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Your Guide to Comments on the Draft ESSA Testing Rules

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How exactly will testing work under the new Every Student Succeeds Act? Earlier this summer, the U.S. Department of Education released its proposed regulations for both testing in general and the "innovative" assessment pilot under the new law.

The official "comment period" ended Friday, and more than 100 educators, parents, and advocates took the opportunity to offer comments or thoughts. The department is supposed to take these comments into consideration and respond to them before releasing its final regulations this fall, likely in November.

In all, there were more than 30 comments on the law's "innovative assessments" pilot, and more than 70 on assessments. That might sound like a lot, but it's a drop in the bucket compared to the 20,000 comments on the proposed accountability regulations.

We're digging through the testing comments so that you don't have to. Here's a sampling of what we've read so far: 

Assessments:

Background: These draft regulations deal with a host of testing issues, such as computer-adaptive testing, testing for English-language learners and students in special education, and subbing out a nationally recognized test, like the SAT or ACT, for the state test at the high school level. (Your cheat sheet here.) 

The proposed regulations were written by a group of advocates through a process known as negotiated rulemaking. That means groups like the Council of Chief State School Officers, the National Education Association, and the Leadership Conference on Civil and Human Rights have already had their say, since, you know, they helped write these. 

Sample comments:

Virginia Department of Education: One of the biggest sticking points in negotiating these rules was on how alternative tests for students with the most severe cognitive disabilities should work. ESSA says that states can only offer these tests to 1 percent of their students, but the law also allows for states to get a waiver from this provision. The proposed regulations put a lot of really strict parameters around these waivers, making it tough for a state to get one.

Steven Staples, Virginia's state chief, clearly thinks that the draft regulations go overboard. He thinks states should be granted waivers for more than a year or two and that the timeline for applying for one is "problematic." And he wants language calling for states to make "substantial progress" in cutting down on the number of students who take alternative tests removed, because it is not tightly defined in the draft and could be interpreted a bunch of different ways.

School Social Work Association of America: The group called the draft regulations "generally solid," but offered a couple of new twists, including making it clear that all school staff should get training on how to help students in special education and English langauge learners deal with testing. The SSWAA also would like to see test results broken down by gender, in addition to the traditional set of "subgroups."

National PTA: The group wrote in saying it was largely supportive of the recommendations, but suggested a few tweaks, such as requiring information about tests to be translated into the second-most-popular language in the state, other than English. That shouldn't be a huge burden for states, the PTA argues because it mirrors a requirement in the proposed regulations saying that there should be alternative tests available for recently arrived ELLs in whatever is the second-most-popular language in the state.

National Down Syndrome Congress: Overall, the group is a fan of the recommendations. It wrote in to ask the department to hold onto certain provisions, including the requirement that any nationally recognized test that's used with high school students in place of a state exam be made accessible for students in special education. The advocacy group also wants to see the department put out much-more specific guidance on how states should define "severe cognitive disabilities" and what tests for children who have them should look like. A number of parents whose children have Down syndrome seconded the recommendations. 

ACTThe testing company wrote in with a recommendation on how the proposed regulations handle tests for accommodations for students in special education and English-language learners in cases where districts decide to use a nationally recognized college entrance or placement test instead of the state exam. ACT is worried that these accommodations might make the tests harder to use for college entrance. So it wants to make sure any accommodations preserve the validity, predictability, and reliability of the tests.

AASA, the School Superintendents Association: The organization is worried that it will be too difficult for states and districts to get a waiver from the 1 percent cap on tests for students with the most severe cognitive disabilities. And AASA is concerned that accommodations for students in special education will wind up on districts' plates. 

Innovative testing pilot

Background: These draft regulations, which were not part of the negotiated rulemaking, deal with a part of the law that allows up to seven states—and ESSA_button.jpgpotentially, eventually, all states—to try out a new form of testing in a small group of districts with the goal of eventually taking it statewide. (New Hampshire got the chance to try something like this under the previous version of the law, No Child Left Behind.) Cheat sheet on the program here, and on the proposed regulations here.

Sample comments:

Council of Chief State School Officers: CCSSO said it liked the regulations overall, but had some suggestions. For one thing, the organization would like to give states more time to develop their new testing systems before they have to be used for accountability purposes. It suggested a two-step approval process, where states can be given a conditional green light to go ahead and build their systems, with final approval when they are ready to use them for accountability. CCSSO also suggested the department give states some flexibility when it comes to proving that these new local assessments are comparable to the state test.

American Federation of TeachersThe union started with a long preamble on the merits of a system of local assessments currently used in New York state, the New York Performance Standards Consortium. It says that, in general, the regulations should make it possible to support systems like this. (AFT doesn't mention this specifically, but some assessment experts have said it might be tough for a state as populous as New York to have a system of local tests that could go statewide because of all the potential technical challenges.) AFT is also worried that the department's criteria for proving tests are comparable across the state is too restrictive. And it worries that the requirement for scaling an assessment statewide might make it hard for states to put a system of locally designed tests in place.

Foundation for Excellence in Education: Overall, this organization, which was started by former GOP Florida Gov. Jeb Bush, was supportive of the proposal. It did suggest a few additional tweaks, including one related to when a state can get extra time to use the innovative assessments in just a few districts rather than statewide. It wants the department to make sure districts that aren't prepared to try out the new tests yet are getting ready to do so before the department grants the whole state more time with the pilot.

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