Formal comments on Florida's consolidated plan for the Every Student Succeeds Act (ESSA) were submitted by Dr. Karen Effrem, FSCCC's executive director.
There were two strong points of agreement with the Department's plan:
Seeking a waiver from the 95% testing mandate
Not using subjective psychosocial criteria as the "any other factor" in the accountability scheme.
There were also several points of disagreement that included: Continued use of the Common Core standards rebranded as the Florida Standards and AIR's FSA as the state test.
Receiving federal funds for ineffective, psyhologically invasive, privacy harming programs under Title IV, such as the 21st Century Community Learning Centers (AKA Parent Replacement Centers) and the safe and healthy schools programs that include a lot of psychological monitoring and data gathering, including by teachers that are already overburdened and not formally trained for this type of activity.
FSCCC hopes that Florida will reappropriate its 10th Amendment right to control education. We strongly agree with American Principles Project senior fellow Jane Robbins, who said in a recent article:
This chatter illustrates a deeper problem. Over the last 50 years, state education establishments and their auxiliary politicians have developed a Washington-dependent mindset. State educrats continually tell parents, for example, that the Common Core standards can't be ditched because what else would Washington approve? What else could we possibly use? And what about assessments? Heaven forbid we implement our own testing policy, because surely Washington knows best. We must seek permission from Washington to make any changes that push the ESSA envelope. Is it worth risking our federal money to venture from the tried-and-(un)true?
Obviously, ESSA restricts both USED and the states. But USED could do much more to achieve the "liberation" that Read more
As expected and in typical bureaucratic doublespeak, the Florida Department of Education used the report by the sole bidders for the allegedly independent review of the 2015 FSA test to magically deem that Florida's test scores could be used in the aggregate for school grades and teacher evaluations. Commissioner Pam Stewart who has presided over much chaos and bears much responsibility for the many problems and lack of accuracy of her own statements in the Common Core standard and testing fiasco, called this statement by Alpine "welcome news." However, even the authors of the study, who have multiple incestuous relationships to the development of Common Core standards and the testing industry, admit numerous problems with their work blaming it all on a fast timeline or other factors beyond their control. Here are some of the most important issues:
Admitted lack of rigor and adequate standardization The report's executive summary said, ""The evaluation team can reasonably state that the spring 2015 administration of the [Florida Standards Assessments] did not meet the normal rigor and standardization expected with a high-stakes assessment program like the FSA."
Basing the FSA on the Utah Test which has no Validity As FSCCC has previously reported, Florida is renting test questions from Utah for three years at a cost to the taxpayers of $16.2 million in addition to the reported $220 million cost of the 6 year testing contract. The Utah test still has no validity information, despite being used for the last two years. However, this should be no surprise as the Department has admitted doubts about the validity and usefulness of the FCAT 2.0 that had been in use since 2011 (see page 137).
The computer adaptive national SBAC test also developed by AIR also has zero validity and reliability data Here are the comments of testing specialist Dr. Doug McCrae presented to the California State Board of Education on 9/3/15:
"My Read more
It is getting very hard to keep up with the American Institute for Research's educational malfeasance in the testing realm. Parent Advocate Deb Herbage and Dr. Karen Effrem of FSCCC have reviewed the 2245 page contract between AIR and the Florida Department of Education. Here are just a few of those revelations as Alpine spends another $600,000 of Florida taxpayer funds to do a validity study that should have already been done and that Commissioner Stewart promised was done. The public has been told this test is going to cost the public $220 million over six years. It is very important to verify what has been paid for has been done.
The following information was taken directly from the executed contract Contract #14-652 for the development of the state assessment (FSA) and Algebra I, Algebra II, and Geometry End of Course (EOC's) exams executed on 6/3/14. The contract was signed by Pam Stewart (FLDOE) and Vickie Brooks (AIR). [The full 2245 page contract is available at the Florida CFO website with all page numbers referencing this document].
1) Potentially Missing Linking, Validity and or Field Studies Have Florida Taxpayers Paid for Work Not Completed? The FLDOE required in its ITN (Invitation to Negotiate) that:
7.6.0. Scaling, Equating, Scoring and Special Psychometric Studies (Pg. 77)
Excerpt from the ITN" Other than the annual regular psychometric operations, such as sampling, test construction, and SES for the assessment system, the contractor will conduct a set of special psychometric studies for these assessments, described in Section 220.127.116.11. (Pg. 77)
The contractor must show evidence that the Department's preferences are psychometrically defensible and operationally feasible. The respondent may include in the reply a different proposal for scaling, equating, and scoring of these assessments to obtain assessment results that are valid, reliable, and accurate. (Pg. 165)
AIR said in numerous places in Read more
Karen R. Effrem, MD - Executive Director
Jeff Solochek of the Tampa Bay Times wrote a confused and confusing column yesterday about the effects of the new testing law (HB 7069) on third grade retention, saying the following:
Because the law no longer mandates retention, districts are now figuring out how to have uniform decisions throughout their elementary school systems.
Here are four pieces of evidence showing that his statement is not true:
His earlier column on the subject:
This wording [The diluted Hays amendment requiring a validity study allegedly before retention] does not end or put off the retention of third graders.
The language to which he refers for the statement above that third grade retention is not ended:
1216 (c) Until such time as an independent verification of the
1217 psychometric validity of the statewide, standardized assessments
1218 first implemented in 2014-2015 is provided,for purposes of
1219 [determining - stricken] grade 3 English Language Arts student performance
1220[ retention pursuant to s. 1008.25(5) - stricken] and high school graduation
1221requirements pursuant to s. 1003.4282, student performance on
1222 the 2014-2015 statewide, standardized assessments shall be
1223 linked to the 2013-2014 student performance expectations.
Because the legislature struck the language referring to the third grade retention statute related to the validity study requirement, there is no protection for third graders being retained due to an invalid test.
Additionally, the language above is only for the 2014-2015 school year. There is no language to indicate that the third grade retention policy is changed, weakened, postponed, or stopped any time beyond 2015.
Another place in the new law:
922 (b) To be promoted to grade 4, a student must score a
923 Level 2 or higher on the statewide, Read more
Bills to deal with the out of control testing system in Florida advanced in the House and Senate this week. Here is an overview:
HB 7069 Unfortunately the two good amendments by Rep. Mia Jones and Rep. Evan Jenne that we discussed in our last alert were defeated along party lines on the 17th. We do thank Rep. Debbie Mayfield (Indian River) and Rep. Tom Goodson (Orange) for being the only two Republicans courageous enough to join all of the Democrats and vote for Rep. Jenne's very common-sense amendment to allow a paper and pencil option and to affirm the requirement for load testing that Commissioner Stewart so flagrantly ignored. Unfortunately, the rest succumbed to the difficult to swallow concept that paper and pencil tests would be too expensive and "blow up the budget," when the state, according to State Board of Education president Gary Chartrand, admitted during the February 18, 2014 hearing and an FSBA memo have both stated that the switch to online Common Core testing will cost Florida taxpayers $2 billion.
One very important issue that we mentioned in our last alert was about reading and third grade retention. We said that HB 7069, "While attempting to streamline the issues surrounding third grade retention for reading deficiency, it actually appears to decrease flexibility for parents trying to prevent retention by limiting any "Good cause" alternatives until after the child has failed the state reading test." Although the language says that a portfolio may be started any time there is concern about a reading deficiency, parents may not be notified of such and may not be able to start a portfolio until after the child has failed the reading test at near the end of the year. In addition, the bill removes the portfolio and alternative assessment from the "good cause" list of exemptions. Now the new language states:
918 (b) In order to be promoted to grade 4, a student must
919 score a Level 2 or higher on the Read more
The Senate Education Committee met on March 4th to discuss a proposed committee substitute for SB 616. The bill, sponsored by committee chairman John Legg, makes some good attempts to begin to deal with the testing issue, but given the severe extent of problems, needs additional protections for student and parental rights, privacy and other issues. The bill works to have a 5% cap on testing, which is a step in the right direction, but does not explain who is going to and how the time is going to be kept on different students who take different tests especially in high school. It gets rid of the 11th grade Reading/English test and keeps the 10th grade high stakes test. It allows districts to seek a waiver on school grades if they so choose for technological or financial reasons. However, if they choose that option they cannot qualify for any kind of performance bonuses even if the problems are beyond their control. The bill also decreases the percentage for which test scores are used in teacher evaluations.
Several common sense amendments by Senator Bullard that would have enhanced these good first steps were rejected along party lines. One of these amendments allowed a paper/pencil alternative for testing that deals with technology issues and would have also protected students from the manipulative and data mining aspects of computerized testing. This is the same language contained in his bill SB 1450, the Senate companion to Rep. Debbie Mayfield's HB 877, analyzed here.
The DOE is now saying in response to emailed inquiries that the FSA is not nor will be adaptive, meaning that the questions change based on the answers to the previous question. However, that is new news and somewhat difficult to accept and verify given AIR's development of the computer adaptive testing platform for SBAC, the other federal Common Core test; the fact that Utah's test, from which Florida is paying another $16 million dollars to lease questions, is Read more