April 2017 Memo ADAD Item 01 Attachment 1

April 28, 2017

Betsy DeVos, Secretary of Education
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202

Dear Secretary DeVos:

The adoption of the California Next Generation Science Standards (CA NGSS) in September 2013 initiated the complete overhaul of science education in California to replace the former science tests, California Standards Test (CST) and the California Modified Assessment (CMA), with a CA NGSS-aligned assessment. In the 2016-17 and the 2017-18 school years (SYs), California continues to develop and implement a new, computer-based general assessment for science that is aligned with the CA NGSS. This is done with the intent of conducting full-census pilot and field testing of all eligible California students. This plan is in the best interest of all our students, teachers, and schools statewide and is consistent with the successful implementation of Smarter Balanced Summative Assessments and California Alternate Assessments for English language arts/literacy and mathematics.

As described in Section 8401 of the Every Student Succeeds Act (ESSA), the California Department of Education (COE) and the State Board of Education (SBE) are requesting a one-year waiver which will allow California to not double test or report student test scores for the 2016-17 SY during the administration of the full-census pilot of the California Science Test (CAST). The approval of the waiver request will allow California to:

• Pilot the new CA NGSS-aligned assessment, the CAST, without creating a double testing situation for all eligible students enrolled in grades five and eight and once in high school.
• Suspend the former science tests, the CST and the CMA, which are based on outdated science standards, and provide a signal to California educators to transition their daily classroom instruction from the previous science content standards to the new CA NGSS.
• Temporarily suspend the required reporting of individual student scores for the 2016-17 SY for the CAST pilot. California still intends to provide student participation rates at school-, district-, and county-levels for the pilot test to the U.S. Department of Education (ED).

ESSA Section 1204(e)(2)(A) requires a state educational agency to apply the same academic achievement standards, and to use the same academic assessments, for all public school children in the state. California requests a waiver of this requirement so that any eligible student enrolled in a California public school will be permitted to take only the CAST pilot as the science assessment. The waiver will ensure that students already receiving instruction aligned with the new CA NGSS will not lose valuable instruction time in preparation for tests aligned with outdated science standards-tests that would yield results that do not have any educational benefit for students, teachers, or parents. It will also reduce the potential stress and psychological impact of extended standardized testing on students. Allowing California schools to avoid the administration of double science testing will provide students with the opportunity to become familiar with the new computer-based assessment in science with no undue concerns about immediate academic consequence. Students will experience the new CA NGSS-aligned item types and functionality and will benefit from engaging with the new items aligned with the CA NGSS.

In addition to validity and fairness, the application of testing-industry standards and practices to any new assessment system through pilot and field testing ensures the reliability of the assessments and improves the quality and meaning of their results. The sophistication and complexity of the CA NGSS requires California to develop assessments that are not only aligned with the CA NGSS but also meet the requirements set forth by the American Educational Research Association, the American Psychological Association, and the National Council on Measurement in Education in the Standards for Educational and Psychological Testing (Standards). As directed in Section 3 of the Standards, all aspects of test development, including test design, validation, development, administration, and scoring should be considered to ensure fairness in testing. In accordance with these provisions, the COE will document all activities related to the development of the science assessments and provide all necessary documentation for peer review. Furthermore, California's plan for the CAST test development will:

• Provide students, schools, and districts with the opportunity to gain exposure to the CAST.
• Meet the federally-required 95 percent participation rate for the state in grades five and eight and in once high school.
• Provide high-quality test items and valuable feedback on the item types and functionality for the CAST.

The timeline for the implementation of CAST is shown below:

California hereby assures that if it is granted the requested waiver:

• California and its local educational agencies (LEAs) will ensure that all eligible students will participate in the CAST pilot and field test.
• California will properly notify all LEAs and schools of their required participation in the pilot and field tests.
• California will ensure that parents and guardians of students in each school participating in the pilot of the CAST will be notified of the school's participation in the pilot and field test by means in compliance with Sections 8401 (b)(4)(A)(i) and (iii) of the Elementary and Secondary Education Act (ESEA), as amended by ESSA.
• California plans to provide training tests such that all stakeholders will have access to the sample test items, as well as expose them to the complex nature of the CA NGSS-aligned items to support teaching and learning and prepare them for the new assessments, in accordance with Sections 8401 (b)(1 )(C) and (F) of the ESEA, as amended by ESSA.
• California will provide student-level raw scores and the corresponding percent correct to LEAs for distribution to parents and guardians, with detailed guidance on how to interpret the raw scores and percent correct and an explanation that this score will not impact a student's or school's academic standing.
• California will provide the aggregated results from the CAST field test at the state-, county-, district-, and school-levels by student groups on the COE public Web site.

With California's move toward full implementation of the CAST, the COE hopes the ED will continue to support our commitment to improve educational opportunities for all of California's students, just as the ED did in 2013 during the State's transition to computer-based assessments aligned with the Common Core State Standards. As a result of the collaborative efforts between the ED and the COE in 2013, there were multiple instances of positive media exposure for the country's most populous state, highlighting the high participation rates and widespread public support for the new standards and assessments.

Please direct questions regarding this request to Keric Ashley, Deputy Superintendent, District, School, and Innovation Branch, by phone at 916-319-0637 or by e-mail at kashley@cde.ca.gov. Thank you for your consideration.

TT/MK:cc