Colorado’s plan to ease the testing burden for 10th graders may well get federal approval, but the state still has to jump through some hoops before the change is a done deal.
The testing reform law passed by lawmakers last spring made several changes to the state’s assessment and accountability system, including a shift in high school standardized testing and a one-year timeout in the rating system for districts and schools.
But lawmakers didn’t necessarily have the last word, given that some changes require U.S. Department of Education approval as part of Colorado’s request for flexibility on requirements of the Elementary and Secondary Education Act, the nation’s main education law.
State Department of Education officials have been discussing the changes with the U.S. Department of Education all summer and will present the proposed request to the State Board of Education for its approval on Wednesday.
“We’ve been going back and forth to make sure we know their issues” before going to the State Board, said Alyssa Pearson, the state education department’s interim associate commissioner of accountability, performance and support. After the board takes action the request will be submitted to Washington, but state education officials still will have work to do.
Here’s a rundown of the status of key issues, based on the draft flexibility application and on explanations provided by Pearson.
High school testing
There’s a little bad news and some good news here.
Legislative backers of the testing reform law, House Bill 15-1323, hoped that the results of PARCC language arts and math tests given in 9th grade could be use to fulfill federal requirements for giving those tests once in the high school years.
Pearson said that after talking to federal officials, the state concluded such use of 9th grade tests to meet federal requirements “wasn’t an option for us.” (Colorado has tested 9th graders for years, but the federal government defines high school as grades 10-12.)
The good news is that federal education officials are open to use of a different 10th grade test. “They said that should work,” Pearson said. But here’s where the hoops come in. The feds want assurances that a new test would be aligned to state academic content standards and want to see a detailed implementation plan. She said the state has 30-45 days to come up with that plan.
The goal of the testing law was to reduce the testing burden on 10th graders by allowing them to take a college readiness test that takes less time than PARCC tests. The law requires the state education department to seek competitive bids for both that test and an 11th grade test. (The ACT test has been given to all high school juniors for several years.)
Timeout for school and district ratings
The testing law requires that the upcoming school year will be a time-out year for accreditation ratings. No new ratings will be announced this fall, meaning schools and districts will retain the ratings they were assigned at the end of 2014. Test scores and student growth data derived from scores are a major part of the ratings.
“They’ve allowed that for other states, so that should not be an issue for them,” Pearson said.
Alternative tests and accountability
A much-debated section of the testing law allows districts or groups of districts to create pilot programs to try out new tests and accountability systems, the hope being to eventually find something to replace the current systems.
The state’s draft application doesn’t include any requests on this issue, but the federal education department has made it clear that students participating in pilot programs also would have to take current state tests for two years, Pearson said.
That could be a disincentive for districts to propose pilots. One group of rural school districts, the Rural Innovation Alliance, has expressed interest in launching a pilot, but that work is in its very early stages.
Opting out of tests
The draft application doesn’t include any request related to penalties for schools and districts that fail to meet federal requirements that 95 percent of students participate in tests.
Test refusal became a hot issue in Colorado starting last fall, when the statewide participation rate on 12th grade science and social studies tests was about 82 percent.
In February, the state board passed a resolution stating districts shouldn’t be penalized for low participation, and test refusal was debated in the legislature last spring. A separate out-out bill died, and HB 15-1323 contains language that clarifies how districts should handle parents who want to opt out.
And spring test participation in major districts generally fell below 95 percent, a recent Chalkbeat investigation found (see story).
Whether districts or the state ultimately will be penalized for lower participation rates is unclear. State law penalizes districts for low participation by lowering their accreditation ratings. But because the accreditation rating system is on hold for a year, there isn’t expected to be any immediate impact from last spring’s widespread test refusals.
Federal officials have raised questions about recent state board approval of an innovation application from the small Holyoke school district in northeastern Colorado. That innovation plan gives the district wide flexibility in meeting the state requirement that 50 percent of teacher’s evaluation be based on student academic growth data. (See details on the Holyoke plan in this document.)
“We have to give them more information” about the Holyoke plan and whether it meets the intent of state evaluation law, said Katy Anthes, the CDE interim associate commissioner.
English language learners
Various changes in testing of some English language learners are included in HB 15-1323. The U.S. Department of Education wants Colorado to do further work on a couple of those, Pearson said.
The state board has gained a reputation for unpredictability since two new members joined in January. (A third new member was appointed over the weekend to fill a vacancy.) A majority of the board has been critical of PARCC tests and the Common Core State Standards. So Wednesday’s discussion of the waiver application bears watching.
Once the state files its waiver application – and answers other questions from the federal education department – it’s hard to say when Washington will make a final, formal decision on the application. The timeline is unclear, Pearson said.
Theoretically, federal rejection of Colorado’s flexibility application could threaten federal education funds for the state. But there’s a long bureaucratic process that would have to happen. And the rules for state-federal education relations could change if the U.S. Senate and House reach agreement on a rewrite of the Elementary and Secondary Education Act. Talks on how to reconcile competing bills are expected to resume when Congress returns from its summer recess.