April 18, 2025
Katherine Craven, Chair
Massachusetts Board of Elementary and Secondary Education
135 Santilli Highway
Everett, MA 02149
 |
| Letter from MAVA Officers to the BOE re: Admissions |
Sent via mail: BoardofEducation@mass.gov
Also sent to: CCTE@mass.gov
Dear Chair Craven and Members of the Board:
On April 10, 2025, in our capacity as MAVA officers, we received a link from DESE to newly posted information on the Department’s website. The updated DESE website outlines how the Department determines compliance with “rules” on vocational admissions. This information was provided as a result of repeated requests by vocational superintendents and MAVA Officers.
DESE’s updated website now includes a new section titled “Career Technical Education Methods of Administration for secondary career technical education (CTE) student eligibility, recruitment, and admission.” It provides an overview of the Methods of Administration (MOA) process and outlines the Department’s process for Disproportionality Analysis.
Presumably, this is the process DESE has adopted to comply with its federally-approved Massachusetts Targeting Plan. Recently, MAVA counsel requested copies of federally-approved plans. While there may be some variation between the documents received by MAVA and the information posted on the DESE website, it is assumed the Disproportionality Analysis posted is based on the most recently federally-approved plan. An excerpt from the aforementioned website is copied below.
Disproportionality AnalysisTo determine if districts are enrolling particular demographic groups (Students of Color, Students with Disabilities, and English Learners) at disproportionate rates, we calculate the difference between the attending 9th grade students at that district and the comparison index for that district. The comparison index is what we would expect the 9th grade enrollment to be at the CTE district, using data from the region and adjusting for grades served, size of the district, and variability.
When the difference between the attending 9th grade students and comparison index is negative, it indicates a 99% confidence level that the enrollment is under-representative of that district's region.
The Department reviews at least two years of data and flags potential disproportionate student populations where:
1. The district has differences of less than 0 for all three demographic groups2. The district has a difference of less than -5 for one (or more) demographic groups3. The district has two demographic groups with differences both less than -2.5
To the best of our knowledge, this is the first time since the initial publication of vocational admissions data in 2020 – that is, five years – that vocational schools and the public have been given information on DESE’s process for identifying schools to review. While this recent clarification is helpful, it is important to note MAVA continues to have serious concerns about the overall integrity of the data on which this analysis is based.1
It is also very important to note what is NOT part of the Disproportionality Analysis – there is no mention of admission “offers” or “acceptances,” or “offer rates” – data repeatedly used by lottery proponents to justify moving to a statewide, one-size-fits-all lottery system.2 Instead, the federally-approved DESE “rules” use a Comparison Index that compares the demographics in the applicant pool to the demographics in the school.
Out of deep curiosity, we ran the analysis posted on the website for Nashoba Valley Technical High School, Essex North Shore Agricultural and Technical School, Old Colony Regional Vocational Technical School, Tri-County Regional Vocational Technical High School, and Pathfinder Regional Vocational Technical School District, the schools we represent. This exercise verified what we already suspected: None of our schools have issues with disproportionality among students from protected classes (See Appendix A). We comply with the rules.
It is assumed that this methodology is employed for data review in all 29 regional vocational schools. It is our understanding this analysis is what led to only ONE regional vocational school, Greater New Bedford Regional Vocational Technical High School, being selected for a Methods of Administration (MOA) review. It is also our understanding that only THREE other schools3 have been identified for potential technical assistance.
With this new information now shared for the very first time with the public (and simultaneously with vocational schools) we are left with unanswered questions:
● Why was this disproportionality analysis never discussed during any of the five BESE Board and subcommittee meetings held to study the vocational admissions process?4
● If this is the process DESE is using to flag only 4 CTE schools, why would any of our five schools – and likely most of the 20 other vocational schools – be required to turn our admissions systems upside down when DESE’s federally-approved guidelines demonstrate that we are in compliance? Our school committees and the taxpayers and voters in our member communities will be expecting us to answer that question. Based on what we have just learned, we have no reasonable explanation for them.
In light of this, we urge you not to adopt any revisions to the regulations related to vocational admissions. Instead, allow this entire issue – including our concerns about the accuracy and adequacy of the data – to be reviewed dispassionately, objectively, and thoroughly by the 15-member Vocational Admissions Task Force already included in Outside Sections 65 and 68 of the House Ways & Means Committee-endorsed version of the FY 2026 state budget.
The Task Force would carefully examine admissions policies, data collection practices, and enforcement standards to ensure that vocational schools and programs continue to serve our communities effectively and equitably.
We support creation of the Task Force for several specific reasons:
● The diverse composition of the task force, which includes legislative leadership, education administrators, and key stakeholders from various organizations involved in vocational-technical education.
● The clear timeline established for the task force, with a start date of September 15, 2025, and a required report by September 15, 2026.
● The requirement for at least one public hearing, ensuring community voices are heard in this important process.
● The prudent pause on regulatory changes, which prevents premature adjustments to admissions policies before the task force completes its thorough review.
And while this Task Force may add more time to the process, it is critically important that we get these policy changes right due to the direct impact on students. In the meantime, DESE already has authority under current regulations to move districts to admissions lotteries using its recently published disproportionality rules, so there are still compliance measures in place while the Task Force does its work.
Vocational-technical education provides vital pathways to career success for many students. By supporting this comprehensive review through the proposed task force, we can ensure these programs continue to evolve in ways that best serve all students while meeting our state's workforce needs.
In closing, these draft regulations are a solution in search of a problem. They are not needed because this is not a statewide problem. The Board should not vote on this issue until an admissions task force has reviewed the matter more thoroughly. In fact, as a good first step and as a signal that the Board of Elementary and Secondary Education truly wants to do what’s right, the Board could endorse the creation of the Task Force and await its findings and recommendations.
If you have any questions, please contact us. Thank you for your consideration.
Respectfully,
Denise Pigeon Heidi T. Riccio Aaron Polansky Karen Maguire Eric Duda
1See MAVA’s 5-page letter dated November 22, 2024, to BESE Chair Katherine Craven identifying a host of problems related to state data and its presentation to the public.
2This same “offers” and “acceptances” data is also publicly posted on DESE’s website, causing widespread confusion and misunderstandings between advocates, policymakers, and even the media. See: CTE Admissions and Waitlist tool Also see: Letter to BESE from Denise Pigeon dated 12.10.24
3Greater Lowell Technical High School, Montachusett Regional Vocational Technical School, and Bay Path
Regional Vocational Technical High School (Southern Worcester)
4 October 28, 2024 Special Board
Meeting on CTE; November 15, 2024 Special Board
Meeting on CTE; November
26, 2024 Career and Technical Education Study Committee; December 16, 2024
Career and Technical Education Study Committee; January 27, 2025 Career and
Technical Education Study Committee
For the full letter including the mentioned Apendix A
