Closing the gaps in opportunity
and achievement, pre-k through
college.
July 8, 2016
Dr. Michael Kirst, President
California State Board of Education
1430 N Street, Suite #5111
Sacramento, CA 95814
Via Email Only ([email protected])
Re:
SBE July 2016 Agenda Item #2 on Developing a New Accountability System
Dear President Kirst:
As a research, policy, and advocacy organization committed to closing opportunity and achievement gaps for California’s
low-income students and students of color, The Education Trust–West writes to share our comments on the latest
developments in the redesign of the California’s accountability system.
We commend the progress State Board of Education (SBE) and California Department of Education (CDE) staff have
made in several areas. We appreciate the May 2016 adoption of state indicators and staff’s current recommendation to add
a college and career indicator. We are also heartened that staff have acknowledged that parents and the broader public must
be among the key audiences for and users of the rubrics.
However, we still have major concerns and questions about how these many indicators and data points fit together into a
cohesive local, state, and federal accountability system. Indeed, we are concerned that while the state has made progress in
selecting strong indicators and identifying a path toward gathering additional data aligned with the state priorities, staff are
not yet satisfactorily articulating how the evaluation rubrics connect to the larger accountability system. Without knowing
how these data relate to larger decisions about school identification, technical assistance, and intervention, it is difficult for
stakeholders to offer meaningful feedback on the rubrics.
For example, we still want to know:
 How will the state use this data to meaningfully differentiate schools from one another, as required by ESSA? How
will subgroup performance factor into that system of differentiation?
 How will the state use this data to identify schools and districts that will receive support and assistance, and how
and where will the state notify the public of which schools and districts those are?
 At what point and under what conditions will schools and districts be referred for intervention? What assurances
do we have that if subgroups continue to languish far below state targets, year after year, action will be taken?
Given that context and larger concern, we still have specific points of feedback we wish to offer:
1. Ensure that goals are ambitious and long-term, as required by the Every Student Succeeds Act (ESSA).
According to the item, the Technical Design Group has recommended that the second highest performance
category (green) serve as the state’s long-term goal, as required by ESSA. CDE staff presented recommended cut
points at the June California Practitioners Advisory Group meeting, and these are to be finalized by the September
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board meeting. We do not believe all of the proposed “green” cut-points are sufficiently ambitious. For instance,
the recommended goal for college and career readiness is that 50 percent of students achieve that standard. The
recommended goal for elementary and middle school math is that 55 percent of students will achieve proficiency.
We believe that the state should be setting and communicating higher, more ambitious goals for both of these
measures, and others. Further, we are unclear how these goals are long-term in nature. How long do schools and
districts have to reach the state goal? What are the consequences of a school or a subgroup not meeting the goal in
a given amount of time? We urge the state to explain these decisions concurrent with the adoption of the
evaluation rubrics, not as a separate set of decisions that will occur later, as the state is developing its ESSA plan.
2. Explain how the top-level display connects to the broader system of accountability. The top-level display is
heading in the right direction, but it still needs to be strengthened to ensure that we achieve transparency and that
we hold schools and districts fully accountable for equitable results. The proposed Equity Report is good, but flags
for subgroup underperformance, on their own, are insufficient. It may be easy for district and school leaders to
ignore these flags if the state does not connect the dots between the Equity Report and decisions it will make about
school identification, technical assistance, and intervention. As we develop the next components of our
accountability system, including meaningful differentiation of schools and identification of schools needing
assistance, how will these subgroup flags count? If a school can still achieve a top rating, color, designation, or
categorization while it has flags for subgroup underperformance, these flags will likely be disregarded. Once
again, we respectfully ask for an explanation of how the evaluation rubric display connects to these broader
decisions before the evaluation rubrics are adopted.
3. Keep 11th grade test scores in the English language arts and math assessment indicators. We strongly
disagree with the recommendation to remove grade 11 scores from the state indicator for test scores. We feel the
11th grade scores must be included, even if they are also included in the College and Career Indicator. It is
critically important that we continue to report academic achievement at least once in high school for every student.
This is required under ESSA. And while draft federal regulations prohibit states from using the same indicator
more than once, we believe the intent of this language is to prevent states from narrowing or diluting
accountability by using the same indicators multiple times. We do not believe including 11th grade scores as a
component of two separate indicators, one of which includes multiple measures (the College and Career Indicator),
would do that. Further, our read of the draft regulations is that they do not prohibit states from creating multiple
and different indicators from the same instrument (in this case, two different ways of using data from the 11th
grade SBAC). To the extent the state feels strongly that 11th grade scores may only be included once, we believe it
is more important to include those results in the academic achievement measure than in the College and Career
Indicator.
4. Continue to improve the College and Career Indicator: We strongly support the recommendation that the SBE
adopt a College and Career Indicator, and we are pleased to see this development. But we urge members to adopt
the CCI in concept while asking staff to continue to work through the details. We reject the proposal to count
Career Technical Education pathway completion alone as “well prepared” for college and career. We also strongly
believe the state must elevate the importance of A-G and have A-G completion (with a C or better) count in the
“well prepared” tier. In addition, we encourage staff to give more consideration to how the tiers relate to the
accountability framework. If schools and districts only receive credit for getting students to the “prepared” tier,
what incentive is there for them to aim for the “well prepared” tier?
5. Continue to refine the Model Practices. We greatly appreciate the statements of model practices; these will be
helpful to Local Educational Agencies as they analyze their progress. We recommend that in Priority 2 (State
Standards), staff include links to all standards, not just Common Core English language arts and math standards.
We recommend that Priority 4 (Pupil Achievement) be expanded to include model practices in science. We
recommend that for the “A-G, AP, Participation Rates” indicator, staff add a point about the importance of
communicating with families regarding placement and progress in A-G courses, and also a point about the
importance of monitoring data for D and F grades that will not count toward UC/CSU eligibility.
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We know you are working through many complex policy considerations and technical details, and we recognize that this is
a massive undertaking. We offer these recommendations in the spirit of collaboration and with the belief that we are
stronger working together. Thank you for your continued engagement of stakeholders, including the equity community.
We stand ready to continue to do this work with you to ensure that all students are thriving in our schools.
Sincerely,
Ryan J. Smith
Executive Director
The Education Trust—West
cc:
Members, California State Board of Education
Karen Stapf Walters, Executive Director, California State Board of Education
Judy Cias, Chief Counsel, California State Board of Education
Dave Sapp, Deputy Policy Director and Assistant Legal Counsel, California State Board of Education
Nancy Brownell, Senior Fellow, Local Control and Accountability
Michelle Magyar, Project Manager, Local Control Funding Formula
Jeff Bell, Program Budget Manager, Department of Finance
Cathy McBride, Deputy Legislative Secretary, Governor’s Office
Jannelle Kubinec, Director of National, State and Special Projects, WestEd
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