NYSEDs “Public Comment” Slight of Hand

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According to Merriam Webster Dictionary,  SLEIGHT OF HAND is defined as:

a : a cleverly executed trick or deception
b : a conjuring trick requiring manual dexterity
a : skill and dexterity in conjuring tricks
b : adroitness in deception

It has come to my attention, that NYSED engages in slight of hand regarding requirements that direct NYSED to post info for public comment. Let me explain.

Earlier this year, it had come to my attention that NYSEDs present ESEA renewal application contains amendments that  several key organizations to issue an objection to. I blogged about that here: http://wp.me/p44iDJ-x7

One of the prevailng themes surrounding the objections, was NYSEDs lack of transparency and failure to provide sufficient notice to advocacy organizations and/or the public for sufficient opportunity to comment on the proposed Amendments before the Regents voted on the Amendment.

Well, NYSED is up to their old tricks again.

Most recent case in point right here!

Below is a screenshot of NYSEDs ESEA memo page which I snapped at 2:56 am on 5/7/14 regarding its redlined ESEA Flex Waiver. The page is located at:

http://www.p12.nysed.gov/accountability/ESEAMemos.html

As you can see, there is a highlighted entry that claims its “NEW”. But, as you can also see, the date is incorrect, its says April 2013. Apparently, someone at NYSED is not college and career ready because to my knowledge it is no longer 2013, it is now 2014 last time I checked my calendar that is. Anyone perusing the website may read that date and figure its outdated info from last year. But, I digress.

Now, scroll to the far bottom right of the screenshot – it is date stamped April 15, 2014. See that?

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Here we go.

NYSED issued a memo seeking “public comment” by way of a memo directed to LEAs: Subject: Requesting comments on New York’s request for an extension for the 2014-15 school year of New York’s ESEA flexibility waiver 

According to NYSED, “USDE has now asked New York to post for public notification and to allow LEAs to comment on this redlined version of its waiver extension request.”

The memo is dated elusively April 2014, but no “day” is provided to specify when the letter was written.

In it closing statement, NYSED specifies that public may comment no later than April 22, 2014.

Going by the date stamp on the webpage, April 15, 2014, this would give advocacy organizations and/or the public roughly 5 business days to provide input and comment on the redlined ESEA Flex waiver.

Is providing the public 5 days to comment really a good faith effort to obtain feedback as to the proposed policy change? Add in the ridiculous wrong date on the website and you have to wonder how the public would know about this at all.

This is nothing new. I have encountered complaints of this nature before by public and advocacy groups.  This is just one example of many.

Slight of hand? You decide.

Here is the memo:

 

April 2014

To: Superintendents of Public Schools and Coordinators of Title I Programs

From: Ira Schwartz

Subject: Requesting comments on New York’s request for an extension for the 2014-15
school year of New York’s ESEA flexibility waiver

“On February 28, 2014 the New York State Education Department (NYSED), on behalf of the
Board of Regents, submitted to the United States Department of Education (USDE) New York’s
request for an extension for the 2014-15 school year of New York’s ESEA flexibility waiver.
Included in the extension request was information regarding how the State notified the public
and provided local educational agencies (LEAs) the opportunity to comment on six proposed
amendments to the State’s approved ESEA flexibility waiver. In addition, the extension request
included a variety of redlined edits, ranging from updates to ongoing activities to grammatical
line edits. As part of the review process, the USDE has asked States that had made any changes
to their approved ESEA waiver to submit a redlined version of their approved waiver reflecting
any updates or proposed changes to the waiver. USDE has now asked New York to post for
public notification and to allow LEAs to comment on this redlined version of its waiver
extension request. In response to USDE’s request, a copy of New York’s February 28, 2014
redlined ESEA waiver submission to Secretary Arne Duncan has been posted at
http://www.p12.nysed.gov/accountability/T1/docs/ESEAFlexibilityredline021814530pm.docx .

Comments on this document may be submitted via email, fax, or mail (post marked) no later than
April 22, 2014 to:

Roberto Reyes, State Director
Title I School and Community Services
Room 365 EBA
New York State Education Department
Washington Avenue
Albany, NY 12234
Fax: (518) 486-1762
T1WAIVERS@MAIL.NYSED.GOV
e thank you for your support and look forward to hearing from you.”

http://www.p12.nysed.gov/accountability/T1/fieldmemos/fmrequestforextensionwaiver.pdf

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