation implemented well and sincerely appreciate the opportunity to share with you our support for the current draft rules.
Sincerely,
Scott Laband – President, Colorado Succeeds
Sonja Semion – Interim Executive Director, Stand for Children Colorado
Chris Watney – President and CEO, Colorado Children’s Campaign
Kelly Brough – President and CEO, Denver Metro Chamber of Commerce
Tamra Ward – President and CEO, Colorado Concern