CCCR

Administration Proposals That Could Leave More Children Behind

Several proposals in the President’s plan threaten to leave more children behind rather than expand educational opportunity.

Proposals for Annual Testing

A requirement to test all students every year in grades 3-8 could undermine requirements of current law, and the efforts of many states, to design and implement “standards-based” assessment systems. Current law calls on states to develop standards-based assessments in at least reading and math, to administer them in the grade of their choice at the elementary (3-5), middle (6-8) and high school levels, and to use results for accountability purposes. Specifically, the President’s annual-testing requirement:

Confuses the differences between assessments for school accountability and those designed to measure individual student progress or to diagnose difficulty in mastering the material. The former are provided for in current law. The latter can and should be developed, with state and district assistance, to assist teachers and schools but do not necessitate the annual standardized testing called for in the proposal.

Raises concerns about the potential misuse of these additional tests for high stakes purposes, such as retaining or tracking students or denying diplomas. Concerns have been growing that assessments designed to help students by making school officials responsible for their progress will instead be used only to visit adverse consequences on the students. The new Administration could help allay these concerns if it announced that it will enforce the Office for Civil Rights’ guidance published in December 2000 to protect students against inappropriate test use.

Could lead to widespread adoption and use of commercially produced, norm-referenced tests that do not contribute to academic improvement. “Off the shelf” tests are readily available and relatively inexpensive, whereas good “standards-based” assessments are time-consuming and expensive to develop, administer and score. The commonly-used commercial tests (e.g., SAT-9, CTBS), however, are not properly aligned with state standards, rely almost exclusively on multiple-choice items and do a poor job of measuring higher order thinking and writing skills. Moreover, they are hardly ever aligned with the curriculum unless the curriculum has evolved substantially into “test prep.”[9]

Fails to address the need to ensure that the curriculum is aligned with the standards and that the tests measure what students are taught. Before tests proliferate, steps must be taken to assure that schools receive the professional development, materials and other assistance they need to ensure that the curriculum they deliver prepares students to meet the standards.

Signals a possible retreat from the Department of Education’s commitment to standards-based assessment and accountability. Over the course of the last year, the Clinton Administration required all states, pursuant to the 1994 law, to submit their plans for final Title I assessments to the Department for review and approval. The Department determined whether the states were meeting key requirements in current law (e.g. for alignment of assessments with standards; for technical quality; and for inclusion and appropriate assessment of all students, including those with disabilities, with limited English proficiency and attending charter schools). As of January 19, 2001, the Department had issued decision letters to 34 states. While the Department found that 11 states were in compliance with Title I assessment requirements and safeguards, it also determined, significantly, that 20 states had deficiencies serious enough to warrant only “conditional approval” or to compel them to seek a waiver of the spring 2001 deadline for full compliance. Moreover, three states - California, West Virginia and Wisconsin - were so egregiously out of compliance that the Assistant Secretary determined they would need to enter into compliance agreements with the Department in order to keep federal funds flowing to the states. Among other deficiencies, the Department found that the states’ heavy reliance on norm-referenced tests did not meet Title I’s requirements that assessments be aligned with state standards.

No Child Left Behind, however, is silent on the issue of “alignment” with standards and calls into question the commitment of the new administration to pushing states to continue to develop and improve their standards-based assessments, as Congress envisioned in the 1994 amendments. Similar concerns also apply to safeguards in current law with respect to assessment of LEP and disabled children. (While these requirements were more frequently breached than observed by states, they were a high compliance priority under the Clinton Administration.)[10]

At minimum, the ESEA should not permit the expansion of testing for accountability purposes to additional grades until such tests are aligned with standards, reflect the curriculum actually taught in all schools and ensure that the requirement of inclusiveness and accommodation in current law are maintained.

[9] We recognize that tests like the SAT-9 may have helped some states (like Alabama) and districts (like Philadelphia, which has used an “enhanced” version) launch accountability systems during the Title I “transition period” between 1995 and 2000. We also know that states and districts remain free, at their discretion, to use such tests as one of a number of measures of schools’ performance. But these tests should not assume a prominent role in the standards-based accountability systems called for in the 1994 act.

[10] See Closing the Deal (Citizens’ Commission report on Title I final assessments, released 3-1-01).

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