Director of Policy Development
On behalf of the undersigned civil rights, disability rights, and education advocacy organizations, we appreciate the opportunity to respond to the request for information (RFI) regarding the Innovative Assessment Demonstration Authority (IADA) under the Elementary and Secondary Education Act (ESEA). Valid, reliable, and comparable information on student achievement produced each year by statewide assessments is an essential tool for addressing inequities in education, particularly for students of color, students from low-income backgrounds, students learning English, students with disabilities, students experiencing homelessness, and other historically underserved groups. This data is not only useful for families and educators helping students as they recover from disruptions to their learning experience during the pandemic, but also necessary for education leaders charged with targeting state and local resources to the students and schools that need them most.
However, several recent reports have found students, families, educators, and other stakeholders questioning whether current assessments are fully meeting their intended goals and being used effectively to improve educational outcomes and reduce educational inequities. Given these findings, we welcome states’ efforts to innovate and improve their assessment systems – and recognize the important roles IADA and the U.S. Department of Education’s (ED’s) other assessment programs could play. States should be encouraged to develop and use more sophisticated, innovative test designs and items that can measure higher-order thinking skills aligned with the state’s academic standards; to make assessments more instructionally, culturally, and linguistically relevant and ensure they are free of bias; to incorporate Universal Design for Learning principles that make assessments more accessible and inclusive; to develop assessments in students’ native languages; and to provide more timely, relevant results to families and educators.
Thus, our comments address four key ways that IADA could be updated to support state educational agencies (SEAs) in developing and adopting more innovative statewide assessments, as well as how ED could leverage its other assessment activities to enhance these efforts:
Ever since SEAs were invited to apply for IADA, states have been expected to be relatively far along in the test development process to take advantage of its flexibility. Specifically, because of the statutory and regulatory requirements, particularly the fact that an SEA receives flexibility from giving the same assessment to all students upon receiving IADA, the idea has been that the first year of the demonstration period coincides with field testing a state’s new assessment. However, that means there is no dedicated program to support the critical phases of work prior to field testing, including:
Given the importance of these activities, we recommend ED create a planning phase for SEAs seeking to develop innovative assessments. This could be accomplished in multiple ways:
Many SEAs lack the resources and capacity to successfully complete the planning activities noted earlier while continuing to maintain and administer their existing state assessments. States that receive IADA have the benefit of some statutory flexibility, but no additional funding – a significant barrier inhibiting them from developing and using more innovative assessment approaches.
Thus, we encourage ED to work with Congress to provide funds to support the development of innovative statewide assessments by:
We believe all states should be eligible to compete for innovative assessment funds, not just those participating in IADA, as SEAs could adopt the innovative assessment funded by a CGSA statewide without taking advantage of the flexibility in IADA (e.g., by requesting a one-year field test flexibility waiver instead). This would also be an effective, and logical, use of CGSA funding, especially as the statutory priorities already align with innovations in state assessments. Plus, with more funding for CGSA, it would be possible for CGSA funds to support larger, transformative changes to state assessment systems relative to the smaller, more limited CGSA grants of the past. To make participation in IADA more robust and effective, it would also be helpful to have dedicated funding through a mechanism that would enable states to invest in developing, implementing, and scaling their innovative assessments.
To date, and as ED’s RFI recognizes, many states have struggled to meet IADA’s “comparability” requirements in ESEA section 1204(e)(2)(A)(iv) and (x): the innovative assessment system must “generate results that are valid and reliable, and comparable… as compared to the results” on the existing state assessment and must “generate an annual, summative achievement determination, based on the aligned State academic achievement standards” for each participating student.
We believe that much of this challenge may stem from a misinterpretation of the legislative language that should be corrected. The correct interpretation of these provisions is not to require SEAs to produce individual student results on new innovative assessments that are the same as current statewide assessments. Rather, “comparable” should mean the results are “able to be compared.” Specifically, states need to be able to compare student results from both assessments in order to use that data during the demonstration period for several purposes required by Title I, Part A: reporting to parents and educators on individual student progress, reporting to the public on state and local report cards, and identifying and supporting school improvement through its accountability system. The ability to compare the results to use them for these purposes goes beyond simply comparing the quality of the two assessment systems, and ED could issue guidance or a Dear Colleague Letter to clarify this interpretation of “comparable” results.
Indeed, part of the impetus for developing a new assessment may be to more accurately measure deeper learning skills and knowledge that are not well-represented on current tests, and student results have naturally differed from prior tests when states have adopted new assessment systems in the past. But because SEAs may receive flexibility through IADA for five to seven years, the “comparability” provisions are intended to provide an equity guardrail while multiple assessments are in use – helping to maintain clear reporting for parents, educators and the public, fairness for schools in the accountability system, and high expectations for all students’ learning during extended field testing. The goal for “comparability” within IADA should be to ensure transparency, alignment to state academic content standards, and some method for families, educators, and state and local leaders to interpret results between the old and new tests, not to ensure that student results would be the same on both assessments.
Given that, ED cannot, and should not, ignore these statutory provisions. However, the “comparability” requirements could be clarified, including in the following ways:
As noted above, some of IADA’s “comparability” provisions have proven to be a barrier for states, even as the issue of comparing student assessment results statewide during IADA remains a bedrock principle of equity. However, SEAs may be unaware of other approaches to develop innovative state assessments that better suit their needs. Specifically, ED could issue guidance on the multiple pathways states can use to plan, build, pilot, and operationalize a more innovative assessment system. For example:
Further, while the Every Student Succeeds Act (ESSA) maintained most of ESEA’s prior assessment rules, it recognized several innovations states could consider both in IADA and in the assessment requirements in Title I, Part A. Yet, despite these changes, states remain unsure of how to develop an assessment system with these features that would satisfy federal assessment peer review requirements. Specifically:
Thank you again for the opportunity to provide feedback as you consider how to best support innovative approaches to statewide assessments. We appreciate your leadership in calling attention to the value of continuously improving our assessment approaches so that they can be better tools for promoting educational equity and student learning.
Center for American Progress
Education Reform Now
National Center for Learning Disabilities
The Education Trust