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Page 1: Massachusetts Department of Elementary and Secondary Educationblogs.edweek.org/edweek/curriculum/MassChester.pdf · Massachusetts Department of Elementary and Secondary ... extension

Massachusetts Department of Elementary and Secondary Education 75 Pleasant Street, Malden, Massachusetts 02148-5023 Telephone: (781) 338-3000

TTY: N.E.T. Relay 1-800-439-2370

Mitchell D. Chester, Ed.D. Commissioner

To: Members of the Board of Elementary and Secondary Education

From: Mitchell D. Chester, Ed.D., Commissioner

Date: Oct. 9, 2014

Subj: Update on ESEA Flexibility Waiver

I am pleased to report that the U.S. Department of Education (ED) has granted our request for an

extension of our Elementary and Secondary Education Act (ESEA) flexibility waiver through the

2014-15 school year. This will allow us to continue to use the accountability system and other

tools we have developed over the past few years to support school and district improvement

efforts.

At the same time, ED did not approve our request to waive the ESEA requirement for a single

statewide student assessment for 2014-15 and will require us to submit a plan demonstrating that

we will be in compliance no later than 2015-16. This schedule is consistent with our plans for a

two-year "test drive" of the PARCC assessment.

This memorandum provides additional information on both of these decisions. A copy of the

approval letter from Deborah Delisle, assistant secretary for elementary and secondary education

at ED, is attached.

The ESEA was first enacted by Congress in 1965, and it is the major source of federal funding

for the nation’s K-12 school systems. It has been reauthorized and amended on a number of

occasions; the most recent reauthorization, in 2001, was nicknamed “No Child Left Behind”

(NCLB). The NCLB amendments instituted extensive requirements for annual student

assessments, and they required every school to make “adequate yearly progress” (AYP) toward a

goal of 100 percent student proficiency by the 2013-14 school year. As the years went by, more

and more schools fell behind AYP’s rigid metric. By 2013, approximately 80 percent of

Massachusetts public schools and 90 percent of our school districts were labeled as failing under

AYP. There was a growing consensus, both locally and nationally, that AYP had lost its

credibility and needed to be replaced, but the political gridlock in Washington undermined

bipartisan efforts to enact a new reauthorization of ESEA.

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To address this problem, U.S. Secretary of Education Arne Duncan offered states the opportunity

to apply for an administrative waiver of AYP and certain other NCLB provisions. Massachusetts

applied for and received a waiver extending through the 2013-14 school year. Under this waiver,

we have been permitted to substitute our state accountability system for NCLB’s AYP

measurements. Our state system, which incorporates the five levels of school designations that

we discussed at last month’s special Board meeting, was developed beginning in 2008 and was

codified in 2010 through the Legislature’s enactment of the Achievement Gap act. It is a more

nuanced system than AYP, with realistic targets and multiple measures of performance. The

waiver provided us the opportunity to implement a unitary accountability system that maintains

our state's high standards and expectations and meets both federal and state requirements.

In the fall of 2013, ED invited states with approved ESEA waivers to request an extension. In

preparing for our extension request, we consulted with Massachusetts educators and other

stakeholders to review our accountability and assistance system and identify potential areas for

improvement. There was broad support in the field for extending the waiver. The Board

discussed the proposed waiver extension at its April 2014 meeting. Our request was submitted to

ED in July, and Assistant Secretary Delisle’s letter indicates that it has now been approved.

The cautionary note in Assistant Secretary Delisle’s letter concerns the ESEA requirement that

states use a single assessment to measure student achievement. Giving districts the choice of

PARCC or MCAS this spring runs afoul of this requirement. In November 2013, I recommended

and the Board approved the two-year “test drive” of the new PARCC assessment to determine if

it is worthy of adoption to replace MCAS as the Massachusetts statewide student assessment.

Last spring was the first year of the test drive, consisting of field tests in a broad sample of

schools and classrooms. This coming spring, in the second year of the test drive, we will give

PARCC in a fully operational mode, and districts have been given the choice of whether to

administer MCAS or PARCC. This will lead to a decision by the Board in the fall of 2015 on

whether PARCC will replace MCAS.

The other states in the PARCC consortium will be implementing the new assessment in all of

their schools this coming spring. As you know, Massachusetts is playing a major role in the

development of PARCC. I chair the consortium's governing board, and our student assessment

staff, led by Associate Commissioner Liz Davis, is actively involved on a day-to-day basis with

the test's development. Even so, we have very good reasons for taking a more cautious and

measured approach to a decision on PARCC than our sister states:

• MCAS is a highly regarded, high quality test that has served us well for nearly two

decades. Although we know that we need to raise the bar even further if we are to

maintain our leadership in K-12 education, we made the commitment that our next

generation state assessment will be as good as or better than MCAS.

• Last spring's field tests, while valuable, do not give us all the information we would need

to make a final decision this fall on adopting PARCC. Next spring's planned side-by-side

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testing will give us a wealth of comparative data, and will allow more educators and

students to experience and provide feedback on PARCC.

• The debate over new curriculum standards and assessments based on the Common Core

State Standards has become politicized in many states. If we want to avoid that happening

here, we need to demonstrate that we will be thoughtful and deliberate, as we have always

been, in making these important decisions.

• Local school officials have given us a lot of feedback about the challenges of

implementing a wide range of new initiatives in recent years. Giving districts a choice of

assessments in spring 2015 will provide a welcome respite for those districts that are

concerned they may lack the capacity to move to a new state assessment this year.

We have been forthcoming with ED staff over the past 15 months about our two-year test drive

plan. Secretary Duncan has said that he fully understands and empathizes with the reasons for our

transition plan, but he is unable to offer us a waiver option that was not available to other states.

Accordingly, Assistant Secretary Delisle's letter requires us to demonstrate that we are prepared

to make a final decision on our statewide testing program for 2015-16 and beyond. As I noted

above, the Board is scheduled to take that vote in the fall of 2015, after we have carefully

considered the results of the MCAS-PARCC comparison review. The ED directive reinforces the

importance of keeping to that schedule.

At the same time, I do not believe that ED's finding of non-compliance for 2014-15 is sufficient

reason for us to accelerate our decision-making timetable. I recommended, and the Board

adopted, the two-year transition plan because it is in the best interests of our students and

teachers. We value our partnership with the federal government, but there are times when

partners will disagree, and when that happens, our first and foremost obligation is to do what is

right for Massachusetts.

We will have an opportunity to discuss these issues in greater detail at the upcoming Board

meeting on October 21. In the meantime, please let me know if you have any questions.

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