On July 29th, the U.S. Department of Education released guidance to clarify the process states must undertake to request a waiver from certain Elementary and Secondary Education Act (ESEA) requirements.
This announcement elevates state leadership at a moment of increasing interest in student-centered learning approaches that improve student engagement, close learning gaps and strengthen workforce readiness in the rapidly shifting era of artificial intelligence (AI). As teaching and learning shifts, so too must our nation’s assessment and accountability systems. While federal assessment grant funding and the Innovative Assessment Demonstration Authority (IADA) helped some states make progress, much work is needed to develop and scale improvements to these systems as well as pilot new approaches. Waivers of certain ESEA requirements could expedite this progress if states work together to pilot and study compelling ideas.
The following resource offers state leaders six compelling ideas of targeted waiver requests that address some of the most common areas of misalignment between federal policy and student-centered learning. States should consider these ideas, among others, as they innovate responsibly to make necessary improvements to assessment and accountability systems.
Accountability
Idea 1: Incorporate school-level inputs
- Waiver request: Allow states to incorporate building-level inputs in addition to student-level outputs into current ESEA accountability systems to strengthen school improvement.
- Why a waiver is needed: ESEA requires student-level disaggregation of all accountability indicators. This is an important safeguard to spotlight performance of individual student groups. However, this protection inadvertently prevents the inclusion of valuable building-level indicators that are critical to student success.
- Justification: Building-level inputs, such as evidence of expanded and rigorous course offerings (e.g., apprenticeships, early college program, work-based learning), measures of student satisfaction and student engagement and teacher retention data are valuable measures for evaluating school quality. Caregivers and community members crave access to this holistic information as they share responsibility for partnering with schools to improve each student’s opportunity to learn. A strong waiver request in this area would emphasize the integration of input and output data to drive informed accountability and school improvement conversations.
Idea 2: Utilize local indicators
- Waiver request: Permit states to include local indicators that may differ from district to district as part of their school quality and student success indicators (i.e. the fifth indicator) in the state’s accountability system.
- Why a waiver is needed: ESEA requires all indicators in a state’s accountability system to be the same statewide. This prevents the inclusion of local indicators that may be different from one district to the next.
- Justification: Communities are on the front lines of school improvement with firsthand knowledge of the data that is meaningful and necessary to strengthen student success. Many school districts are now partnering with their communities to design local accountability systems that incorporate data responsive to community needs, such as attainment of credentials with local businesses, the number of community partnerships that drive learning, teacher retention/shortage data and evidence of rigorous coursework in schools. Engagement with this data increases buy-in and ensures the community shares accountability for the design and execution of solutions.
Idea 3: Elevate durable skills
- Waiver request: Allow states with a framework of higher-order thinking skills to incorporate a measure of those skills in the state’s academic indicators for the state’s accountability system so long as the state can demonstrate how it will do so in an integrated way with the assessment of content knowledge.
- Why a waiver is needed: ESEA requires states to assign “substantial” weight to each of the academic achievement indicators which include academic proficiency, another academic indicator for elementary schools, graduation rate and progress on English language proficiency. Additionally, states must ensure these indicators, in aggregate, carry “much greater weight” than the other indicators in the system classified as school quality or student success measures.
- Justification: Academic proficiency is a critically important measure, but in isolation, it will not ensure students are ready for the jobs of today and tomorrow. The increasing integration of AI and automation has elevated the need for human-centered capabilities such as creativity, critical thinking and problem-solving, and has elevated the need for workers to upskill and adapt to remain relevant. America Succeeds’ recent analysis of 80 million job postings revealed that seven of the 10 most-requested skills are durable skills – interdisciplinary skills that transcend content areas. In response, twenty states have developed statewide portraits of a graduate to articulate the skills students need for success in addition to academic content knowledge. A waiver related to durable skills would enable states to value both academics and skills in alignment with workforce demands. This would help districts and schools align curriculum, instruction and assessment to this holistic picture of student success.
Assessments
Idea 4: Assess priority standards
- Waiver request: Permit states to assess a set of priority standards – the most critical knowledge and skills within a subject area – to determine academic proficiency so long as the state has a plan for comprehensive coverage of the state’s standards in its instructional system.
- Why a waiver is needed: Under ESEA, states are required to test the “full depth and breadth” of the state’s K-12 academic standards. To satisfy this requirement, state assessments must go through a federal peer review process in which alignment studies provide evidence of standards coverage. While a state could reduce its state standards to a set of priority standards and remain in compliance with federal law, that process would address more granular standards as components of the broader instructional system.
- Justification: The federal requirement to assess the full breadth and depth of the standards on math, English language arts and science assessments necessitates that the tests have enough questions to confidently determine student performance on each standard. This results in lengthy tests and a disincentive to include more time-intensive items that aim to capture deeper levels of knowledge and skill. Permitting states to focus assessment on priority standards would preserve access to data to inform policy, resource and professional development decisions while also giving states more leeway to address concerns about test quality and length.
Idea 5: Sample student mastery of academic content
- Waiver request: Allow states to use a content-based sampling approach for K-12 assessments where children take part of a full exam, but collective results still produce reliable and comparable data for state accountability systems.
- Why a waiver is needed: Under ESEA, states must assess 95% of students on the state assessments which must cover the full breadth and depth of the content standards. Additionally, each student in the state must take the same assessment.
- Justification: The United States already uses a sampling approach for the National Assessment of Education Progress (NAEP) assessment, which is widely regarded as a credible measure of student achievement. A content-sampling approach would ensure all students are assessed each year, but assessment time would be reduced as each student is administered a part of the exam. Psychometric modeling would enable results to present a representative sample of student performance on all content areas for all students and each subgroup of students to inform policy and resource decisions. Additionally, improvements in benchmark and formative testing are providing parents with access to real-time score reporting that is useful for driving instruction. A balanced assessment system relies heavily on benchmark and formative assessments to drive instruction, with right-sized federal assessments to evaluate system quality.
Idea 6: Pilot deeper learning assessments
- Waiver request: Permit a state to pilot a deeper learning assessment without requiring double testing of students participating in the pilot. Permit the state to use results from the deeper learning assessment in the state’s accountability system and study that assessment before expanding.
- Why a waiver is needed: Under ESEA, states must administer the same assessment to each student in the state to ensure comparable data for use in the state’s accountability system. This requirement limits states from utilizing assessment models that promote deeper learning (e.g. student-driven performance assessment). While states may apply for the Innovative Assessment Demonstration Authority (IADA), states have found program requirements especially challenging including the requirement to demonstrate comparability of the pilot assessment to the traditional assessment despite the goal of building a better measurement instrument.
- Justification: States have struggled to pilot and evaluate promising assessment approaches in math, English language arts and science. The idea of administering simultaneous assessments in a district to develop proof of concept is costly and politically challenging, as stakeholders increasingly protest the amount of instructional time lost to testing. Even under IADA, a program created to spur innovation, districts must double test to establish comparability of the assessments before using the pilot assessment for accountability. Furthermore, innovative districts face challenges in meeting IADA’s requirement to demonstrate comparability to traditional assessments, as more standardized formats are often perceived as hindering deeper learning. A waiver to simplify this process would create a viable pathway to test new ideas that drive deeper learning without placing an undue burden on districts and schools.
