If so, why is the evidence not available after five years of KPREP testing?
The Bluegrass Institute has discovered a rather extraordinary January 6, 2017 letter from the US Department of Education to Kentucky Commissioner of Education Stephen Pruitt.
This letter says evidence provided by the Kentucky Department of Education only shows that the state’s public school assessments just partially meet requirements of federal education legislation.
The letter lists the following general comments:
- Reading/ language arts (R/LA) and mathematics general assessments in grades 3-8 (Kentucky Performance Rating for Educational Progress (K-PREP)): Partially meets requirements
- R/LA and mathematics general assessments in high school (ACT QualityCore EOC for R/LA and math): Partially meets requirements
- R/LA and mathematics alternate assessments for students with the most significant cognitive disabilities in grades 3-8 and high school (Alternate K-PREP for R/LA and math): Partially meets requirements
The letter continues:
“The partially meets requirements designation for a component means that it does not meet a number of the requirements of the statute and regulations, and Kentucky will need to provide substantial additional information to demonstrate it meets the requirements. The Department expects that Kentucky may not be able to submit all of the required information within one year (underlined emphasis added).”
Keeping in mind that the Kentucky KPREP and End-of-Course tests have been in place since the 2011-12 school term, the letter’s expanded details about the missing evidence are very disturbing.
For example, Under Critical Element 1.2, the US Department of Education says Kentucky needs to provide:
“A description of State stakeholders involved in the development and/or adoption process for the R/LA, mathematics, and science content standards that includes detail on subject-matter expertise, individuals representing English learners (ELs) and students with disabilities.”
This might be really hard to do. Kentucky basically just adopted the Common Core State Standards for English Language Arts and Mathematics (CCSS) at a high level. State stakeholders really had no say in the final decisions about what went into the CCSS. The adoption was made by the Kentucky Board of Education, the Kentucky Educational Professional Standards Board and the Kentucky Council on Postsecondary Education. Subject matter experts were not involved in this widely televised, media event joint meeting of these three boards.
In fact, the adoption of Common Core took place about 3-1/2 months before the final version of the Common Core was even published. It is hard for experts to have looked at something that didn’t even exist at the time of adoption. In fact, the public comment draft of the Common Core didn’t even come out until March 2010, weeks after the three Kentucky boards had already adopted the Common Core, sight unseen.
Under Critical Element 1.5, Kentucky still needs to provide:
“Evidence that the State has procedures in place for ensuring that each student is tested and counted in the calculation of participation rates on each required assessment.”
How’s that? Kentucky can’t provide evidence it really is testing all students with KPREP? Not even after the test has been in used for five testing cycles? That is a real problem.
And, the letter doesn’t stop there. To learn still more, click on the “Read more” link.
There are a bunch of other areas where the Kentucky Department of Education failed to provide sufficient evidence that KPREP tests comply with federal requirements. Some of these include:
- Concerns about actual alignment of the tests to the actual education standards
- Evidence of subject matter expertise on the part of those who created the KPREP test items
- A timeline to address shortcomings that might have been found in alignment studies that might exist
- Evidence that the assessments tap the cognitive processes they should address based on such things as laboratory investigation, expert judgement or other empirical evidence
- Comparisons of KPREP to other tests (one of my favorites because KPREP has comparison issues with NAEP, as I have shown here, here, here and here.
- Evidence that the tests are fair to major student subgroups
- And, perhaps my favorite, Evidence there are test score interpretive guides for educators and parents (anyone seen those????)
Other states besides Kentucky recently received similar letters about their assessment programs, but for Kentucky there is a big difference. While Common Core aligned tests in most states have only been in use for a year or two, Kentucky’s have been on line since the 2011-12 school year. If we don’t have the evidence the US Department of Education wants after all that time, it might not exist at all. But it should have been collected years ago.
And, that’s a real problem.
So, was KPREP properly vetted by real subject matter experts? Is it scored properly? Is it fair? Who really looked at Common Core before we adopted it?
If the US Education Department is still waiting for that information in 2017, we may have some real problems.