September 17, 2013

Dear Chief State School Officers,

Over the past several years, many of you have adopted college- and career-ready content standards in reading/language arts and mathematics to ensure that students in your State have the knowledge and skills necessary to succeed in the twenty-first century workplace.  I applaud you for your efforts.  Many of you are now developing new next generation assessments aligned with those content standards that you will field test in the 2013–2014 school year.  The U.S. Department of Education (Department) is aware that testing students on your State’s current reading/language arts and mathematics assessments at the same time you are field testing these new assessments may create burden on students who must take both tests.  To support this transition to college- and career-ready standards and more rigorous high-quality assessments, on June 18, 2013, Secretary Duncan announced that the Department will consider State requests for flexibility from potentially having to double-test students as you conduct your field tests in the 2013–2014 school year.  This letter is to provide you with additional information regarding that flexibility.

To support a State educational agency (SEA) that is field testing new reading/language arts and mathematics assessments aligned to college- and career-ready standards during the 2013–2014 school year, the Department will consider requests for one-year waivers related to two aspects of these field tests: the first is related to testing (“double-testing flexibility”) and the second is related to accountability determinations based on those assessments (“determination flexibility”).  The “double-testing flexibility” will allow schools that participate in the field test to administer, for purposes of meeting the assessment requirements in section 1111(b)(3) of the Elementary and Secondary Education Act of 1965 (ESEA), as amended, only one full-form reading/language arts and one full-form mathematics assessment in 2013–2014 to any individual student — i.e., either the current State assessment or the full form of a field test.  The “determination flexibility” will allow schools that participate in the field test to retain for the 2014–2015 school year the same Federal accountability determinations as they have for the 2013–2014 school year and to implement in 2014–2015 the same interventions and supports as they implement in 2013–2014.  Together, these constitute the “field-test flexibility.”

Any SEA that has schools that will participate in the field test of a new reading/language arts or mathematics assessment aligned to college- and career-ready standards in the 2013–2014 school year may request this flexibility.  Eligible assessments include, but are not limited to, assessments being developed by the two Race to the Top Assessment consortia — the Partnership for Assessment of Readiness for College and Careers (PARCC) and the Smarter Balanced Assessment Consortium (Smarter Balanced) — as well as new alternate assessments based on alternate academic achievement standards for students with the most significant cognitive disabilities being developed by the two General Supervision Enhancement Grant (GSEG) consortia — Dynamic Learning Maps and the National Center and State Collaborative.  An SEA’s request for field-test flexibility may include either or both types of assessments.  Please know that the field-test flexibility is not limited to an SEA that is participating in a Race to the Top or GSEG assessment consortium or that has received ESEA flexibility. 

An SEA may request both the double-testing and the determination flexibility or only the double-testing flexibility.  What provisions will need to be waived will vary based on the scope of the SEA’s request, whether the SEA has received ESEA flexibility, and, if so, the specific elements of the SEA’s approved request for ESEA flexibility.  To assist you in requesting this field-test flexibility, the Department has posted template waiver requests on its website — one for use by ESEA flexibility SEAs and one for use by non-ESEA flexibility SEAs. 

Eligibility for and Implementation of the Field-Test Flexibility

For purposes of the field-test flexibility, a school “participates in the field test” if at least one full classroom or course section within the school takes the full form of the assessment being field tested in at least one subject area during the 2013–2014 school year.  For example:

• School A is a K-8 school with four classes at each grade level.  One fifth-grade class takes the full form of the mathematics field test.  The other three fifth-grade classes and all of the third-, fourth-, sixth-, seventh-, and eighth-grade classes take the current State mathematics assessment.  All classes in grades 3-8, including the fifth-grade class that takes the mathematics field test, take the current State reading/language arts assessment.
• School A participates in the field test for purposes of the field-test flexibility.
• If the SEA requests and receives the double-testing flexibility, the students in the fifth-grade class who take the full form of the mathematics field test do not need to take the current State mathematics assessment in 2013–2014.
• If the SEA requests and receives the determination flexibility for School A, School A would retain its 2013–2014 Federal accountability designation for the 2014–2015 school year and continue to provide the same supports and interventions in 2014–2015 that it provides in 2013–2014.

• School B is a K-8 school with four classes at each grade level.  One fifth-grade class takes some field-test items from the mathematics field test (but not the full form of the mathematics field test).  The other three fifth-grade classes and all of the third-, fourth-, sixth-, seventh-, and eighth-grade classes take the current State mathematics assessment.  All classes in grades 3-8, including the fifth-grade class that takes some field-test items from the mathematics field test, take the current State reading/language arts assessment.
• School B is not participating in the field test for purposes of the field-test flexibility.
• Even if the SEA requests and receives the double-testing flexibility, the flexibility does not apply to School B.  The students in the fifth-grade class who take some field-test items from the mathematics field test must also take the current State mathematics assessment in 2013–2014.
• The SEA cannot apply the determination flexibility with respect to School B.  School B would receive a new Federal accountability designation based on the 2013–2014 current State assessment results.

Please see the guidance for additional examples.  Note that the definition of what it means to “participate in the field test” set forth above and in the referenced guidance applies only for purposes of determining whether a school is eligible for the field-test flexibility; this definition is not intended to prohibit a school from being a part of the field test simply because it does not meet this definition.

Reporting Requirements Related to the Field-Test Flexibility

A field test is not designed to be a valid and reliable measure of student achievement; rather, it is designed to help the test developers evaluate whether the tests, individual items, and the technology platform work as intended before the first operational administration.  As a result, neither an SEA nor its local educational agencies (LEAs) are required to report field-test results — either individual student results to parents and teachers or on State or local ESEA report cards.  An SEA and its LEAs, however, must continue to do the following in 2013–2014:

• Meet all reporting obligations with respect to the reporting of achievement for students who participate in any current State assessments, i.e., reading/language arts, mathematics, and science.
• Report participation rate for the “all students” group and all subgroups, including the total participation rate, the participation rate on the field test, and the participation rate on the current State assessment.
• Report performance against annual measurable objectives (AMOs) at the SEA and LEA levels and at the school level for any subject for which the school administers the current State assessment to all students in the tested grades.
• Report the Federal accountability designations, as applicable, for each school (e.g., reward, priority, or focus school; school improvement, corrective action, or restructuring).

Other Considerations Related to the Field-Test Flexibility

The Department encourages each SEA to give careful consideration to the implications of requesting the field-test flexibility.  For example, in deciding whether to request the flexibility, an SEA should consider if:

• State law requires that all students annually participate in the State assessments or requires annual accountability determinations based on the results of those assessments.
• Every student must participate in a State assessment in order to meet the State’s promotion, remediation, or graduation requirements.
• State assessment data from every student in a school that receives a School Improvement Grant (SIG) is needed in order to determine the progress of the school and whether to renew the school’s SIG grant.
• It needs State assessment data from every student to implement teacher and principal evaluation and support systems and, in particular, to measure student academic growth for purposes of evaluating teachers and principals.
• It needs State assessment data from every English Learner in order to determine if the student can exit English Learner status.
• It needs State assessment data from every student in order to carry out external evaluations of particular programs.

Please note that these are merely examples.  An SEA should take into account all relevant State and local laws, policies, and needs when determining whether to request the field-test flexibility. Moreover, in 2014–2015, an SEA administering new assessments aligned with college- and career-ready standards in reading/language arts and mathematics must administer those assessments to all students, as required by the ESEA, and the SEA and its LEAs must report on the results of those assessments and use the results in making accountability determinations.

An SEA wishing to request the field-test flexibility should submit its request to the Department by November 22, 2013.  To aid you in requesting this flexibility, the Department is providing guidance along with this letter, as well as templates you may use for submitting your request available at http://www2.ed.gov/policy/elsec/guid/esea-flexibility/index.html.  If you have questions, please email your ESEA flexibility contact at the Department or, if you are not an ESEA flexibility SEA, Carlos Martinez (carlos.martinez@ed.gov).

Please know that the Department greatly appreciates your commitment to improving educational outcomes for all students.  I look forward to our continued partnership in this critical work. 

Sincerely,

/s/

Deborah S. Delisle

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