October 2024

**Just Equations founder and executive director Pamela Burdman submitted the following public comment to the chairs of the California State Assembly Education Committee and Higher Education Committee in response to their Oct. 10, 2024 hearing on the mathematics requirements for public university admissions.**

**In the letter, Burdman shares concerns that the University of California’s Board of Admissions and Relations with Schools (BOARS) deliberations on the issue were neither transparent nor thorough. The process also lacked participation from K-12 educators and analysis on the impact on student education equity. **

Dear Chairs Fong and Muratsuchi,

I write as the executive director of Just Equations, a California-based policy institute that promotes math education policies that expand, rather than hinder, equitable education outcomes. (I was present at the recent hearing of the Assembly Higher Education and Education committees but had to leave before the public comment period.)

I have been following and writing about math education policies, including the Area C mathematics definition, for more than a decade.

Our organization shares the committee’s concern about the recent BOARS deliberations over Area C. The recent guidance from the University of California Office of the President goes a long way toward providing clarity about current Area C mathematics policies. However, the 15-month process preceding it was not transparent, thorough, consultative, or coherent. Nor was it informed by any analysis of the impact on student access or equity.

For those attempting to understand the process and its implications, the decisions were highly confusing and the reasoning unclear. Furthermore, there was no participation whatsoever of K12 educators in the deliberations. With a better process, a similar conclusion might have been reached absent the confusion and contention.

This statement discusses three concerns with the substance of BOARS’ decisions, and then details issues with the process, including the July 2023 decision, the January 2024 workgroup report, and the June 2024 workgroup report.

**BOARS WORKGROUP DECISIONS **

(1) **Our organization understands the rationale for the decision that non-algebra courses cannot replace (or validate) Algebra II**. There are valid concerns that a student’s sophomore or junior year of high school is too early to rule out an interest in STEM. Taking Algebra II (despite some concerns about the efficacy of the course) keeps that option open. Furthermore, BOARS appears to be applying this position consistently, that is to all non-algebra-intensive courses.

At the same time, we concur with speakers such as Dr. Linda Darling-Hammond and Aly Martinez of Student Achievement Partners—as well as the National Council of Teachers of Mathematics—that** the current Algebra II course is in need of modernization**. We think efforts to ensure all students have exposure to key Algebra II content should incorporate consideration of needed updates to the course, similar to those being implemented in states such as Georgia and Washington.

(2) **We remain concerned about BOARS’ approach to UC’s recommended fourth year of high school math.** In this area, BOARS appears to have exceeded its charge and the requirements of Senate regulation in deciding to create a** hierarchy among fourth-year classes. **The opaque analysis in the Area C Workgroup’s Stage 1 and 2 reports do not justify this decision.

In doing so, BOARS conflated the issue of whether a course validates Algebra II with a course’s academic merit. It inappropriately extends the defensible decision to require students to take an Algebra II (or equivalent) course to an **unjustified expectation that all post-Algebra II courses must build substantially on Algebra II content, which exceeds longstanding practice and creates new uncertainty around courses like statistics, which have long been accepted as fourth-year math courses. **

While Algebra II is a prerequisite for the Calculus sequence and certain other advanced math courses, its content is not required for many other **higher-order **math and quantitative reasoning courses, courses such as introductory statistics. College courses such as this one at UC Berkeley and this one at CalPoly San Luis Obispo don’t significantly rely on advanced algebra or utilize algebraic equations, even though students at those universities took Algebra II in high school. As CSU’s Quantitative Reasoning Task Force concluded in 2016, “to be successful in [undergraduate] Statistics, a student would need to be proficient in most of the K–8 curriculum as well as in several topics from the Algebra 1 or Integrated Math 1 Curriculum.”

Algebra-intensive courses such as calculus and precalculus are appropriate for students who seek to pursue STEM majors. Recommending such courses in order for students to keep their STEM options open is understandable. It is not appropriate guidance for college preparation generally. The BOARS reports (intentionally or unintentionally) inappropriately communicate a **default admissions preference** for such courses. For a student with no STEM aspirations to feel obligated to take a precalculus or calculus course simply to get admitted to college has **no valid academic purpose. **Further, doing so** displaces opportunities** for the student to take a more relevant course such as data science, statistics, discrete mathematics, or mathematical modeling.

It is important for the university to distinguish between guidance for STEM-bound or STEM-potential students and actual admissions criteria. The BOARS reports failed to do this, though recent UCOP guidance provided needed clarification.

(3) **Our greatest concern is that the reports’ narrow focus on the traditional requirements for STEM fields overlook the importance—and rigor—of the statistical and data sciences. Such courses are relevant to students across the university, whether in STEM, social science, humanities, or arts. **Improving calculus preparation and STEM success—particularly for historically excluded student groups—is an important goal, but statistical and data competency are increasingly necessary for success across majors professions, and crucial to thriving in the 21st century. The university and the state ignore this imperative at their peril.

Even CSU’s Quantitative Reasoning Task Force recognized in 2016 that some statistics courses are “significantly more conceptually challenging” than algebra courses, despite being less “algebraically intensive.”

What follows are highlights of our concerns about the **highly irregular** **process** that led to the current confusion about Area C math requirements.

**BOARS AREA C PROCESS CONCERNS**

**BOARS’ July 2023 decision **

- There was no prior notice, including in the agenda, that BOARS was deliberating on such a resolution. Therefore, there was no input on the topic from K-12 educators, course developers, or equity advocates.

- The process seemed extremely rushed—with the resolution apparently being drafted during the course of the meeting, not in advance. Two weeks after its vote, BOARS had to reconvene to clarify its intent (the first time in BOARS’ recorded history it has added a meeting to its calendar).

- While appointing a workgroup to evaluate math requirements, BOARS pre-empted that analysis by determining what they should find about a subset of high school math courses, specifically three data science courses.

- There was no acknowledgment that data science courses were part of an entire category of courses that had been allowed to validate Algebra II (including statistics for at least 10 years as well as courses such as mathematical modeling and financial algebra), and no awareness of the confusion that would be caused by singling out a subset of these courses. For at least 15 months, the status of courses such as statistics, computer science, and discrete math—in addition to data science—has been unclear to California math educators.

- The announcement of BOARS’ premature decision in the press—before any clarifying guidelines could be developed by UCOP or any analysis conducted by the workgroup—caused widespread confusion and left UC officials flatfooted, unable to provide thorough and thoughtful responses to inquiries from K12 educators or journalists. (This resulted in media leaks accusing UC officials of burying the vote.)

**Area C Workgroup Stage 1 report - January 2024**

- Despite having several months to issue the report, the work group did not consult with K-12 math educators, the developers of the courses they were reviewing, or even with experts on K-12 math education among the UC faculty. They also apparently did not conduct an analysis to assess the impact of this decision on access and equity.

- The Stage 1 charge included determining “what types of courses are eligible for the 4th year of Area C coursework,” but the report provides no criteria whatsoever for fourth-year math courses.

- Nevertheless, the report singles out three specific courses (out of thousands approved under Area C), concluding that they do not qualify as recommended fourth-year math courses, with no stated rationale. The sole analysis shows that the courses don’t cover Algebra II, which is the definition for a course that validates Algebra II (not a recommended fourth-year course).

- The report also indicates that AP Statistics does qualify as a recommended fourth-year course—again with no explanation (and no evident analysis). This conclusion was wildly confusing to the field, given that some of courses not deemed “recommended” cover nearly identical content to AP Statistics, as documented in a crosswalk published earlier this year by Data Science 4 Everyone.

- The absence of any rationale for the above decisions made it impossible to know how the group’s unstated criteria would apply to any of the thousands of other previously-approved Area C courses. The lack of stated criteria also made it impossible for course developers to know how to design or redesign their courses to meet requirements.

- The report invokes Academic Senate Regulation 424 to justify rejecting these courses, but that regulation is completely silent about the content of fourth-year math courses. In doing so, it again seems to conflate the requirements for validation with the requirements to qualify as a fourth-year math course.

- One of the courses deemed “not recommended” is offered for undergraduate credit at more than 50 colleges, including two Ivy League schools, four UC campuses, and six CSU campuses. The course developers subsequently communicated with BOARS, noting that the workgroup had failed to review all of their course materials, but no further action was taken.

**Area C Workgroup Stage 2 report - June 2024**

This report repeated many of the problems with the prior report, including the absence of input from K-12 educators.

- As in the prior phase, there was no consultation with K-12 educators or university-based experts on K-12 education.

- The Stage 2 report repeated many of the problems with the prior report, exceeding the work group’s charge and the requirements of Senate regulations to create a hierarchy of fourth-year classes, including Category 4 courses, which it deems “not recommended.”

- While it does provide some criteria for its categories, the distinctions are quite confusing. There is no explanation for placing AP Statistics in a different category than typical data science courses. And no clarification of where regular statistics courses fit.

- The report emphasizes the importance of “abstract mathematical concepts,” “a workout in Algebra II,” and making sure math is visible (rather than hidden behind “computational black boxes,”) but does not explain how these opaque criteria would be used in evaluating future course submissions or defend the educational purposes for these as default admissions requirements for all students.

- While non-algebra-intensive courses are typically not recommended for students pursuing quantitative fields, the analysis conflates preparation for STEM fields with eligibility and competitive eligibility for admission, incorrectly sending the message that preparation for STEM is a condition of admission to the university.

- The status of other existing data science courses is left unresolved. So is the status of previously-approved courses in areas such as computer science and discrete math.

- Creating a hierarchy of courses further creates the incongruous situation that high school math courses are being held to a higher standard than college courses that meet general education math requirements at UC and CSU campuses (notably, data science and statistics courses). As stated above, most of these college-level courses do not require or meaningfully integrate Algebra II.

- This incongruity is further complicated by the fact that the state has set a priority to expand dual enrollment opportunities. Numerous statistics courses (including one of the “not recommended” courses) are offered to high school students via dual enrollment at community colleges. It would be quite weird for courses that give college credit not to be considered recommended fourth-year high school courses for purposes of admission.

Sincerely,

Pamela Burdman

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