January 26, 2017
Dear Oklahoma Lawmaker,
As the executive director of the Oklahoma Private School Accreditation Commission (OPSAC), which represents the 12 approved private school accrediting agencies that accredit approximately 140 private schools in Oklahoma, I write to make you aware of proposed legislation this session being introduced in the name of “accountability.”
There are various pieces of legislation aiming to require certain private schools to participate in the Oklahoma School Testing Program, to adopt the A-F report card system, and to publish reports containing information about services provided to disabled students, to cite just a few examples. Specifically, the requirements are meant to apply to schools which participate in some of Oklahoma’s school choice programs.
Like most Oklahomans, our private school leaders agree that private schools should be held accountable. The question is to whom they should be held accountable. Fortunately, the schools I represent are already very much accountable—to parents. We administer standardized tests, of course. But we’ve found that test scores aren’t the only factor—and often not even the main factor—parents are concerned about. We have to satisfy our customers (parents) when it comes to school safety, curriculum, school culture, instruction in moral values, and much more. If we fall short, parents can and do vote with their feet—and their checkbooks. This, of course, is the ultimate form of accountability.
Having said that, it’s not as though our schools are not also accountable to state and federal governmental entities. They are. Our schools comply with numerous governmental requirements, including health and safety regulations, anti-discrimination and civil rights laws, rules concerning the minimum number of school days/instructional hours, applicable wage and hour laws, IRS and other tax regulations, and more.
Moreover, Oklahoma has established OPSAC to provide additional accountability and oversight of Oklahoma private schools that are accredited. OPSAC works in collaboration with and on behalf of the Oklahoma SDE to ensure that accreditation standards for private schools are equivalent to accreditation standards for Oklahoma public schools. Accredited private schools in the state must attain and evidence continued compliance with requirements that address areas related to educational quality and school operations and practices (including curriculum and the instructional programs), administrative and teacher qualifications, course offerings and graduation requirements, assessment, financial management and integrity, resource sufficiency, governance and organization structures, and more.
We recognize that because public schools are directly accountable to government agencies—and lack the direct accountability to parents that our schools are known for—your job as elected officials is to try to craft rules and regulations which can approximate this true accountability as best as possible. We respect that. But we would suggest that it is unnecessary for you to regulate markets the same way you regulate these public school monopolies. Heritage Foundation scholar Lindsey Burke has noted, “There is no compelling body of evidence that top-down regulation improves student outcomes in schools that are already directly accountable to parents. By contrast, there is much evidence that direct accountability to parents yields results superior to those that are defined by bureaucratic red tape.”
Placing extra strictures on our schools would require schools to redirect valuable time and resources that would otherwise be used in direct support of children’s education. We believe that the placement of these burdens is a solution in search of a problem and we respectfully urge you not to do so.
Donald Peal, Ed.D.
Oklahoma Private School Accreditation Commission