Massachusetts Department of Elementary and Secondary ?· Massachusetts Department of Elementary and…
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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
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 nations 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 AYPs 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.
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 NCLBs AYP
measurements. Our state system, which incorporates the five levels of school designations that
we discussed at last months special Board meeting, was developed beginning in 2008 and was
codified in 2010 through the Legislatures 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 Delisles letter indicates that it has now been approved.
The cautionary note in Assistant Secretary Delisles 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
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.