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A letter from Gene Wilhoit: How might we respond to Secretary DeVos?

Updated: Sep 24, 2020

On September 3rd, all chief state school officers received an important letter from US Education Secretary DeVos regarding assessment and accountability for the current school year.  You now have greater clarity about Federal expectations. To quote: “It is now our expectation that states will, in the interest of students, administer summative assessments during the 2020-2021 school year, consistent with the requirements of the law and following the guidance of local health officials.  As a result, you should not anticipate such waivers being granted again.”  However, this does not mean assessment designs and administration need to be as they have been. And, we know that we have learned a lot under the intensity of COVID 19 and the call for social and racial justice. It appears the Department is open to working with states to improve assessment and accountability this year. Again, to note: “It might be difficult to imagine the administration of statewide assessments in the same manner as they have been administered in the past… may be that the assessments will look different….Now may be the perfect time for you to rethink assessment in your state, including considering competency and mastery-based assessments, to better gauge the learning and academic growth of your students.” 

So, let’s get down to specifics about assessment and accountability.

All chiefs took the opportunity to request and receive a Federal reprieve to forgo state summative assessments for the year just completed. The reason was COVID 19—schools were closed, students and teachers were communicating with each other via hastily developed distance learning with some students coping and too many disconnected totally. Curricula were adjusted, aborted or dramatically altered. So, everyone admitted that forcing summative tests on a system in disarray was unfair and impossible to administer. This made sense given what we thought was a one-time situation in which we found ourselves and we thought we could return to normal assessment and accountability routines this year. 

It is clear that we are not going to return to prior practice this year and, given what we are learning, we may be at a point of inflection that will reshape multiple aspects of learning in this country. Therefore, the issues of assessment and accountability are up for debate and revision. For real reasons, people have concerns about this shift. Well-meaning advocates for historically underserved children - whether they be students with special needs, English language learners, students of color and those in poverty - know that those children and youth have not been supported as they should. Their rightful plea to policymakers is that we not regress to a time when these children were overlooked, underserved and forgotten. 

Moreover, the entire system of federal and state reporting and accountability is dependent on these summative tests. They undergird state and school district collection, reporting and determination of learning gaps, labeling school and district performance and formation of improvement plans.  The entire accountability system in all of the states is anchored in the standardized end-of-year assessments and they are used by states to make judgments about schools, districts and state performance. Many states factor these results into judgments about individual teachers and students.

Given this web of dependence, many will be doing all they can to make it through the crisis in the hope that we will be able to return to normalcy as soon as possible. After all, we may not like the system, but we do understand it and have developed ways to operate within or around it. Our systems are dependent upon what we have crafted over the years. Policymakers are invested in and are content with this system as a way to hold schools and districts accountable; we do have what they perceive as a valid way to make policy and to allocate resources. Why not build upon this system? Does it not make sense?

We at C!E have a different perspective. The COVID crisis is an opportunity - for it has shown light on a system that is not serving us as we envisioned. The shortfalls of our investment in assessment and accountability have been recorded—narrowing of the curriculum to perform well on assessed areas and the revelations of cheating are only symptoms. Underneath are more serious issues. We contend that we have put too much faith in the tests as true measures of success or failure. End-of-year summative assessments can give only very broad indications of progress. Because of budget constraints, testing time, nature of test design and other factors, state summative assessments are not appropriate tools to determine student or teacher accountability nor do they support the most important purpose of testing, which is student learning.  Do not misunderstand our intent. We need state measures of institutional accountability, for courts uphold the state as the ultimate agent of responsibility for services to students according to each state’s constitutional language. Policymakers must know that each and every school and district is living up to its responsibility to the community and to the state.  We must not abandon the states’ oversight responsibility.  Standardized assessments can be good instruments for institutional accountability and should be continued since states do need some means to validate local judgments. But they do not need to exist as they are. 

One can envision state summative assessments that are less intrusive, given less frequently and used in much more reasonable ways. States can make valid and reliable judgments about the institutions within their states by annually alternating content areas or assessing by school unit; these tests can be administered in time frames longer than a year, they can be sampled as opposed to each child taking every test, they can be improved in terms of methodology and they must be limited in their application to the use case for which they were designed. For this reason, tests developed for institutional accountability should not be the primary determinant of student and teacher accountability.

In order to balance the impact of state standardized tests we must correct a missed opportunity to invest in the capacity of those working most directly with students by supporting the development of local faculty to assess student progress and standing.  In our immediate future we must commit substantial resources and energy to empower teachers to be the primary determinants of student accountability and for local administrators to use multiple indicators to adjudicate teachers and to provide the necessary support to build individual and team capacity.  To be clear, to withdraw intrusive and inappropriate applications of state summative assessments without ensuring the complementary capacity of local professionalism related to assessment would be folly.  We see no choice; we must do better, and we will never have a high functioning system of assessment and accountability until we shift greater responsibility and support to local educators. 

As professionals, teachers should be expected to possess the knowledge and skill to become the center of a balanced system of assessment. It can be done. We have been privileged to stand in support of one state effort to do so and are aware of others that are moving in this direction. 

Under a 1204 agreement with the U.S Department of Education, New Hampshire is engaged in a process to empower and engage teachers as the builders of a better way. I am sure these educators would say this is not the only way, just one way to build a balanced system of assessment and accountability.  The NH Performance Assessment of Competency Education PACE system is based on local performance assessments that are calibrated partially by comparisons to state tests in the core content areas of English Language Arts, Math, and Science given not annually, but only in grade spans, as well as Common PACE performance tasks in each grade and content area, that are constructed and piloted by teams of NH teachers, overseen by the National Center for Assessment.  Data analysis and group calibration sessions find PACE accountability determinations to largely be as reliable as the state test overall.  The common task development sessions of teams of educators within a community of practice model has led to an apprentice-like development of assessment literacy among the teachers leading the process.  Scaling across the state has been slow due to the lack of resources in 1204 for supporting innovative assessments, something crucial to the development of a locally supported model.  

New Mexico, in the last year, has adopted what approaches a fully balanced assessment system that is closely aligned to what we have laid out in this paper.  They have adopted a state assessment in required content areas with a minimal footprint to meet federal school accountability requirements and are simultaneously constructing a locally developed performance assessment for student graduation, based on state and locally derived Portraits of a Graduate. Their design is intended to better connect to the diverse cultural populations in a state with vast rural areas as well as the substantial racial, ethnic, and socioeconomic realities that exist in Albuquerque and other cities. They have adopted a community of practice approach to work in partnership with local leaders and educators, as the system is designed and implemented.  They are approaching the emergence of this new way from an asset-based perspective, looking to build on the strengths of their communities, although they recognize that local capacity building with educators will need to be extensive over the coming years.  This project is just completing its first year, and although they have been hampered by the COVID moment, their momentum and commitment to a more equity-based system is exciting to see.

We encourage leaders in other states to use this moment as a time to reassess the balance of their assessments.  Does our assessment system only address state-level accountability at the expense of classroom improvement?  If so, how might we reduce the footprint of our state assessment to allow for growth at the local level?

Ultimately, an effort to build balanced systems of assessment that provide valid and reliable determinants of school and district accountability complemented by evidence of student learning at the classroom and school level will require federal leadership from the Congress and Administration.  The 1204 option should be replaced with a challenge to states to engineer balanced systems of assessments from which appropriate accountability can be designed. This may be the opportune time to act.

More importantly, states in cooperation with local leaders must be the primary agents for assessment and accountability reform. Accountability was conceived of primarily as a way for state and federal officials to hold local schools accountable. To honor and be responsive to the heightened role of families, we will need to engage in productive dialogue with families to consider how schools, districts and even states will be accountable to them.  Governors, legislators, and state boards of education, facilitated by Chief State School Officers and their agencies, must come together with field leaders and families to face the effectiveness of their assessment and accountability systems. 

COVID 19 and the social and racial justice awakening have laid bare deficiencies in systems. Now is an opportune time to ask serious questions and to resolve to do what is possible to develop systems that uphold our commitment to high standards for what students must know to succeed in life while supporting creative learning opportunities for each and every learner. Is the current system serving us well? Where are we achieving our goals and where are we falling short? What are the unanticipated shortcomings? How can we engage our professionals, parents and caregivers and communities in a process of improvement and mutual accountability? Are we willing to and do we have the ability to commit necessary human and financial resources to move in a new direction?

The important point is to use this awakening to pursue improvement. If upon collaborative investigation, you decide your system is serving you well, reaffirm and move forward. If your system needs improvement to better serve learners, educators and their communities and the state, please risk for the good. There are places attempting to redesign assessment and accountability who can be resources. We and others are committed to supporting this important transition within states in which policymakers pledge to come together, engage broadly with education professionals and with broader communities in an effort to align assessment and accountability for the betterment of all learners.




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Considerations Assessment & Accountabili
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