The AFT gave a qualified thumbs-up to federal regulations governing academic assessments under the Every Student Succeeds Act, with some important caveats on flexibility for testing students with disabilities and English learners, and how the alternative testing proposal will work given the realities of big school systems.
The AFT was represented by Executive Vice President Mary Cathryn Ricker on the negotiated rulemaking panel that crafted the proposed regulations, and the rules generally "reinforce and provide clarity" to how testing is treated under ESSA, AFT President Randi Weingarten observed in written comments to the U.S. Department of Education. Among the proposed improvements are rules that could help stop double-testing of eighth-graders and a path for districts to harness accountability systems based on nationally recognized tests instead of traditional state standardized tests.
When it comes to the appropriate inclusion of English learners and students with disabilities in testing, the proposed rules generally "make sense and appear fair," Weingarten wrote. She expressed concern, however, that the Education Department proposal requires states to test 95 percent of all students and 95 percent of students with disabilities in order to receive a waiver from testing students with significant cognitive disabilities. This "inappropriately ties one provision of ESSA, test participation rates, to another unrelated provision, flexibility on testing students with such disabilities," she stressed. "The department is setting up a host of implementation problems and potentially pitting groups of students and parents against each other."
The union also expressed its continued reservations about proposed rules that allow English learners within their first year in the country to be exempted from one administration of the reading/language arts assessment but not those in math and science. "Mandating testing in the first year, rather than leaving this decision to the local educators on a case-by-case basis as we recommend, does not produce valid test results that show what these students know and can do, nor is it fair to their schools or the students themselves."
The AFT's comments also caution that the department's rules to allow districts to choose "locally selected, nationally recognized assessments" will do little to achieve ESSA's legislative goal of reducing testing at the high school level. Moreover, they would put big, diverse school systems at an extreme disadvantage because districts would be forced to choose the same alternative test for all their high schools.
The union also weighed in on proposed rules for a pilot program included in ESSA that allows states to use performance assessments and other nontraditional assessments for accountability and reporting purposes. In a letter that offers some recommendations for strengthening the language, Weingarten again hailed the pilot as one of the most promising components of ESSA. "It is an opportunity for schools to move away from traditional multiple-choice, fill-in-the-bubble exams that have been much-criticized and too often misused, and toward performance assessments that assess students' knowledge and skills in a deep and meaningful way over time."
The department will review comments on the proposed regulations and release final rules later this year. The new accountability system is set to take effect at the beginning of the 2017-18 school year.
[Mike Rose, Beth Antunez]