Over the next year, states will engage in critical design conversations as they craft a new vision for their education system under ESSA. While the new law doesn’t go into effect until the 2017-2018 school year, now is the time to begin to involve stakeholders in planning for supporting personalized, competency-based learning through redesigning assessments, rethinking accountability, and transforming educator and leader licensure.
The U.S. Department of Education (ED) recently issued draft rules proposing to use existing grant monies authorized under the Enhanced Assessment Grants program in No Child Left Behind to help states prepare for the new assessment flexibilities in ESSA, including the Innovative Assessment Pilot.
Once ED finalizes the rules, states would have the opportunity to apply for funding in three priority areas:
- Developing innovative assessment item types and design approaches;
- Improving assessment scoring and score reporting; and
- Inventory of state and local assessment systems.
These resources—particularly with the first two priorities in the proposed rules—will help states develop high-quality assessment approaches aligned to the new assessment opportunities in ESSA. The Innovative Assessment and Accountability Demonstration Authority in ESSA presents an opportunity for states to pilot new approaches to assessments that better support student-centered, personalized approaches to learning.
Last month, iNACOL, joined by our strategic partners KnowledgeWorks, the Center for Assessment, and the Center for Innovation in Education, submitted public comment praising ED for leveraging the EAG program priorities to help states build capacity for ESSA, and providing feedback to strengthen program outcomes.
The full text of the letter is below:
May 18, 2016
Senior Advisor to the Secretary
Delegated the Duties of Assistant Secretary for Elementary and Secondary Education
U.S. Department of Education
400 Maryland Avenue SW., Room 4W311
Washington, DC 20202
Docket ID ED-2016-OESE-0004
Enhanced Assessment Grants Comments
Dear Ms. Whalen,
We are writing to provide comment on the Proposed Priorities for Enhanced Assessment Instruments published in the Federal Register on April 18, 2016. We appreciate the opportunity to provide input on this topic.
KnowledgeWorks, iNACOL, the Center for Assessment, and the Center for Innovation in Education have partnered extensively over the past few years to advance policies that enable the development of next generation systems of assessments. We actively supported and provided technical assistance for the development and inclusion of many of the new assessment provisions in the Every Student Succeeds Act (ESSA) including the Innovative Assessment and Accountability Demonstration Authority and improvements to Section 1111 that enable states to design assessment systems that incorporate individual student growth, use multiple measures of student learning from multiple points in time to determine summative scores, and use adaptive assessments to measure where students are in their learning. These policy improvements provide states with a significant opportunity to design more useful assessments that guide improvements in teaching and learning and help ensure all students graduate college and career ready.
Over the next year, states will engage in critical design conversations as they craft a new vision for their education system under ESSA. We commend the U.S. Department of Education (ED) for proposing to prioritize resources from the Enhanced Assessment Grant program to support states during this important transition. We believe these resources will help states develop high quality assessment approaches aligned to the new assessment opportunities in ESSA.
While we strongly support ED’s intent outlined in the notice of proposed priorities for the Enhanced Assessment Grants program, we offer the following comments to help ED further strengthen the outcomes of the program.
General Recommendation – Balancing Priorities
Given national interest in the design and use of state and local assessment systems, we expect interest in this competition to be high. States are likely to face significant design challenges as they seek to build and implement new systems of assessments that align to the opportunities in ESSA. Many states will also face increased pressure to reduce unnecessary or duplicative assessments. Since states will have to address both areas as they develop balanced and comprehensive assessment strategies, we encourage ED to ensure that awards are distributed appropriately across each of the proposed priority areas outlined in the notice. Specifically, we recommend that ED fund at least one award from each priority, assuming it receives highquality applications on each topic. This approach will enable ED to maximize the limited funding allocated for this program.
Priority 1 – Developing Innovative Assessment Item Types and Design Approaches.
The Innovative Assessment and Accountability Demonstration Authority in ESSA presents an opportunity for states to develop new systems of assessments that better support student-centered, personalized approaches to learning. Since the statute does not include planning time or resources to help states prepare for this opportunity, states will need to secure additional resources to develop high quality applications and build capacity for implementation. Grants awarded under proposed Priority 1 would address this critical need. We applaud the Department for its foresight in proposing this priority.
We believe ED can strengthen the competition by adopting the following recommendations for Priority 1:
- Maintain Priority 1 and fund, at a minimum, one award from this category
- Require states applying for funding under Priority 1 to articulate a defensible theory of action for how new innovative assessment systems and design approaches will support deeper student learning.
- Clarify the term “competency-based assessment” to communicate that it is an assessment that supports competency based determinations, rather than a type of assessment. “Competency-based” refers to the grain-size of the content being assessed and the expected level of performance (demonstration) of that content—or more often, a particular system of learning—rather than the type of assessment. For example, assessments designed to measure a competency may take a variety of forms and may not necessarily contain innovative item types that “allow students to interact with material and concepts to formulate responses” as described in the Background section of this notice. Instead, traditional and innovative assessment approaches such as performance tasks, simulations, or modular assessments would support competency determinations, rather than competency-based assessments per se.
Priority 2 – Improving Assessment Scoring and Score Reporting.
In order to transition to innovative assessments that more deeply measure mastery of competencies at scale across a state, it will be necessary to invest in capacity for improving assessment scoring and score reporting particularly of performance-based tasks through automated methods. We strongly support the inclusion of these activities under proposed Priority 2.
Under the SEA requirements for submission to proposed Priority 2(b), SEAs can propose projects that improve “the assessment literacy of educators and parents to improve the interpretation of the test results to support teaching and learning in the classroom.” Since improving assessment literacy is critical to the success of a balanced assessment system, ED should maximize the impact of Enhanced Assessment Grant funding by ensuring that applications addressing Priority 2(b) plan to leverage other sources of federal funding to support this goal. States and districts may already use ESEA Title I, Part A, Title II, Part A, and Title III professional development funds to improve educator assessment literacy as clarified in ED’s February 2, 2016 guidance to the Chief State School Officers. Additionally, Title I, Part A funds might be used to support parental engagement activities.
In summary, we believe ED should make the following improvements to Priority 2:
- Maintain Priority 2 and fund, at a minimum, one award from this category.
- Amend (b) of Priority 2, to ensure that states and districts seeking funding to improve the assessment literacy of educators and parents have a high quality plan to leverage and align other federal funding sources such as Title I, II, and III funds to improve educators’ assessment literacy, and Title I, Part A funds to support parental engagement activities.
Priority 3 – Inventory of State and Local Assessment Systems.
While the goals of proposed Priority 3 are important, we believe ED should limit funding for the Enhanced Assessment Grant program to the activities outlined in proposed Priorities 1 and 2 since states may already access other sources of federal funding for the activities referenced in proposed Priority 3. ED’s February 2, 2016 guidance to the Chief State School Officers provides guidance to states on these other sources of funding. The guidance specifically references use of ESEA Section 6111 funds to conduct state and local assessment audits and ESEA Title I-A funds to support the appropriate use of assessment results.
In lieu of removing proposed Priority 3, ED should, at a minimum, reframe the priority to emphasize the design of balanced assessment systems that create coherent assessment experiences at the student and classroom levels. Rather than referring to individual assessments, including the term “balanced systems of assessments” implies an underlying theory of how different types of assessments work together to provide information to relevant stakeholders within the system. This approach would better align with the intent of the Enhanced Assessment Grants program and greatly improve the quality of applications.
Further, we believe requirement (a)(3) of proposed Priority 3, “Review State and LEA activities related to test preparation to make sure those activities are focused on academic content and not on test-taking skills“ is beyond the scope of the proposed priority. We are concerned that this requirement has the potential to divert funds from the critical goal of enhanced assessment design to programmatic and instructional concerns.
In summary, we recommend the following:
- Strike proposed Priority 3;
Or, if Priority 3 is maintained:
- In (a)(1), (2), and the preamble to (b), replace each occurrence of ‘assessments’ with ‘balanced systems of assessments,’ and clarify in the introduction to proposed Priority 3 that the goal of the inventory is to ensure that all assessments in the state’s systems of assessments work together to provide information to the relevant stakeholders within the system.
- Strike requirement (a)(3) of proposed Priority 3 to maintain focus on the assessments rather than including other kinds of instructional practices and programs in this review.
Thank you for the opportunity to provide comments on this notice. We look forward to working with you and our state partners to support the development of better assessment instruments with the potential to transform teaching and learning.
Judith A. Pepper, President and Chief Executive Officer, KnowledgeWorks
Maria Worthen, Vice President, Federal and State Policy, iNACOL
Scott Marion, Executive Director, Center for Assessment
Gene Wilhoit, Executive Director, Center for Innovation in Education