October 31st, 2017
Dr. Gayra Ostgaard
Results Measurement Specialist
Minnesota Department of Education
1500 Highway 36 West, Roseville, MN 55113
Re: Minnesota local Chinese American community feedbacks to the Minnesota Department of Education data disaggregation documents
Dear Dr. Ostgaard,
Please accept our sincere appreciation to you for your efforts in organizing a great feedback session at the Minnesota Department of Education (MDE) on October 2nd, 2017. This session provided our community members a great opportunity to voice their concerns and thoughts to you and your colleagues at MDE. Many thanks for your warm welcome, extreme patience, diligent work, sincere professionalism, and continuous encouragement during the three-hour discussion with members from various minority communities!
As briefed during that feedback session, MDE plans to roll out three documents, including a “Sample Parent Letter for Districts”, a “Racial and Ethnic Demographic Designation Form”, and a document titled as “Frequently Asked Questions”, to all Minnesota public schools to collect racial and ethical disaggregation data beyond the current federal requirements. The purpose of these documents is that, in addition to the student categories identified under the most recently reauthorized federal Elementary and Secondary Education Act (ESEA) that Minnesota public school districts are already collecting, MDE will require all Minnesota public schools to collect more detailed subcategories student data set by the 2017 Minnesota Statutes 2017, 120B.35, subdivision 3.
In addition to the feedbacks provided by the local Chinese American community members who attended the feedback meeting, we later engaged more members from the Chinese American communities in Minnesota to review the above-mentioned documents and voice their concerns if there is any.
To our knowledge, the broad Chinese American community in Minnesota has been deeply upset by these MDE documents.
1. It seems that in these documents, MDE misrepresented to Minnesota parents, if not lies on purpose, that the collection of these additional detailed and sensitive disaggregated data under MN 120B.35 Clause Subd.3. (a) (2) is required at both federal and state level. However, the federal governments do NOT require detailed subcategories of each race and ethnicity.
a.A very necessary disclosure to all parents about the optional nature of providingthese additional detailed disaggregated data provided by the law in the “Racialand Ethnic Demographic Designation Form” is not included at all. The 120B.35Clause Subd.3. (h) clearly states that “The school district must inform parentsand guardians that volunteering information on student categories of notrequired by the most recent reauthorization of the Elementary and SecondaryEducation Act is optional”. However, none of the documents provided by MDEindicates that disclosure of additional racial data is optional.
b.The document of “Frequently Asked Questions” by stating “This information willbe reported to the federal government by compiling the categories into thefederally collected racial/ethnic categories as illustrated on the data collectionform for all federal reporting” fails to provide an important clarification that onlyseven racial and ethnic data in the most recent reauthorization of the ESEA isrequired to report to the federal government, NOT additional detaileddisaggregated data collected by MN 120B.35.
c. The use of observation identification for both seven categories required by the federal and the additional detailed disaggregated data required by the MN state is also misrepresented in these documents. For example, “Frequently Asked Questions” states that “If families/students do not fill out the form, districts are required to make a determination based on the best information they have for financial and reporting reasons and to submit the information to MDE”. Also, the “Sample Parent Letter for Districts” states that “an employee of the school district is required to provide the information for your student using the best information they have available”. However, the observer identification is actually ONLY allowed for seven federal categories in the most recent reauthorization of the ESEA. NO observer identification has been allowed for additional subcategories listed in the 2017 Minnesota Statues 120B.35. Moreover, it is practically impossible to accurately distinguish among Asian minorities based on observation.
d.The signature of guardians or parents is missing on the MDE data collection formto confirm a consent from parents to disclose sensitive data about minors.
2.MDE fails to provide necessary options for parents who are unwilling to discloseadditional detailed disaggregated data to ensure any provided data “will not violate theprivacy of students or their families, parents, or guardians” under 120B.35 ClauseSubd.3. (h).
3.Regarding the very sensitive information and privacy nature of these data, MDE cannotdemonstrate to parents how the Department is able to comply with the current federaland state law to ensure a validated security platform to protect the additional detaileddisaggregated data collected by all Minnesota school districts and MDE.
Furthermore, parents from the Chinese American community in Minnesota have been outraged by some underlining messages that these MDE documents will be delivering to all kids and parents in all Minnesota public school districts. Such disturbing messages include:
1.Racial discrimination and racial registry of minority Americans at Minnesota public schools are justifiable;
2.The stereo-type of minority Americans as “foreigners” will be perpetuated in Minnesota;
3.American communities shall be more divided instead of being more united and integrated;
To help you and your colleagues at MDE understand our perspectives and serious thoughts and concerns regarding the implementation of such racial data disaggregation, we included in this letter the following materials collected from our local Chinese American community for your reference.
1.Redlined MDE documents to provide more accurate legal requirements by the law;
2.A summary of concerns expressed by parents who attended the community feedbacksession;
3.A copy of petition with 850+ signatures from local Chinese American communitymembers;
To follow up, we would sincerely appreciate further updates and continuous dialogues/follow-ups with the MDE regarding this matter and related documents.
1.We hereby request to be updated on any newer version of the MDE forms for a furtherreview with our Chinese American community so to make sure mutual agreed languages and clauses to be adopted before their launching to the rollout sites in 2018;
2.We hereby request to be included as a concerned community in the hearing withMinnesota legislative committees having jurisdiction over kindergarten through grade 12 education policy and finance, in which MDE is anticipated to deliver a report by February 1, 2018.
Again, thank you very much for this great opportunity allowing us to voice our deep concerns! We understand you have been working on a task that is tough and challenging. Our community is more than willing to provide any further help and contribute to the development of these MDE documents. Looking forward to hearing from you very soon!
Ling Li, 651-248-0872, [email protected]
Roger Li, 612-481-0392, [email protected]
Wei Qiao, 651-340-5868, [email protected]
Shawn Wang, 612-860-8962, [email protected]
Yongling Gorke, 612-598-3537, [email protected]gmail.com
Zoe Zhi, [email protected]
Chuck Li, 651-600-414, [email protected]
Jeff Jiang, 612-839-8803, [email protected]
Sharlene Dai, 517-285-1366, [email protected]
and friends from the local Chinese American community