US Department of Education Seeking Public Comments on Approaches to Innovative Assessment Pilot

Information will be used to inform implementation of the Innovative Assessment Demonstration Authority (IADA)

The US Department of Education is requesting information on successful approaches to innovative assessment implementation that can encourage state educational agencies (SEAs) to pursue the Innovative Assessment Demonstration Authority (IADA) and improve statewide assessment. The Department will use this information to inform their implementation of IADA, under Title I, Part B of the Every Student Succeeds Act (ESEA).

Specifically, the Department is inviting stakeholders who are aware of policies and practices in educational assessment relevant for innovation to address the following questions:

1. The Department is interested in whether there are additional considerations or approaches to comparability, whether through changes to current IADA regulations or additional guidance (for elaborating on the “other method” in section 200.105(b)(4)(i)(E)), for the innovative assessment.

   a. Are there other methodologies that could be used as models to provide comparable results to current statewide assessments without compromising the innovative nature of the new assessments?
   b. Are there ways that a State could plan for an orderly transition from using the achievement standards for the current statewide assessments to achievement standards for the innovative assessment as it scales to statewide use?
   c. We note that ESEA section 1204(e)(2)(A)(iv) states that the IADA “generate results that are valid and reliable, and comparable, for all students and for each subgroup of students described in section 1111(b)(2)(B)(xi), as compared to the results for such students on the State assessments under section 1111(b)(2);” and ESEA section 1204(e)(2)(A)(x) states that the IADA “generate an annual, summative achievement determination, based on the aligned State academic achievement standards under section 1111(b)(1) and based on annual data, for each individual student.” Within these statutory requirements, are there other issues with respect to comparability that the Department should clarify, either in regulation or guidance to help states meet this requirement? Please be specific in: (a) describing the issue; (b) identifying the proposed change to address the issue; and (c) identifying how the change will lead to a State being more likely to apply for IADA.

2. Current IADA regulations do not specify a timeline by which a State approved under IADA must administer an operational IADA assessment in some schools or LEAs.

   a. Would a State be more likely to submit an IADA application if the Department explicitly provided one or two planning years, after the granting of IADA authority, before the State first administers an operational IADA assessment in some schools or LEAs?
   b. Noting that the State would need to have enough detail about its plan for the Department to grant IADA approval or pre-approval, please describe the benefit to the State that would be provided with one or two years of planning time as well as suggestions for the types of activities the State would undertake during the planning time?

3. Please describe any other barriers in the Department’s regulations that might preclude a State from applying for IADA. Please be specific in: (a) identifying the regulatory provision; (b) describing the issue; (c) identifying the proposed change to address the issue; and (d) identifying how the change will lead to a State being more likely to apply for IADA.
   

In providing feedback, commenters are encouraged to cite published research on promising practices and methodologies for innovative assessment design and implementation.

The Aurora Institute will be submitting comments. We encourage you to submit comments, including on the assumptions in the framing of these questions, and provide your detailed feedback to the US Department of Education. Please submit your comments using the USED website by May 1, 2023 at 11:59 pm EDT.