Letter to ISBE re PARCC misinformation: 2/5/15

We have serious concerns about the threatening and misleading letter that you sent to Illinois school districts on January 30, 2015. You have not listened to the voices of administrators, teachers and parents across the state who have asked you to seek a one-year waiver for the PARCC.

5 February 2015                     

Dr. Christopher Koch, State Superintendent of Education

James Meeks, Board Chair

Illinois State Board of Education

100 N 1st ST

Springfield, IL 62777

Dear Superintendent Koch and Chairman Meeks:

We have serious concerns about the threatening and misleading letter that you sent to Illinois school districts on January 30, 2015. You have not listened to the voices of administrators, teachers and parents across the state who have asked you to seek a one-year waiver for the PARCC. We have also learned that some districts are receiving approval for using all paper-pencil testing due to tech issues discovered during field testing. This information needs to be made public to taxpayers and stakeholders. In addition:

1) The letter misleadingly threatens dire consequences if all students do not take the Partnership for Assessment of Readiness for College and Careers (PARCC) assessments. No state has ever lost Title I funds for deliberately breaching the assessment requirements of the federal Elementary and Secondary Education Act (ESEA) sec. 1111(b)(3)(C). At most, the U.S. Department of Education (ED) has prevented state agencies from keeping a small part of the Title I funds at the state level; there has never been a net loss of funds.

For example, California had permitted half of its 8th graders (219,000 students) to take a test aligned to 6-7th grade content standards for several years. As a consequence, ED required that California’s department of education had to pass on 6% of its Title I administrative funds directly to the districts. Last year, California unilaterally administered the Smarter Balanced assessment as a field test, without any reporting at the student or school level and with 5% of the students taking an exam in either math or English, not both. ED granted them a waiver. This year, Massachusetts unilaterally allowed its districts to choose between the PARCC and the MA assessment  for which they received the sanction of a letter of reprimand.

2) You threaten to create the very consequence you hope to avoid: the loss of Title I and other funds to school districts. We fail to see how a limited assessment of students with a test of dubious quality would imperil their education, compared to the denial of multiple funds. This is cutting off one’s nose to spite one’s face.

3) High schools giving the PARCC will not be testing all students in English and math in any single grade. Instead, students will take the assessment based on what courses they completed, which means that some students will not take any assessment. In addition, high school districts were given the choice of which (partial) cohort of students to test this year---either those completing first year, second year or third year coursework; and so there will be no uniformity across the state in which year will be tested this spring. There is no provision in the ESEA testing requirements or Illinois’ flexibility waiver for either of these modifications. Your position appears to be that the federal law cannot be violated except when you want to violate it. Why do you get to pick and choose which part of the law you will comply with?

4) The PARCC has not been shown to be valid and reliable.  As stated above, some districts are using  pencil-paper versions due to technical glitches discovered during field testing. Other students are taking the electronic version on a variety of devices, with different screen-sizes and resolutions. Without validity studies completed, the validity of the test across different modes and platforms (especially for different student subgroups) is uncertain. As such, we question your commitment  to "implementing valid and reliable performance measures for our schools" and the legality of using the PARCC in its current forms as an accountability assessment under IL School Code sec. 2-3.64a-5(i)  and ESEA Sec. 1111(b)(3)(C)(iii), which require that all assessments be shown to be valid and reliable.

5) The State Board of Education (ISBE) could have pursued a one-year waiver to postpone the PARCC assessment but refused, despite petitions from the public, school districts and legislators asking you to do so. We do not understand why you wrote the U.S. Department of Education (ED) in November 2014 to ask what current law stated -- something we already knew -- rather than seeking reasonable, temporary changes to the Illinois test schedule like those that were granted in California last year.

6) It is unclear how ISBE will comply with the ESEA requirements for grade-span testing of students in science. No students will be assessed in science this year. This means that unless next year’s 5th graders and 12th graders take science exams, which they have never previously done, Illinois will violate the federal requirement that such students be assessed in science between grades 3-5 and 10-12. Are we to believe that in only a year, Illinois will be able to commission, design, and field-test a valid and reliable science assessment for 5th and 12th graders?  

7) ISBE has violated the terms of state testing law in the past. From 2011 to 2013, ISBE failed to assess students in grades 3, 5, 6, and 8 in writing despite state law requiring it to do so. ISBE argued then that the General Assembly did not appropriate enough money.

We call on you to retract the threats you’ve made to districts, produce validity studies for PARCC, and seek the one-year testing waiver that parents and districts have asked for.  


Wendy Katten

Executive Director

on behalf of Raise Your Hand