22 Pa.Code Chapter 4 Proposed Regulations to Establish Graduation Competency Assessments (GCAs)

Senate Education Committee 
May 14, 2008 Hearing

Good morning, Chairman Rhoades, Chairman Musto and members of the Education Committee.  I am Jim Vaughan, PSEA’s Assistant Executive Director for Government Relations. I am here today to speak on behalf of PSEA’s 185,000 school employees and voice our concerns regarding the State Board of Education’s proposed regulations that would establish high stakes exit exams known as Graduation Competency Assessments or “GCAs”.

This proposal would deny the Class of 2014, those students currently in the sixth grade, the ability to receive a diploma and graduate from high school unless they test “proficient” in mathematics, reading, science and social studies by either a validated local assessment system or a combination of the GCAs and PSSAs.

PSEA stands in opposition to this proposal or any other that seeks to implement yet another high stakes test for our students. The basis of our opposition is fundamental, yet practical as well. From a practical standpoint, there are simply too many questions that remain unanswered for the Commonwealth to move forward and implement such a policy that will have wide ranging social, economic and educational impacts. Fundamentally, the imposition of GCAs and high stakes testing is not sound educational policy, with a wide array of research to confirm this claim.

PSEA is not alone. Twenty-one additional organizations have also signaled their opposition by signing on to a Joint Statement in Opposition to GCAs which outlines the core reasons we collectively oppose the proposal. The signatories represent parents, students, civil rights advocates, advocates for children with disabilities, advocates for gifted students, principals, superintendents, school board members, pupil services administrators, teachers and others.  As you know, it is uncommon for this collection of groups to agree on an issue; this consensus from such a broad cross-section of organizations, representing hundreds of thousands of Pennsylvanians, suggests that the State Board and Department of Education should step back and re-evaluate these proposed regulations.

The proponents of GCAs contend that these tests are necessary if we are to increase student achievement. PSEA agrees with the goal of increasing student achievement but high stakes testing is not the way to accomplish that goal.  In fact, there are numerous other options available that would directly benefit student achievement that that PSEA believes the state would be better served focusing on either implementing or broadening within the K-12 public education system.

There is extensive research that demonstrates significant unintended consequences of high stakes testing that we will assuredly encounter if the GCA proposal is adopted as proposed. For your convenience, PSEA has compiled a sampling of this research and provided it along with this testimony for your review. In sum, the research has found that the negative consequences of high stakes testing include increased dropout rates, harmfully narrowed curriculum, diversion of resources away from education of students and toward more standardized testing of students, and disproportionate harm to some of our most vulnerable students -- students living in poverty, minority students, English language learners, and special needs students.   I would like to call special attention to the attached report of The Children’s Defense Fund, one of the premier national children’s advocacy organizations, which opposes high stakes exams for these very reasons.

For the sake of discourse, I ask that you set aside PSEA’s strong opposition, and take a full spectrum overview of this proposal. In doing so, it is easy to see that this debate must be broadened to increase the likelihood of obtaining the best possible outcomes for our students.

Today’s sixth graders will be the first class required to pass high-stakes exit exams and they, as well as all subsequent classes, will need all of the necessary time, support, and resources to be successful. We cannot wait or fall back on vague promises of implementing needed supports at some future time or in some future budget. Again, setting aside our opposition, from an objective standpoint, I would point out that several conditions must be addressed before an exit exam system could truly be considered for Pennsylvania’s students.

Funding

Late last year the State Board of Education released the much anticipated Costing-Out study, which confirmed what those of us in the education community already knew - public education is currently underfunded by more than $4 billion. This number was derived from determining the adequate amount of resources needed per pupil, including those with unique needs, in order for students to meet the state’s academic standards of 100% proficiency by 2014. Compounding this funding shortfall is the fact that Pennsylvania needs a school funding formula to distribute these dollars more equitably to ensure that students have an equal opportunity to meet the state standards, regardless of the community they live in.   The GCA proposal would allocate millions of dollars annually toward developing and administering the GCAs; PSEA would argue that prior to any such expenditure of funds on high stakes testing, the state must first meet its commitment of adequately and equitably appropriating the resources needed to guarantee student success.

I would be remiss not to acknowledge that the governor has proposed enacting a funding formula over a six year period that would make a $2.6 billion state investment in basic education focused on closing the “adequacy gap” between current spending and the targets identified in the Costing-Out study. PSEA strongly supports the enactment of a permanent funding formula focused on meeting “adequacy” but even if a formula is enacted this spring it will be years before students come through the system at full adequacy funding.

Streamlining Accountability Measures

PSEA is especially concerned with this new graduation requirement since as it has no direct impact on school districts meeting the NCLB-mandated requirements of Adequate Yearly Progress (AYP). These new tests cannot be used to determine the proficiency of 11th graders for determining AYP of high schools. Despite success on GCAs, students will continue to be pressured to score proficient or advanced on the PSSAs. Proponents of the GCAs tout them as an option for students when in reality they are not. The bottom line is that we are adding yet another high stakes test to the detriment of instructional time. Given this reality, Pennsylvania must work to streamline its system by having the GCAs accepted as the measure of AYP under NCLB and its successors.

State-Developed, Model Curricula and Assessments

Admittedly, it is encouraging that the State Board of Education has included the development of model curricula in this proposal. Necessary companions to these model curricula are the materials and the professional development to properly implement them. Many school districts across the Commonwealth have worked hard to align curricula with state standards. Others have struggled to prioritize curricular alignment on a list of many competing challenges. Although no district intentionally denies students an appropriate curriculum, there are some that may lack the capacity to build and deliver a standards-based curriculum that is challenging as well as seamless from one grade to the next.

Denying a diploma to the students in these districts will not change these problems; specific technical assistance from the Department of Education can. For such districts and others, a model curriculum could have many benefits, such as:

• Providing districts with clear, specific guidance concerning appropriate curricular content and level of instruction.
• An easy-to-use tool for districts lacking the capacity to develop such a curriculum on their own.
• Underscoring the intent of state standards and assessments and discouraging rote learning, test drilling, or narrow, depleted curricula.
• Providing PDE with a useful tool to help build instructional capacity within schools and districts while expanding students’ exposure to standards-aligned curricula.

A statewide model assessment system would provide a standard of comparison for those that have model curricula and a benchmark of progress for those that have not.  Yet, even in a system that includes model end-of-course assessments, standards of practice in the field of student assessment insist that these tests be used as only one of many sources of evidence to make graduation and promotion decisions. A statewide model assessment system could reflect high standards of professional practice by including several different types of formative and summative, group and individual, assessment strategies.

Evaluation systems that include multiple sources of evidence are more appropriate than high stakes testing for several reasons:

• Multiple sources of evidence are more valid and reliable than one-size-fits-all systems because they give students more and different opportunities to demonstrate proficiency over time. In general, systems with multiple sources of evidence can be designed to more closely reflect how and what students should learn.
• Systems with multiple sources of evidence can be designed to measure a wide range of standards-based educational performances that do not generally narrow the curriculum to drill and test preparation.
• Multiple sources of evidence can suggest more specifically the areas in which individual students require extra support.

Targeted Auditing and Intervention with Local Assessment Systems

Proponents of the GCAs cite the large number of school districts (461) where the difference between the percent graduating and the percent scoring proficient or better on the PSSA is 20% or more. They cite this number to support severely altering local control over graduation. Yet, the PSSA has never been validated to be used as an exit exam and was never designed as such. Furthermore, the PSSA was not designed as a tool to validate local decisions as to which students should graduate.  The State Board of Education specifically directed HumRRO not to look into the question of whether "the PSSA produce[s] results that support decisions required by Chapter 4 regulations.. Includ[ing] a determination of whether a student has demonstrated proficiency in meeting State academic standards in reading, writing, and mathematics; the award of the State certificate of proficiency or distinction; etc."  (This language is a direct quotation from the HumRRO report, "PSSA Issues and Recommendations", May 2004, Arthur A. Thacker.)  Comparing the number of students who graduate based on local assessments to the number of students who achieve proficiency on the PSSAs tells us nothing.  No analysis or audit of any district's local assessments has been performed to justify any conclusion as to whether the local assessments are a faulty measure of students' mastery of the contact.

On the contrary, the State Board of Education has data that demonstrates it is false to claim that local graduation assessments must be inadequate when they show more students to be proficient than those who scored proficient on the standardized paper-and-pencil PSSAs.   This data too is found in the HumRRO report, which studied students who enrolled in three Pennsylvania universities, and shows that  58.7% of students it tracked,   who scored basic or below on the PSSA tests, took at least the standard level mathematics or English college course. Meaning, most students who supposedly “failed” the PSSA enrolled in non-remedial college courses in the same subject area. There were thousands of students in these three universities who would not have been able to go on to college if we were to believe that a proficient score on the standardized PSSA test is the correct standard for determining who should graduate.

Notwithstanding the former, PSEA believes a more prudent approach, educationally and economically, would be to identify and target districts in need.  There are some school districts that do not have the capacity to develop adequate, aligned assessment systems. However, these districts need to be identified through sound statistical analysis and auditing and assisted with interventions to develop that capacity.  And, prior to any intervention, we believe that both state and local systems would benefit from adjusting the PSSA percentages to account for percent of IEP students and English Language Learners not scoring proficient or advanced; and targeting for assistance school districts where the discrepancy between percent proficient of graduation and percent 11th/12th grade PSSA proficient, after adjustment for these students, is significant.

No one argues that both groups of students present serious challenges to school districts. In 2006-07, these two groups were among the lowest in scoring proficient or advanced of all the disaggregated groups of students. Obviously, they are groups upon which we need to focus more resources and energy; and, yet, implementing the GCA proposal will do nothing but drain they entire system of both.

Additionally, PSEA also believes both systems would benefit from the determination of a statistically sound number that represents the “significant” difference between the percent of students scoring proficient on the PSSA and the percent of students graduating from a school district. This would assist PDE in targeting the districts with the most need.

While the “20% difference” currently used as a baseline may sound significant, it is important to ask whether it is a statistically significant number given that the assessment tools used at the local level are different than the PSSA as an assessment tool, as evidenced by the HumRRO Report. There always will be a difference between the percentages; but it is imperative to know when that difference truly represents the need for intervention. Finally, a reputable third party should be employed to make such a determination.

GCA Implementation Costs

PSEA estimates that the cost of developing and implementing the GCAs has the potential to require hundreds of millions in new expenditures at the state and local level.  Further, we believe that the Regulatory Analysis Form, forwarded along with the proposed regulations, is flawed and missing pertinent data.

The form includes dollar amounts in various savings and costs categories, but no explanation of the basis for those estimates.  The $5 million per GCA for test development ($50 million total for 10 GCAs) is possible, although it appears to represent a low-end estimate in light of the fact that the proposed regulations would require each GCA to be administered three times per year, meaning that three distinct versions of each GCA would need to be developed.

Other cost estimates in the Regulatory Analysis Form are not possibly accurate, however.  Costs to the Regulated Community, which includes school districts, are estimated at “zero”.  First, I refer you to the attached analysis by the Center for Education Policy, “High School Exit Exams:  Costs to Consider”, which states:

“While state policymakers may view exit exams as a low-cost way to raise student achievement, the exam costs -- both apparent and hidden -- are considerable.  The true costs of an exit exam policy often are invisible to state policymakers because the majority of expenses are absorbed by the local school district -- an estimated 96% according to CEP research.”

One example of a cost that school districts would have to bear under this proposal is test administration.  Already, school professional staff divert many hours to protecting security on the PSSAs and proctoring those exams.  School guidance counselors commonly lose days every year to counting out tests, checking test numbers, collecting tests, proctoring exams, etc.   The PSSA is administered just once a year, in stark contrast to the GCAs, which would be administered multiple times each year.  Further, participants who spoke at the State Board roundtables questioned the feasibility of maintaining security on these tests. This equates to more than a fiscal impact; a guidance counselor dedicating days to protecting security on shrink-wrapped standardized exams is losing days of working with and counseling students.  Students can ill afford additional loss of counseling services sacrificed on the altar of more standardized testing.

Another item that appears to have been ignored wholesale during this policy debate is the cost of remediation. PSEA’s Research Division prepared a minimum cost estimate for remediation in just two of the 10 GCAs: the result was $115 million per year if the remediation is provided in class sizes of 25, and $187 million per year if provided in class sizes of 15.  A spreadsheet that shows how those estimates were calculated is attached.  Carrying these estimates out to all 10 GCAs, the minimum cost estimates for remediation are $575 million to $945 million per year.

Even more, our researchers indicate that this is a likely a low end figure due to the specific requirements for highly individualized remediation for students, based on the components of the GCAs on which they do or do not achieve “proficiency”. How these costs will be covered cannot be left to chance, yet there has been no discussion of this aspect of the proposal.

Ultimately, the costs of this remediation model are most likely tremendous, which raises a question as to how the costs to school districts could be estimated at a $0 figure.

How Can We Improve Pennsylvania Student Achievement?

With a high price tag likely attached to this proposal, and a vast array of evidence indicating an abundance of negative consequences, PSEA urges the State Board and the General Assembly to consider further investment in proven, researched based strategies that will improve student achievement. A few of these initiatives include:

• Parental involvement programs.  Any teacher can tell you from personal experience what the researchers have documented through research:  children do better in school when their parents are actively involved in their education.  Although many parents understand the importance of making sure their children do their homework and volunteering in their children’s classrooms, others -- particularly those who themselves grew up in homes where education was not valued -- need help and encouragement to become effectively involved.
• Transition programs.  There are two transition points in a student’s education at which the student is particularly vulnerable:  making the transitions from elementary to middle school, and from middle to high school.  Students who, having trouble making these transitions, disengage from school find themselves on a short path to academic failure and dropping out.  There are programs to help students make these transitions.  They are effective not only at lowering dropout rates and improving academic achievement; they can have collateral positive effects such as reducing teenage drug abuse and teenage pregnancy.
• Smaller class sizes in the early grades.  The evidence is clear:  children in smaller classes in grades kindergarten through four perform better academically not only in those early years -- they do better academically throughout their educational careers.

Early childhood education.  Talk to the kindergarten and first grade teachers in your school districts.  They will tell you about the vast disparity in the readiness of the students who come to their schools.  Some children arrive in kindergarten knowing their alphabet and numbers, even reading.  Other children arrive in the same kindergarten classes unable to even name the colors red, blue and brown; they have not even begun to learn their alphabet and numbers.    When children start school so far behind their peers, they are at a serious academic disadvantage that is more than difficult to overcome.  Many never catch up.  Compounding their difficulties is the fact that many of those children are coping with other serious problems such as poverty.

Most importantly, the state could fund school districts at their adequacy targets, enabling administrators and educators to implement these initiatives that are proven to help improve student achievement. All of these steps can help to further elevate Pennsylvania’s status among the state’s as a leader in educational opportunity and close the achievement gap that is present in too many of our schools. PSEA commits to supporting these efforts.  Together, we can find ways to support our children to achieve, without unfairly jeopardizing their futures through unwarranted denial of high school diplomas.

Thank you for conducting this hearing today, and providing PSEA the opportunity to testify before you. I look forward to your questions.