In late September, the Ministry of Education released a draft form of a new K–12 Student Reporting Order. Following the release of the draft K–12 Reporting Order, the Ministry invited teachers, parents, and students to share feedback and comments. The Federation appreciates the opportunity to be able to submit feedback on the draft K–12 Reporting Order and supporting documents that are currently available for public response.

The following are some areas of ongoing concern that have been identified by representatives selected from the Federation’s 46,000 members. A number of these concerns have also been previously identified in the feedback from the Reporting Order Pilot Committee and the Ministry Classroom Assessment and Reporting Committee.

General issues and concerns

• The continued use of percentages and letter grades at the 10–12 grade level both invalidates and disrespects the newer K–9 assessment model. Students and parents will have grown accustomed to the proficiency-scale approach to assessment and reporting, which better supports the pedagogy of the revised curriculum. To suddenly shift back to an outdated grades/percentages model in Grades 10–12 creates confusion and takes away the valuable support to students provided by the reporting model at Grades K-9. The previously suggested approach of converting proficiency scale assessments to traditional letter grades and/or percentages was also highly problematic and without pedagogical basis. The new Reporting Order should be designed to meet the needs of students and parents and not the concerns of higher education institutions. Having two separate assessment systems is also challenging for teachers who teach within both grade ranges—e.g., Grade 9 English and Grade 10 English—especially in small rural schools where these courses may be taught within the same combined class.
• It is unclear from the documentation provided if the Summary of Learning is meant to be cumulative or summative. How can a report on student goals be summative? Additionally, a summative report is not in line with how the curriculum is taught as part of a learning journey.
• There needs to be greater clarity about what is required to be reported on five times per year. Do all subject areas need to be reported on in each report, even at the primary level? Do teachers have to report on each individual subject in every informal and formal learning update?
• There continues to be significant concern expressed about the wording attached to the four-point proficiency scale. Teachers report that parents do not always understand what the levels really mean and that the interpretation of the individual terms varies broadly between classes, schools, and districts.
• The draft Reporting Order and supporting documents continue to be based on traditional, colonial reporting structures and contain language that is of a colonial nature.
• There is a disconnect between the draft Reporting Order and the needs of distributed, distance, and blended learning models. These models do not follow regular school calendar timelines, and greater clarity and examples are required on how the order will be implemented in these situations.
• There is no consideration in the draft Reporting Order and the supporting documents to the unique needs of Adult Education.
• Teachers are often directed to keep comments on report cards brief and to the point. The new Reporting Order requirements will increase the length of report cards and provide information that is not necessarily helpful to parents and students. Additionally, for parents who are English language learners (ELL) themselves, longer, more detailed written feedback is not going help them understand their student’s progress.
• Many report cards are never received or viewed by parents, especially at the secondary level. Parents have also clearly provided feedback that they just want to know how their child is doing. The draft Reporting Order encourages inconsistent timing around reporting. Parents have previously provided feedback to teachers and school administration that they do not want random learning updates from teachers and would prefer a regular schedule of reporting.
• There is no mention of social-emotional learning anywhere in the Reporting Order or supporting documents, yet this a large and important part of a student’s education program.
• For Kindergarten and Grade 1 students, it would be difficult to provide meaningful reports on student progress in each subject area after 25% of the year. Most of this period of time is taken to establish relationships, routines, and learning structures with the students, and very little subject content is covered during this first part of the year.
• Do ELL and resource programs need to be reported on for each of the learning updates, including informal updates? This would be a huge increase in workload for non-enrolling teachers, many of whom often work with every student in the school.
• Federation members have raised several concerns regarding the collection and organization of the required student self-assessments and student goal setting items:

• At the primary level, students are mostly unable to do independent goal setting. Goal setting at this level is often done as part of a three-way conference or with the teacher interviewing the student and recording the responses. The requirement to then type these goals up and add them to the learning updates will increase teacher workload and does not meet the definition of “self-assessment.”
• At the secondary level, it is not clear from the documents if the goal-setting process is to occur in every class a student attends—which would create a significant increase in teacher workload—or if it would be done once per student, maybe as part of a student’s homeroom activities, for each learning update.
• Will students be directly uploading the student-generated content? If teachers are expected to collect, track, and data-input the student goal setting and student core competency self-assessments, it is going to lead to a significant increase in teacher workload.
• Student reflection and goal setting are already a part of the life-long learning elements contained in the career education curriculum. Duplication of this process to meet the requirements of the Reporting Order does not make sense and impacts the time that teachers have to work directly with their students.
• The question was raised by Federation members if it is even appropriate to have something as personal as a student’s goals be included in their official student record as part of the official reporting process.

Concerns regarding implementation

• Teachers are currently experiencing high levels of stress and anxiety due to the significant challenges of teaching during the COVID-19 pandemic. While there is a desire to see an updated reporting process, it is essential that the new Reporting Order be completely ready for the field, with all the required supports in place, before implementation begins. It would make more sense to implement it when the system has reached a post-pandemic stabilized state.
• There are significant changes in the Reporting Order requirements, and it will result in a big shift in the way that teachers and schools carry out reporting. While some have been experimenting with elements of this Reporting Order at Grades K–9 as part of the reporting pilot, for most schools in the province, many of the concepts will be new. In addition, the approaches to reporting for Grades 10–12 will be new in all schools. For successful implementation, the ministry and school districts will need to ensure that the appropriate levels of in-service, collaboration time, support, and mentorship are provided to enable teachers and administrators to both understand the changes and to implement them in a uniform manner.
• Federation members have expressed significant concerns about how learning updates will be recorded in MyEducation BC and if the system is even capable of serving the requirements of the proposed Reporting Order. It is essential that any required evidence—such as student goals, core competency self-assessments, and informal learning updates recorded in alternative platforms such as FreshGrade—can be automatically transferred to MyEducation BC. Alternatively, the ministry needs to provide the ability within MyEducation BC to support informal, portfolio-style reporting, student goals, and student self-assessments to support districts and teachers with the informal learning updates and the tracking of these updates. This would eliminate the need for districts to use expensive, alternate, and sometimes problematic, platforms. It would also make reporting more seamless for both teachers and parents.
• It remains unclear how the use of the proficiency scale ties in with a student’s Individual Education Plan (IEP), and the requirements in the still unreleased revised Special Education Manual. If a student is in Grade 5, but working towards Grade 1 learning standards under their IEP, would they be assessed on the proficiency scale for Grade 1 or Grade 5? Will MyEducation BC allow a teacher to put modified IEP goals in for students who are on a modified program? How will students with learning challenges but without a formal IEP fit into this reporting system?
• The five-point Ministry English Language Learning Standards Scale (Beginning, Developing, Expanding, Consolidating, and Bridging) does not integrate well with the four-point proficiency scale.
• There needs to be clarification regarding how many times reporting needs to occur in a non-linear system (e.g., semesters, quarters). Is it four learning updates per semester and the summative at the end of the year? Or is it four learning updates per year, which would mean only two per semester? The current draft policy language is open to multiple interpretations.
• It appears that the ministry is downloading most of the implementation onto school districts and their staff. This approach will lead to a lot of duplication of work and significant variation in reporting across the province. One of the issues identified during the reporting pilot was that every district seemed to have a different interpretation of how to implement the pilot. A successful implementation will require significant support and clear guidance from the ministry.
• Consideration needs to be given to pre-service teachers who will be trained and mentored in the requirements of the new Reporting Order.

   

  Recommendations

• That the implementation of the new K–12 Reporting Order be delayed until it better reflects the feedback from the field and is ready for implementation with all the required supports, including reporting management systems, in place. Consideration should also be given to implementation occurring when the system has reached a more stable post-pandemic state and there is the capacity at the district and school level for a successful implementation.
• That the provincial proficiency scale be used for reporting at all grades, and that there be no requirement for traditional letter grades or percentages in the K–12 system.
• That the ministry provide clear direction and interpretation to school districts to ensure a uniform implementation of the new Reporting Order across the province.
• That the ministry work with educators to make available an extensive collection of reporting exemplars for each grade level, and that they be released to the field well in advance of the implementation of the new Reporting Order.
• That the ministry provide in-service release time for teachers to implement the new reporting order.
• That the ministry consider splitting the Grades K–3 and 4–9 reporting requirements, and that the Grades K–3 requirements reflect the integrated nature of primary-level teaching and the play-based learning employed at that level.
• That the ministry review the draft policy and supporting documents with a truth and reconciliation lens and avoid the use of reporting structures and language that are of a colonial nature. For example, any reference to “student ownership,” which is colonial-style language, should be replaced with the term “student voice.”
• That changes be made to the draft Reporting Order and supporting documents to ensure that the ministry’s stated goal of not increasing teacher workload is met.
• That the needs of the education system’s most vulnerable students are met by the Reporting Order. This includes better integration with IEPs and the ELL standards, as well as recognition of social emotional learning.

While the Federation agrees that a new Reporting Order that better supports the pedagogy of the revised curriculum is urgently needed, it is vitally important that the new order meet the needs of all those involved in the K–12 system before implementation occurs.

The ministry currently has the opportunity to implement a progressive, forward-thinking Reporting Order that supports formative student learning. However, the current draft Reporting Order is still tied to traditional and outdated educational thinking, particularly at Grades 10–12, and it also contains structures and language that do not meet the ministry’s stated goals regarding Truth and Reconciliation.

The Federation looks forward to continued dialogue, both directly and through the Classroom Assessment and Reporting Committee, on the issues raised within this document and those that are identified as part of the public feedback process.