Letter Report to the U.S. Department of Education on the Race to the Top Fund (2009) / Chapter Skim
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Letter Report
Letter Report
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Secretary: This letter offers comments concerning the Department's Proposed Regulations on the Race to the Top (RTT) fund of the American Recovery and Reinvestment Act of 2009 (74 Fed.
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Tests often play an important role in evaluating educational innovations, but an evaluation requires much more than tests alone. A rigorous evaluation plan typically involves implementation and outcome data that need to be collected throughout the course of a project.
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Throughout, the Departments' specific proposed language is in italics, with the page numbers taken from the notice in the Federal Register. RELIANCE ON TESTING AND ASSESSMENT IN EDUCATIONAL REFORM The proposed regulations rely heavily on the use of testing and assessment both to drive and to measure education reform.
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Development of an appropriate system of multiple indicators involves thinking about the objectives of the system and the nature of the different information that different indicators can provide. Such a system should be constructed from a careful consideration of the complementary information that is provided by different measures.3 SPECIFIC AREAS OF CONCERN Need for States to Include Evaluations in their RTT Program Activities The Department specifically requests comment on whether states should be required to conduct evaluations of their support programs and indicates that the final notice for RTT applications will specify the nature of the evaluations that will be required: The State and its participating LEAs must use funds under this program to participate in a national evaluation of the program, if the Department chooses to conduct one.
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The RTT fund offers an analogous opportunity in education: a careful choice of evaluation requirements can result in substantial opportunities for research and learning about the educational innovations that are supported. BOTA's discussion on evaluation focused on six key principles: (1)
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When possible, summative evaluations should be designed in ways that provide generalizable knowledge to guide future education reform. Independent Evaluators Evaluations should employ independent and well-qualified external evaluators.
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The availability of NAEP does not in any way obviate the need to plan rigorous evaluations -- at national, state, and local levels -- that are appropriately designed to assess the implementation and outcomes of RTT initiatives. These concerns do not diminish the importance of NAEP as an independent measure of educational progress at the state and national levels.
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37809) The most prominent way to measure student growth involves "value added" approaches that use results from earlier tests, as well as other information, to adjust new test scores for preexisting differences across students.
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The considerable majority of experts at the workshop cautioned that although VAM approaches seem promising, particularly as an additional way to evaluate teachers, there is little scientific consensus about the many technical issues that have been raised about the techniques and their use. Prominent testing expert Robert Linn concluded in his workshop paper: "As with any effort to isolate causal effects from observational data when random assignment is not feasible, there are reasons to question the ability of value-added methods to achieve the goal of determining the value added by a particular teacher, school, or educational program" (Linn, 2008, p.
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Even in pilot projects, VAM estimates of teacher effectiveness that are based on data for a single class of students should not used to make operational decisions because such estimates are far too unstable to be considered fair or reliable. Use of Data to Improve Instruction We applaud the Department's support of "instructional improvement systems" that include the use of assessments, as well as student work, to help teachers focus instruction and evaluate the success of their instructional efforts.
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The use of high-stakes tests already leads to concerns about narrowing the curriculum towards the knowledge and skills that are easy to assess on such tests; it is critical that the choice of assessments for use in instructional improvement systems not reinforce the same kind of narrowing. In applying its criteria to evaluate state proposals for RTT funds, BOTA urges the Department to clarify that assessments that simply reproduce the formats of large-scale, highstakes, summative tests are not sufficient for instructional improvement systems.
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Although BOTA supports the value of a joint development effort toward common assessments, we want to stress that the requirements are quite high for producing common assessments that would truly allow comparisons in student achievement across states in the same way that NAEP currently does. BOTA's previous work on potential approaches to developing common standards and assessments (Uncommon Measures, 1999; Embedding Questions, 1999)
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The aspiration for higher quality in standards and assessments is one that BOTA members share, and over the coming months, BOTA will be conducting a series of workshops on improving state assessment systems, with particular attention to the opportunities offered by the current interest in moving toward common assessments and by the ARRA funding set aside for this purpose. Challenges in Creating Longitudinal Data Systems We applaud the Department's desire to support statewide longitudinal data systems.
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Comments on Race to the Top Proposal Attachment A Membership of the Board on Testing and Assessment Attachment B Reviewer Acknowledgments Attachment C Selected Reports of the Board on Testing and Assessment Attachment D Key Professional and Technical Standards Documents Relevant to the Use of Educational Assessments Attachment E References 14
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