November 5, 2020
Mike Morath, Commissioner Texas Education Agency 1701 N. Congress Avenue Austin, TX 78701-1494
Re: Petition USDE for a 2020-2021 ESSA academic accountability waiver due to the COVID-19 pandemic
Commissioner Morath,
During the July and October 2020 ATAC/APAC meetings, the Agency proposed 4 potential approaches to the 2021 A-F rating system, the State of Texas Assessment of Academic Readiness (STAAR), and public school sanctions and interventions. The 41 member districts of the Texas School Alliance (TSA) propose a 5th option for academic accountability ratings during the 2020-2021 school year.
KEY POINTS
- Separate assessment from accountability
- Extend the Not Rated label to the state’s A-F accountability ratings in 2020-21
- Update identification and exit criteria for school improvement (federal and
state) without adding new campuses to any list
Separate Assessment from Accountability
During a normal (non-pandemic) school year, in which students have the opportunity for 180+ days of in-person instruction from highly qualified teachers, state assessments can play a role in monitoring equity, achievement, and other long-term educational trends. However, it will be incredibly challenging to collect, interpret, and use high- quality state standardized test data during the 2020-21 school year.
Secretary DeVos’ September letter to chief state school officers indicated that the Department was “not likely” to grant a blanket state assessment waiver for this school year; which has led some to say, “It is better to have low-quality data than none at all.” But that’s not true. It’s highly unlikely that STAAR data this year will be capable of supporting the important decisions facing education and policy leaders. Grasping at invalid test scores may “feel” like the right thing to do, but such actions can lead to serious unintended consequences such as misrepresenting actual achievement and encouraging intense focus on remediation rather than access to grade-level content.1
Extend the Not Rated label to the state’s A-F academic accountability ratings in 2020-21
While the USDE’s position on state assessment appears to be firm, the door appears to remain partially open for accountability. The Secretary’s letter states, “We are open to discussions about what, if any, actions may be needed to adjust how the results of assessments are used in your state’s school accountability determinations.”
STAAR assessment results cannot be interpreted this year without a better understanding of the circumstances and opportunities facing students; such as whether they have access to digital devices and high-speed broadband, the type and amount of instruction available (at-home, in-person, hybrid), and the level at which students are engaged are key to understanding a student’s “opportunity-to-learn.” Did a student or group of students get a question wrong because they did not know the concepts tested, were not taught the concepts, or did not have the technology to access the content? When students lack opportunities to learn the content on STAAR this year (for whatever reason), users risk drawing invalid conclusions about the effectiveness of educators, programs, or schools.
Missing, incomplete, pandemic-influenced and changing data from the 2019-20 and 2020-21 school years, such as the College Career Military Ready indicators from the Class of 2020, will impact the Texas A-F accountability ratings for campuses and districts. And if STAAR and TELPAS data are collected, its meaning and interpretation will significantly change if: 1) TEA adopts a ‘skip-year growth’ model, which would look at ways to calculate improvement based on 2019 STAAR reading and math data; and 2) if at-home learners opt-out of returning to a campus to take a STAAR or End-of- Course (EOC) test.2
Update identification and exit criteria for school improvement without adding new campuses in 2020-21
In addition to the significant unknowns for 2020-21, campuses identified for both state and federal interventions and sanctions have had decreased opportunities to implement required improvement plans, thereby stifling continuous improvement efforts. TSA recommends that the Agency update the identification and exit criteria for school improvement (federal and state) without adding new campuses to the lists during the pandemic.
Sincerely,
Dr. Roland Hernandez, President, Texas School Alliance Superintendent, Corpus Christi ISD
cc: Governor Greg Abbott
Lt. Governor Dan Patrick
Representative Dan Huberty, Chairman House Public Education Committee Senator Larry Taylor, Chairman Senate Education Committee
1 National Center for the Improvement of Educational Assessment. “THIS IS NOT A TEST; THIS IS AN EMERGENCY” October 2020. “There is a long-history of low-income students and students of color being over-identified for special education, subject to over-remediation, denied grade promotion and graduation, and kept out of advanced classes based on test scores that have not been validated for such uses.”
2 Texas Education Agency. APAC & ATAC October Meeting PPT, October 27 and 28, 2020