Dear Members of the California State Board of Education,
Last Spring, 3.2 million students in California (grades 3-8 and 11) took the new, computerized Math and English Language Arts/Literacy CAASPP tests (California Assessment of Student Performance and Progress). The tests were developed by the SmarterBalanced Assessment Consortium, and administered and scored by ETS (Educational Testing Service). Costs are estimated at $360 million dollars in federal tax dollars and $240 million dollars in state funds for 3 years of administration and scoring.

Despite the documented failure of the assessments to meet basic standards of testing and accountability, [invalid] scores are scheduled to be released to the public on September 9th.  According to media reports, the 11th grade scores will be used for educational decision-making by nearly 200 colleges and universities in six states. For detailed documents, see Critical Questions about Computerized Assessments and SmarterBalanced Test Scores, the SR Education SBAC invalidation report, the following video, and transcript provided here.

At the September 2nd, 2015 State Board of Education meeting, you heard public comment from Dr. Doug McRae, a retired test and measurement expert who has for the past five years communicated directly and specifically to the Board about validity problems with the new assessments.  He has submitted the following written comments for Item #1 [CAASPP Update] at the latest meeting and spoke again about the lack of evidence for validity, reliability, and fairness of the new assessments. 

“My name is Doug McRae, a retired testing specialist from Monterey.

The big question for Smarter Balanced test results is not the delay in release of the scores, or the relationships to old STAR data on the CDE website, but rather the quality of the Smarter Balanced scores now being provided to local districts and schools. These scores should be valid reliable and fair, as required by California statute as well as professional standards for large scale K-12 assessments. When I made a Public Records Request to the CDE last winter for documentation of validity reliability and fairness information for Smarter Balanced tests, either in CDE files or obtainable from the Smarter Balanced consortium, the reply letter in January said CDE had no such information in their files. I provided a copy of this interchange to the State Board at your January meeting. There has been no documentation for the validity, reliability, or fairness for Smarter Balanced tests released by Smarter Balanced, UCLA, or CDE since January, as far as I know.

Statewide test results should not be released in the absence of documented validity reliability and fairness of scores. Individual student reports should not be shared with parents or students before the technical quality of the scores is documented.  But, the real longer lasting damage will be done if substandard information is placed in student cumulative academic records to follow students for their remaining years in school, to do damage for placement and instructional decisions and opportunities to learn, for years to come. To allow this to happen would be immoral, unethical, unprofessional, and to say the least, totally irresponsible. I would urge the State Board to take action today to prevent or (at the very least) to discourage local districts from placing 2015 Smarter Balanced scores in student permanent records until validity reliability and fairness characteristics are documented and made available to the public.” [Emphasis added]

D. J. McRae, Ph.D. 09/03/15

(To hear his comment, click on the image above and listen from 2:50:55 – 2:52:52).

I support Dr. McRae’s recommendations and would add further that a fundamentally ignored and harmful aspect of the test score release is the psychological impact on the vast majority of youth who are to receive [false] scores indicating that they are not on track for college or career.  Consider the first of twenty principles in educational psychology according to the report by the American Psychological Association: Top 20 Principles from Psychology for PreK-12 Teaching and Learning (Coalition for Psychology in Schools and Education (see also Principles 19 and 20 related to assessments).

“

We know from decades of research that beliefs matter in student learning and motivation.  Without an understanding that the scores are meaningless, students will be likely to internalize failing labels with corresponding beliefs about their academic potential. And unless otherwise informed, families will be likely to believe what the State Department of Education communicates about their children’s readiness for college and career based on an assessment that fails to meet basic standards for testing and accountability.  

Jonathan Pelto has written extensively about SmarterBalanced testing in Connecticut:

“Considering that many of the world’s greatest scientists, authors, actors, teachers and leaders were once English Language Learners one would think the public education system in the United States would be designed to promote and support opportunities for those who need extra help learning the English Language. Moreover you would think education policymakers would be working to find ways to take advantage of the opportunities that having a multilingual population present.”

***

“According to the Smarter Balanced Assessment Consortium’s own information, more than 90 percent of the English Language Learners will be labeled as failures. Rather than discuss whether the test is an appropriate tool or is appropriately calibrated when it comes to passing or failing, the proponents simply say that ‘it is what it is.’

That, in English, is called discrimination and racism….
And it has no place in the nation’s public schools.

Here are some of the “projected” results for the Common Core SBAC Test:

Screenshot and text above from: http://jonathanpelto.com/2015/02/24/more-than-90-of-english-language-learners-projected-to-fail-common-core-sbac-test/

This seems an ethical dilemma for educational leaders.  If they are to be honest with students and families and communicate truthfully that the test scores are meaningless, they would have to acknowledge that the public has been misled (whether knowingly or not) by those promoting the assessments.   Acknowledging the current situation would also include accepting the fact that hundreds of millions of taxpayer dollars have been wasted (and are slated to continue to be wasted) should the assessments continue to fail meeting basic standards for testing and accountability.

Yet, what appears to be the case is that the invalid tests are being falsely promoted as accurate measures of “college and career readiness.”   The LA Times just published a piece entitled, “‘Don’t Panic’ Officials Say as California Braces for Lower Student Test Results.”  It appears state officials are fully aware of the potential harm and motivational fallout yet “Don’t Panic” is the best message being offered as a remedy rather than full disclosure about the lack of validity of the tests.   EdSource just published a piece entitled, What Parents Need to Know About California’s Common Core Aligned Tests.  The first comment from a parent reads,

Again, as Dr. McRae asserts, including current scores in student academic records without evidence of validity, reliability, and fairness of the assessments would be “immoral, unethical, unprofessional, and to say the least, totally irresponsible.” 

False data are false data. Period. And to compare future results with current 2015 scores as “baseline” would be just as fraudulent as it would be to promote the 2015 scores as somehow valid.  The Board has received clear correspondence directing their attention to the SR Education SBAC invalidation report. Rasmussen’s analysis of mathematics test questions posted online by Smarter Balanced “reveals that, question after question, the tests”:

• “Violate the standards they are supposed to assess;
• Cannot be adequately answered by students with the technology they are required to use;
• Use confusing and hard-to-use interfaces; or
• Are to be graded in such a way that incorrect answers are identified as correct and correct answers as incorrect.”

Rasmussen adds,

“No tests that are so flawed should be given to anyone. Certainly, with stakes so high for students and their teachers, these Smarter Balanced tests should not be administered. The boycotts of these tests by parents and some school districts are justified. Responsible government bodies should withdraw the tests from use before they do damage.” –
Read full report

The SR Education report has been published on EdWeek and EdSurge, and reports on the ground from EdSource confirm specific examples of the technological barriers to the test interface described in the report.

Why has the State Board of Education not made a formal request for SBAC or the assessment team to write a public response to concerns documented in the report? 

Above, I referenced costs required for the development and administration of the SBAC tests. If you follow EdTech news, you might not be surprised to see the recent market drop of Amplify, which had received $13.5 million dollars for “report development” and “formative assessment” of SBAC tests and $7M for PARCC’s “data management and reporting.”  Benjamin Herold of Edweek states that “despite a $1 billion investment and a steady stream of brash promises to radically disrupt the way public schools do business, the company’s education division, known as Amplify, is deeply in the red and on the auction block.“ 

One can only wonder how the decline of Amplify may be related to the quality of SBAC reports we are about to receive, as well as the security of data collected given the pending sell-off of the company.  McGraw-Hill, which also received $72.5 million to develop the SBAC assessments has also recently announced pulling out of the summative testing market.

Will the State Board consider the financial insolvency of SBAC-partnering companies as current contracts continue to funnel taxpayer funds to promote future iterations of the experimental assessments? Please include one more Critical Question to the original ten: 

Q11:  How can the State of California ensure that contracts with SBAC and Amplify do not result in the same failures of data security that have occurred in related EdTech fallouts such as the multi-million dollar bankruptcy of ThinkGate LLC? The ThinkGate contract was described by a Superintendent as “a dismal failure that ended exactly in the way that most parents and educators were most concerned about. Student data in the hands of for-profit corporations.”

In closing and in the spirit of critical thinking, I respectfully request that the State Board of Education take on the following challenge. The ultimate endorsement of confidence in your release of SBAC scores would be for each Board Member to publicly take the 11th Grade SBAC Math/ELA tests and to publish your scores at the next State Board of Education meeting. If the assessments are confirmed to be functional and can be verified as accurately, securely, and fairly assessing skills necessary for “college and career readiness”, then every State Board Trustee (all of whom are assumed to be college-educated and career-successful) should receive scores that exceed passing performance.  At the very least, this process should allow you the opportunity to fully endorse the assessment product that has been bought and administered to children. 

If this request is declined or somehow otherwise considered unfair, then why would you demand the same of youth entrusted to your care?

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