Credit Recovery Testimony

Testimony of David C. Bloomfield

Regents Town Hall Hearing on Credit Recovery

February 8, 2012


Honorable Members of the Board of Regents, Commissioner King, guests:  My name is David Bloomfield.  I am Chair of the Department of Childhood, Bilingual, and Special Education at Brooklyn College and serve on the Urban Education doctoral faculty at The City University of New York Graduate Center.  Previously, I was an elected member and President of the Citywide Counsel on High Schools, a parent advisory body to the New York City Department of Education.  I speak today as a private citizen.


In prior work (, I have called the systematized use of credit recovery under Commissioner’s Regulation § 100.5(d)(8) a “Race to the Bottom” since it may be the single most destructive element in New York high school graduates’ widespread lack of college and career readiness.  The Regents rule on credit recovery subverts students’ need for subject mastery and inflates meritless graduation data paraded before the public.


In the short time allotted to me, I want to focus on a particularly egregious element of the Regents rule, that contained in § 100.5(d)(8)(ii) and (iv), which allows the credit recovery program to ignore the full breadth of the failed course and to simply focus on “intensive instruction in the [student’s] deficiency areas,” at (8)(iv).  This loophole within the overall regulatory loophole ignores the reality of course failure.  A student who fails one or more unit exams can still pass a course if they pass other exams and assignments. 


Course failure results from ignorance of basic subject concepts, the whole not the parts.  Allowing credit recovery programs to address deficiencies piecemeal is an adult-created shortcut which is a disservice to struggling students.  In general, this is true of the rest of the process, especially the misuse of online programs encouraged by that most notorious part of § 100.5(d)(8)(iv) optimistically called “digital learning”.  If credit recovery is to exist, and I believe it has its place, the subject should be mastered holistically, such as through summer or night classes, not using a fig leaf to cover administrative embarrassment.          


Thank you again for your time.  It is imperative that the Regents withdraw this damaging, fundamentally flawed credit recovery regulation, and, if necessary, start anew.


Contact: David C. Bloomfield, 718-877-6353,


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