{"id":2032,"date":"2016-09-19T00:00:00","date_gmt":"2016-09-19T04:00:00","guid":{"rendered":"http:\/\/aurora-institute.org\/blog\/inacol-and-knowledgeworks-submit-public-comments-on-innovative-assessment-pilot-under-essa\/"},"modified":"2019-12-16T12:55:11","modified_gmt":"2019-12-16T17:55:11","slug":"inacol-and-knowledgeworks-submit-public-comments-on-innovative-assessment-pilot-under-essa","status":"publish","type":"post","link":"https:\/\/aurora-institute.org\/blog\/inacol-and-knowledgeworks-submit-public-comments-on-innovative-assessment-pilot-under-essa\/","title":{"rendered":"iNACOL and KnowledgeWorks Submit Public Comments on Innovative Assessment Pilot Under ESSA"},"content":{"rendered":"
The <\/span>Every Student Succeeds Act (ESSA)<\/span><\/a> presents states with <\/span>a historic opportunity to redesign K-12 <\/a>education around a new definition of student success. States can create space and support for personalized, competency-based learning with next generation accountability systems and innovative new <\/span>systems of assessments<\/span><\/a>, and build capacity with modernized educator development. (Learn more about the new flexibility in ESSA for states to redesign systems of assessments around student-centered learning <\/span>here<\/span><\/a> and <\/span>here<\/span><\/a>.) Over the next year, states will engage in critical design conversations as they craft a new vision for their education system under ESSA.<\/span><\/p>\n Central to these design conversations is how systems of assessments can support personalized instruction and enable competency-based learning progressions. ESSA offers a new opportunity for states wishing to pilot new, innovative systems of assessments in a subset of districts before scaling to statewide use for accountability and reporting purposes<\/span>\u2014<\/span>the Innovative Accountability and Assessment Demonstration Authority (Innovative Assessment Pilot).<\/span><\/p>\n The U.S. Department of Education recently <\/span>issued proposed regulations<\/span><\/a> for the Innovative Assessment Pilot, soliciting input and feedback from the public. <\/span>In response, iNACOL and strategic partner KnowledgeWorks, jointly <\/span>submitted comments<\/span><\/a> on the draft rules. The letter praises the Department\u2019s thoughtful analysis of implementation challenges and offered solutions to prevent unnecessary barriers to piloting innovative new approaches that seek to improve equity.<\/span><\/p>\n September 9, 2016 <\/span><\/p>\n Ann Whalen Docket ID: ED-2016-OESE-0047<\/p>\n NPRM: ESSA Innovative Assessment Demonstration Authority <\/span><\/p>\n Dear Ms. Whalen: <\/span><\/p>\n We are writing to provide comment on the proposed Innovative Assessment Demonstration Authority priorities for the Elementary and Secondary Education Act, as authorized by the Every Student Succeeds Act of 2015, published in the Federal Register on July 11, 2016. We appreciate the opportunity to provide input on this topic.<\/p>\n KnowledgeWorks and iNACOL have partnered extensively over the past few years to advance equity in education policies that enable competency-based, personalized learning. Together, we have a deep reach into the field of K-12 student-centered learning. With over 5,000 front-line innovator members, iNACOL is catalyzing the transformation of K-12 education through policy advocacy, quality standards, and communities of research and practice. KnowledgeWorks develops the capabilities of educators to implement and sustain competency-based and early college schools, works with state and federal leaders to establish aligned policy conditions and provides national thought leadership around the future of learning. <\/span><\/p>\n Our organizations applaud the Department for carefully balancing its commitment to flexibility and innovation with the need to ensure state assessment systems developed under this authority are of high quality. We appreciate the flexibility for states to pursue unique visions for better systems of assessments and we strongly support the Department\u2019s set of selection criteria for evaluating state readiness for this important opportunity.<\/p>\n While we are pleased with the Department\u2019s continued commitment to ensuring this opportunity is of high quality and achievable for interested states, we believe there are several improvements to the proposed regulations that are necessary to prevent unnecessary barriers to innovation. Our specific recommendations below address the following sections of the NPRM:<\/span><\/p>\n The proposed regulations would define \u201cdemonstration authority period\u201d to clarify that an SEA must be ready to implement the innovative assessments in at least some of its LEAs at the time of its application and must be ready to use the system for purposes of accountability and reporting.<\/p>\n We believe states will need significant time and resources to design and build their systems before they are ready to implement in a group of districts. Simply requiring states to be ready to implement at the time of application without the promise of extensive support will likely deter states from participating and limit the demonstration authority\u2019s potential to build knowledge of alternative approaches to assessment. We are pleased with the Department\u2019s proposal to provide technical assistance to interested states in the background section of the NPRM, and think this is an important first step. We strongly encourage the Department to incorporate two additional strategies for bolstering state readiness: <\/span><\/p>\n The proposed regulations would clarify that any innovative assessment design may be used so long as it meets applicable requirements and produces an annual summative determination for each student of grade-level achievement aligned to state standards. While we support this proposal and believe it is important for driving equity and rigor of the system, we recommend the Department make the following two clarifications to ensure states have the ability to produce information of each student\u2019s grade level and current level of performance: <\/span><\/p>\n The statute requires an innovative assessment system to generate results that are valid, reliable, and comparable as compared to the results for students on the statewide assessment. The proposed regulations would require states to submit an annual plan to determine comparability using one of the following methods: Using the state assessment in grade span; administering the state assessment to a sample of students, using a significant number of common items from the state assessment, or some alternative that is equally rigorous and statistically valid. <\/span><\/p>\n While we appreciate the Department\u2019s intention to not constrain states to one approach for evaluating comparability, we are concerned that the fourth option would ultimately be determined by a peer review panel that must decide what qualifies as an \u201cequally rigorous and scientifically valid\u201d standard. We believe it is important for the Department to clearly define the expectations for demonstrating comparability in its final regulation. <\/span><\/p>\n As such, we support the recommendations for evaluating comparability submitted by Susan Lyons, Ph.D. and Scott Marion, Ph.D., at the National Center for the Improvement of Educational Assessment (Center for Assessment) and endorsed by nearly a dozen of the nation\u2019s leading measurement specialists with expertise in comparability. These recommendations emphasize the following points: <\/span><\/p>\n The proposed regulations would clarify that the innovative assessment system and each assessment in the system must meet all of the requirements of Section 1111(b)(2) and the application requirements in order for a state to transition out of the demonstration authority and use its assessment system for purposes of Section 1111(b)(2). We believe this proposal is not consistent with statute which requires the system of assessments to meet all of the requirements of Section 1111(b)(2). <\/span><\/p>\n We believe it would be impractical if not impossible to require this information for each individual assessment in the system. Individual assessments that are part of a system are likely to assess portions of standards as opposed to the comprehensive set of standards covered in the state test. As such, they will not be able to demonstrate comparability to the full breadth and depth of the state tests. Furthermore, states would have to significantly increase the amount of required testing time for districts participating in the innovative assessment system in order to satisfy this requirement. This would likely discourage districts from participation. <\/span><\/p>\n For purposes of evaluating whether a state may use its innovative assessment system for purposes of Section 1111(b)(2) beyond the Demonstration Authority period, the proposed regulations would require an SEA to demonstrate that it has examined the statistical relationship between student performance on the innovative assessment in each subject area and on the other remaining indicators in the accountability system for each grade span in which an innovative assessment was used. Further, a state would have to demonstrate how the innovative assessment that would be used to produce results for the Academic Achievement indicator affects meaningful differentiation of schools. While we believe this information is important to consider, we encourage the Department to make the following clarification to its proposal: <\/span><\/p>\n Clarify that Information on Student Performance Alone Should not Determine Whether a State May Transition to its Assessment System for Purposes of Section 1111(b)(2)<\/span>. We agree that the Department, the peer review panel, and participating states should take into account student performance on required accountability indicators as they consider the full picture of change throughout the demonstration authority period. That said, the Department must be careful not to imply that an assessment system on its own will drive improvements in student performance. The goal of the transition evaluation must be to determine whether the assessment system produces a valid and reliable inference of each student\u2019s performance level that can inform decisions for accountability purposes. Changes in student performance, however, are the result of state and district teaching and learning strategies. We believe the Department should clarify that the Secretary and the peer review panel should consider the statistical relationship between student performance on the innovative assessment in each subject area and on the other remaining indicators in the accountability system for each grade span in which an innovative assessment was used, but that this information alone should not impact whether a state may be allowed to continue use of its innovative assessment system beyond the demonstration authority period for purposes of Section 1111. <\/span><\/p>\n Thank you for your consideration of these important recommendations. We look forward to working with the Department and interested states as they explore this opportunity and begin to build better assessment systems that drive student-centered learning.<\/span><\/p>\n <\/p>\n Sincerely,<\/p>\n Lillian Pace<\/span><\/p>\n Senior Director of National Policy<\/span><\/p>\n KnowledgeWorks<\/span><\/p>\n <\/p>\n Maria Worthen<\/span><\/p>\n Vice President, Federal & State Policy<\/span><\/p>\n iNACOL<\/span><\/p>\n","protected":false},"excerpt":{"rendered":" The Every Student Succeeds Act (ESSA) presents states with a historic opportunity to redesign K-12 education around…<\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"_relevanssi_hide_post":"","_relevanssi_hide_content":"","_relevanssi_pin_for_all":"","_relevanssi_pin_keywords":"","_relevanssi_unpin_keywords":"","_relevanssi_related_keywords":"","_relevanssi_related_include_ids":"","_relevanssi_related_exclude_ids":"","_relevanssi_related_no_append":"","_relevanssi_related_not_related":"","_relevanssi_related_posts":"","_relevanssi_noindex_reason":"","footnotes":""},"categories":[1],"issue":[61,384],"location":[],"class_list":["post-2032","post","type-post","status-publish","format-standard","hentry","category-uncategorized","issue-federal-policy","issue-harness-opportunities-in-essa-federal-policy"],"acf":[],"yoast_head":"\nThe full text of the letter is below:<\/span><\/h3>\n
\n<\/span>Senior Advisor to the Secretary
\n<\/span>Delegated the Duties of Assistant Secretary for Elementary and Secondary Education
\n<\/span>U.S. Department of Education
\n<\/span>400 Maryland Avenue SW., Room 4W311
\n<\/span>Washington, DC 20202 <\/span><\/p>\nOverview of Comments <\/b><\/h5>\n
\n
Section 200.76 — Innovative Assessment Demonstration Authority: <\/b>Definition of \u201cDemonstration Authority Period\u201d <\/i><\/b><\/h5>\n
\n
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Section 200.76 — Innovative Assessment Demonstration Authority: Definition of <\/b>\u201cInnovative Assessment System\u201d<\/i><\/b><\/h5>\n
\n
Section 200.77 — Demonstration Authority Application Requirements: <\/b>Comparability<\/i><\/b><\/h5>\n
\n
Section 200.79 — Transition to Statewide Use: <\/b>Individual vs. Systems of Assessments <\/i><\/b><\/h5>\n
Section 200.79 — Transition to Statewide Use: <\/b>Transition Evaluation <\/i><\/b><\/h5>\n