Comment From The Education Trust-Midwest On Request For ESSA Waiver On Science Assessments

The Education Trust-Midwest (ETM) recognizes the importance of developing and field testing assessment tools that measure current state standards, provide parents and educators with honest information about student and school learning and proficiency, and provide a clear picture of proficiency and areas of needed improvement.

Despite this, several concerns with the requested waiver remain. Concerns include:

• A request to not release data from the science assessment for the 2017-18 and 2018-19 school years;
• Request of a waiver regarding assessments after the assessment had been administered; and
• Inadequate notice and understanding among educators, parents and students of the nature of changes made during the 2017-18 school year.

More details of these concerns are below:

A request to not release data from the science assessment for the 2017-18 and 2018-19 school years.

Although ETM supports the temporary exclusion of data from a new assessment from the state accountability system, including the new science assessment, not providing data is a disservice to all education stakeholders, including students, parents and educators.

Providing school-level data publicly will expose gaps in performance between schools and school districts, and among student subgroups. Providing student-level data to parents provides the opportunity for parents to better understand strengths and deficits of their student. Furthermore, it is unreasonable for the state to sit for an assessment without the opportunity for students to understand their performance on the assessment.

Finally, the approach of releasing student-level and school-level data, without accountability attached during the initial years of testing, is consistent with Michigan’s recent approach to new English language arts and math M-STEP assessments.

We urge the Michigan Department of Education to revise the waiver request to include the public release of school-level, district-level and state-level data. Additionally, we urge the MDE to revise the waiver request to also provide for the timely distribution of student-level reports to parents.

Request of a waiver regarding assessments after the assessment had been administered.

The timing of the Michigan Department of Education’s request for waiver from requirements of the Every Student Succeeds Act is particularly troubling.

The waiver request comes several months after testing concludes, rather than well in advance of the assessment administration. Furthermore, the waiver request indicates that the need to develop and field test a new assessment during this time period was well understood by the MDE during 2017, including before Michigan’s consolidated state plan under the Every Student Succeeds Act was finalized and approved by the Michigan Department of Education.

The request for a waiver from the requirements of the Every Student Succeeds Act should have been made well in advance of the spring 2018 state assessment. The most appropriate timing would have been within Michigan’s draft ESSA plan or contemporaneously with Michigan’s draft ESSA plan.

Inadequate notice and understanding among educators, parents and students of the nature of changes made during the 2017-18 school year.

While the Michigan Department of Education did reference the 2018 science assessment as a “field test” in some assessment documents, it is unclear whether educators, parents and students understood the underlying need for a field test, what was included and excluded from the assessment, how it would compare to future assessments, and what the implications would be for accountability and public reporting.

The Education Trust-Midwest urges the Michigan Department of Education to revise the waiver request to outline specific actions that will be taken prior to the spring 2019 field test to ensure broad understanding by all education stakeholders, including students, parents, teachers, and administrators, about the field test and related implications, in the event that the waiver is approved.