FL DOE Admits Not enough Research to Support Even FCAT for High Stakes - Must Hold Harmless on FSA

March, 2015

We have reported on the major issues with the validity of the FSA and the great work of Senator Alan Hays (R-Umatilla) and Senator David Simmons (R-Altamonte Springs) to prevent our students, teachers, and schools from being held "accountable" to an invalid test.  One issue that needs further emphasis is the fact that the FCAT had major validity problems as well.

In their attempt to answer Senator Simmons' excellent questions about the alleged validation process of the FSA from the March 4th hearing of the Senate Education Appropriations Subcommittee (transcribed on page 1 HERE), the Department of Education sent a 175 page document.  This document, irrelevant to the discussion of the FSA and the senator's questions, discussed the validity of the previous test, the FCAT 2.0 and the End of Course Exams (EOCs). The report dated December 2014 contains the following very telling paragraph on page 137:

Less strong is the empirical evidence for extrapolation and implication. This is due in part to the absence of criterion studies. Because an ideal criterion for the FCAT 2.0 or EOC assessments probably cannot be found, empirical evidence for the extrapolation argument may need to come from several studies showing convergent validity evidence. Further studies are also needed to verify some implication arguments. This is especially true for the inference that the state's accountability program is making a positive impact on student proficiency and school accountability without causing unintended negative consequences. (Emphasis added)

This is a stunning admission!  In December of 2014, the Department of Education is admitting that the FCAT 2.0 and the EOC's which have been present for several years do not have enough research support to have the citizens and policy makers of Florida be confident in their use to determine "student proficiency" and "school accountability" without "unintended negative consequences."

If that is the case for tests that have been in use for a number of years, how can the state of Florida and the legislature continue with the idea of using the new FSA that was field tested on a completely different population of students and does not have ANY evidence of psychometric review or validation? The only way to prevent massive class action lawsuits is to pass another amendment closer to Senator Hayes original validity amendment and hold harmless ALL of the stakeholders from high stakes decisions third graders, high school students, teachers and schools until the tests are independently validated.  Otherwise, they are likely to face legal action under the Debra P. vs. Turlington case which requires curricular validity before major decisions can be made using tests. It is also the very minimum that legislators should do ethically to prevent grave harm to all of these people and institutions by basing life altering decisions on invalid tests..

Please tell your senators to support strengthening of the validity language of SB 616 as it goes to the floor on Wednesday, April 1st!

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