On October 24, 2016, the Office of Head Start (“OHS”) launched the CLASS section of the FY17 Aligned Monitoring Virtual Expo. This launch includes the “FY2017 CLASS Field Guide,” “FY2017 CLASS Review At-A-Glance,” and “Preparing for your CLASS Review Event.” According to a letter from the Director of OHS, Dr. Blanca Enriquez, CLASS is one of three monitoring events that will continue this fiscal year.

CLASS, which stands for Classroom Assessment Scoring System is an observational tool developed to evaluate teacher performance.  This review event has high stakes since low CLASS scores can have a devastating impact. Under regulation, low CLASS scores can trigger recompetition:

(1) if CLASS scores are below certain “minimum thresholds” (4 for Emotional Support, 3 for Classroom Organization and 2 for Instructional Support) or

(2) if CLASS scores are among the lowest ten percent of all Head Start programs.

Since OHS’s implementation of the Designated Renewal System (DRS), the use of CLASS scores to trigger recompetition has become increasingly controversial. The National Head Start Association, among others, is calling on Congress to prohibit OHS from requiring recompetition when CLASS scores are among the lowest ten percent.  The calls have not been ignored.  In July, a bipartisan group of 19 Senators sent a letter  to urge OHS to “reform the Head Start Designation Renewal System (“DRS”) by immediately suspending the use of the lowest 10 percent of the Classroom Assessment Scoring System (CLASS) trigger.”

In their letter, the Senators expressed concern that the lowest ten percent CLASS trigger “does not accurately identify poor performance in Head Start programs and as a result does not meet the intent or letter of the Head Start Act.”  In support of this concern, the Senators made three arguments based on the statutory language:

  • First, in order to determine whether a grantee’s CLASS scores are among the lowest ten percent, OHS compares the grantee’s scores to scores from other CLASS observations that were conducted in the same fiscal year. As a result, the cutoff varies from year to year and programs must “aim for an unknown and moving target.”  Using this moving target to trigger recompetition is incompatible with OHS’s mandate to ensure that DRS is “transparent, reliable and valid.”
  • Second, grantees often do not find out if their CLASS scores are among the lowest ten percent until the fiscal year following the year in which the CLASS observation was conducted. This delay violates the Head Start Act’s requirement that DRS be “applied in a manner that renews designations, in a timely manner.”
  • Third, the Senators noted that “83 percent of the 140 programs who are in DRS solely for being in the bottom 10 percent of CLASS have won their grants back entirely.” Based on this evidence, the Senators questioned whether the lowest ten percent trigger truly identified low-performing programs.

The Senators aren’t the only ones to question whether CLASS scores are a reliable measure of program performance.  This post on the blog of Teachstone, an entity founded by developers of the CLASS tool, admits that the reliability of CLASS is dependent on proper training of the observers.  The author recommends that observers participate in a special kind of training, called calibration, where observers “code a sample classroom and receive feedback on their codes from a Teachstone master coder.”  The author specifically recommends that “[f]or individuals who conduct frequent observations, typically for accountability or research, calibration is recommended every 2–4 weeks or every 10–15 live observations.”  In the FY2016 CLASS Field Guide and the recently issued FY 2017 guide, OHS notes that CLASS observers receive certification and training only once per year.

The Department of Health and Human Services’ (“HHS”) response to the Senators shows some promise, but it is unlikely that Head Start programs currently facing recompetition will see any relief. HHS writes that it cannot waive the lowest ten percent trigger because the trigger is codified in the regulations.  But HHS’s response is unsatisfying.  Regulations that violate a statute (as the Senators note this one does) are invalid.  Further, OHS could postpone CLASS reviews, just as it has done with other monitoring events for Fiscal Year 2017.

Stay tuned.  The controversy over CLASS scores and DRS is shaping up to be a showdown with significant impacts on Head Start programs nationwide.  If your program is facing recompetition due to low CLASS scores, contact us to learn more about your options.