Regulatory Process

Due to Governor Lombardo’s Executive Order 23008, agencies needed to repeal, streamline, clarify, reduce, or otherwise improve the regulations that were submitted, which the State Board of Education did due to Executive Order 23003. The Department of Ed has started the process of reviewing that regulation and has had its first regulation hearing. Superintendent Ebert reports that it went well, but no comments were provided at that time. They will continue to hold workshops every month until they get through the over 100 pages provided. The Department of Education created a visual guide to help the Board better understand the regulatory process, which you can view here.

CCR Assessment

In 2013, Assembly Bill 288 mandated the selection of a College and Career Readiness Assessment by the State Board of Education. In 2014, the State Board selected the ACT with Writing as the CCR assessment, which was implemented in 2015. In 2017, the CCR became Nevada’s federally reported high school criterion-reference assessment (CRT) for Math and English Language arts. A CRT test is a test or exam that’s designed to see if you meet specific standards or criteria in a particular subject or skill. Instead of comparing you to your classmates, it checks if you’ve reached the level of knowledge or ability that’s expected based on these standards. The Department of Ed formed an evaluation committee to score the different proposals that could have gone to the Board of Education. The proposals were scored based on Project Management, Functional and Technical Requirements, Equity, and Cost. The recommendation from the Evaluation Committee would be to continue forward with the ACT. The State Board of Education voted in favor of continuing with the ACT. You can view the presentation here.

School Start Times – Public Input

During the first public comment section of the meeting, we received many comments from members of the public as well as school officials. The Clark County School District sent two people to give public comment: Patricia Haddad and Luke Puschnig. Patricia Hadid, the Director of Governmental Relations for CCSD, voiced her disdain for the regulation, citing the operational and practical challenges for school districts and families. She stated, “The guardrails that are set forth in the proposed regulation will lead to significant disruptions as they are unfeasible for the daily lives of students and families and will significantly burden district operations.” She also notes that we need to gather input from the communities, but she did not mention that the Board of Education held three workshops across the state to understand local communities’ thoughts on this issue. 

The second individual from CCSD to provide public comment was Luke Puschnig, general counsel for the Clark County School District. The general counsel oversees the legal aspect of any given organization. During his public comment, Mr. Puschnig questioned the state board’s authority to regulate start times, stating, “CCSD will take all steps, including litigation, to prevent any ultra vires decision by the department on this particular issue.” By saying CCSD will pursue litigation, he is indicating that the school district may be prepared to take legal action against the state to prevent the regulation from going through.

In addition to hearing from the Clark County School District during the public comment period, we also heard from the superintendent of Carson City School District, the superintendent of Humboldt County School District, the superintendent of Elko County School District, the deputy superintendent of Washoe County School District, and the Charter School Association of Nevada’s Executive Director, all speaking against the regulation.

In contrast, we heard support from two students, Diego Ramirez and Charlotte Hong, as well as Claudia Mahea, who spoke for the Nevada Psychological Association. Mr. Ramirez and Ms. Hong both go to Silverado High School, which currently starts at 7 a.m. During his public comment, Mr. Ramirez said, “Nationwide, the average school start time is closer to 8 a.m.; this allows students more time to get a healthy amount of sleep, to eat breakfast, and to make it to school on time. A later school start time within CCSD is a very viable solution to many of these issues.”

 I ask every student with an opinion on school start times to either send in a public comment to a board meeting or email me directly at nevstuco.sboeducation@gmail.com. Students are the most important voices in this discussion and, therefore, must be equally heard. In addition to sending in public comments to the State Board of Education meetings, I ask you to send public comments to your local school board meetings as well.

I would like to highlight something said by Member Hughes during the meeting. During our discussions, he said, “When we hear from public comment, which is super important, there is sort of a bifurcation, where we see people who are running systems have a clear opinion, and people who are recipients of this system seem to have a different opinion, and so by-and-large what we’re hearing from families and students is ‘we want a later start time,’ and what we’re hearing from folks who run the system is ‘we don’t want a later start time because that’s too complicated.’” This is very important to remember as we go through this discussion. Even though we may hear a lot of resistance to this through public comment, the people opposed to this have much louder voices than the people who support it. 

School Start Time – Board Discussion

We reviewed the initial draft regulation for later school start times at this meeting, which is available here. Originally, the draft language required 25 percent of high schools to start later, starting in the 24/25 school year. I voiced my concern for this number, as through the data I compiled provided to me by the Department of Education, CCSD, the school district most infamous for early start times, already has about 22.39 percent of high schools starting after 8 a.m. The board mostly decided that 35 percent would be a better starting number. President Ortiz gave the idea of requiring that only 90 percent of the schools in the district must start after 8 a.m. by the end of the gradual implementation plan, but I had concerns with that because the other 10 percent might be the more underfunded schools that need the extra support of a later start time. 

The survey was a big part of the discussion at this meeting, with questions about whether they would need to survey the entire district or individual schools, as well as discussion about the necessity of the survey to be representative of the school population. We all stressed the importance of the survey reflecting the makeup of their student body, but there was concern with districts’ ability to receive accurate and reflective survey data.

President Ortiz ended the discussion, leading into a vote, by saying, “The intent of this is to ensure that our kids are first and foremost in all of our decisions, and as we’ve learned from the research and from the numerous public comments and from folks that have actually come in person and commented as well, this makes a humongous difference in the lives of our children. It will ensure not only their safety but their mental health, and it will provide options not only for our students but for some of our teachers who are not ready and willing to work at 7 a.m. in the morning.” The board unanimously agreed to forward the language we had discussed back to the Legislative Counsel Bureau to make the appropriate changes to the regulation language. The revised regulation can be found here, which we will be discussing at our October 4th meeting.

Teacher Licensing and Pipeline Presentation

The Board of Education received a presentation on teacher licensing and the new teacher pipeline. The Department of Education has many programs for teacher recruitment and retention, such as the Teach Nevada Scholarship. They highlight the Department’s Licensure operations, which serve 59,860 licensed professionals. In 2014, their average response time for a license was 16 weeks, and that has dropped to 12 calendar days currently. They also addressed the Teaching and Training CTE program and the timeline from completion of that program to teaching in Nevada. In the 22-23 school year, 45 schools in 8 districts plus the state charter school authority had enrollment in at least one Teaching and Training CTE program.

AB 428 passed in the last legislative session and is Nevada’s Teacher Academy College Pathway. There are three goals related to this piece of legislation. The first is to create a “Grow your own” program, which allows a seamless pipeline that goes from high school all the way to the workforce. The second is to remove barriers to becoming a teacher, allowing students to graduate and enter the profession with no debt. The third is to provide wraparound services and support throughout. This can start in middle school and continue through high school and higher education, where once they start working in a Nevada school as a teacher, they can get a third of their tuition reimbursed for every year they work in a Nevada school. You can view the entire presentation here.

If you have any personal experience with school start times, I strongly encourage you to send in a public comment to the Board of Education by emailing NVBoardEd@doe.nv.gov  to be read into the record at our next board meeting. 

You can find the entire meeting materials HERE. You can also watch a full recording of the meeting HERE. The next meeting will be held on October 4th at 2 p.m.