News From the Mothership: USDOE's Response to CO Testing Questions

A month ago, I put on my policy explorer cap and attended a Colorado State Board of Education meeting. At that meeting, a panel of CDE employees presented a whole bunch of information on testing in Colorado. More specifically, they went into some depth on the various aspects of local control as they relate to PARCC testing in the state. At the time, the panel was waiting for a response from the mothership (also known as the U.S. Department of Education) on a few of their stickier questions.

Well, that response has finally been beamed back. Notably, the sci-fi analogy doesn’t seem so farfetched when one looks at DOE’s response document—it actually feels like reading a document written in an alien language. Fortunately, Chalkbeat has provided a helpful summary for those who, like me, find legalese to be far more terrifying than extraterrestrials.

After deciphering DOE’s hieroglyphics, the document has some disappointing—albeit unsurprising—answers to the panel’s questions. In brief, Colorado doesn’t have much wiggle room when it comes to testing this year.

I won’t cover everything in the letter, but I will talk about a few of the more interesting snippets. First, the (good) idea of drawing representative samples of students instead of testing every single one has been shot down. As Chalkbeat puts it:

A state “may not assess only a sample of students, even if that sample is representative of students in each LEA (local education agency – jargon for ‘district’) or the state as a whole,” read the letter. (The exception to this is that a separate test can be used for students “with the most significant cognitive disabilities.”)

“That’s a big issue that we get a lot of questions about. Sampling is not allowed,” [Deputy Commissioner Keith] Owen said.

Sorry, statistics. You’re on the bench for now.

What about local districts using their own assessments? While the DOE letter does say that this is a possibility, it proceeds to outline a number of particularly onerous flaming hoops that must be jumped through first. Foremost among them is a requirement that local assessments:

  • Be equivalent to one another and to the State assessments in their content coverage, difficulty, and quality;
  • Have comparable validity and reliability with respect to student subgroups; and
  • Provide unbiased, rational, and consistent determinations of the annual progress of schools and LEAs (Local Education Agencies) in the State.

I don’t know about you, but I translate those requirements roughly to “calling your assessments local assessments is fine as long as they are actually state assessments in practice.”

The letter also indicates that failure to meet federal standards could result in some very serious federal funding consequences. If you’re still imagining DOE as a huge spaceship, it may be helpful to recall the movie Independence Day.

The upshot is that, for now at least, Colorado is stuck. As disappointing as that realization may be for some, it doesn’t mean the conversation is over. It just means it’ll be a longer game than originally anticipated.