Friday, August 10, 2007


August 7, 2007

The Honorable George Miller

Chair, Committee on Education and Labor

United States House of Representatives

2205 Rayburn House Office Building

Washington, DC 20515

The Honorable Edward Kennedy, Chair

Senate Committee on Health, Education, Labor and Pensions

317 Russell Senate Office Building

Washington, DC 20510

The Honorable Howard P. McKeon

Ranking Member, Committee on Education

2351 Rayburn House Office Building

Washington, DC 20515

The Honorable Michael Enzi

Ranking Member, Senate HELP Committee

379A Russell Senate Office Building

Washington, DC 20510

Dear Sirs:

We are writing to express our strong support for a comprehensive model of accountability in the re-authorization of ESEA that will include multiple measures which can focus schools both on developing high quality teaching and learning and on educating all students to graduation. We applaud the Congress’s commitment to address the inadequate education received by poor and minority children, which led to the enactment of No Child Left Behind. We share the goal of real progress on educational outcomes, and we see accountability as a valuable tool. We also believe Congress can improve the law to better foster genuine educational progress and to hold schools and school systems accountable for a broader array of important educational outcomes. The benefits can be increased and the harms dramatically reduced with a relatively simple and feasible system of multiple indicators.

Therefore, we are very pleased that you and the Committees on Education are considering including the use of multiple measures of student progress for accountability decisions in the reauthorization of the Elementary and Secondary Education Act. We believe that the accountability provisions must include a system of multiple assessments of learning, which can help schools focus on assessing the full range of standards and skills appropriately, and multiple indicators of school performance, which emphasize the importance of keeping students in school and educating them to graduation.

Ideally, schools should be held accountable for student growth along all parts of the achievement continuum. They should demonstrate continuous progress on an index of indicators comprised of multiple academic assessments, plus measures of student progress through school, such as graduation and grade promotion rates. Together, these components can support a comprehensive and educationally beneficial accountability system.

If education is to improve in the United States, schools must be assessed in ways that produce high-quality learning and that create incentives to keep students in school. A number of studies have found that an exclusive emphasis on (primarily multiple-choice) standardized test scores has narrowed the curriculum.

The most recent reports of the Center for Education Policy (CEP) and the National Center for Education Statistics (May 2007 Stats in Brief) confirm sizeable drops in time dedicated to areas other than reading and math, including science, history,art, and physical education. The CEP als found that districts are more tightly aligning their instruction to this limited format as well as content of state tests. While these tests are one useful indicator of achievement, studies document that they often overemphasize low-level learning. As reporter Thomas Toch recently stated, "The problem is that these dumbed-down tests encourage teachers to make the same low-level skills the priority in their classrooms, at the expense of the higher standards that the federal law has sought to promote." To succeed in college, employment and life in general, students need critical thinking and problem solving skills that the tests fail to measure, and they need a complete curriculum.

The law's every-grade every-year testing requirement has discouraged the use of assessments of higher order thinking that motivate ambitious intellectual work and leverage stronger teaching and learning, but take more time and resources to score. These kinds of assessments – which include written essays, oral examinations, research papers, open-ended problems, and other performance assessments – are routinely used in high-achieving European and Asian systems that emphasize higher-order knowledge and skills. Some of our nation’s highest performing districts and states have given up the high-quality assessments they created in the 1990s, because the law currently acts as a disincentive to encourage their continued use.

Perhaps the most troubling unintended consequence of NCLB has been that the law creates incentives for schools to boost scores by pushing low-scoring students out of school. The very important goal of graduating more of our students has simply not been implemented, and the accountability provisions actually reward schools with high dropout rates. Push-out incentives and the narrowed curriculum are especially severe for students with disabilities, English language learners, students of color and economically disadvantaged students. Recent reports of the Public Education Network confirm that parents, students and other community members are concerned about the over-reliance on test scores for evaluating students and schools.

A number of recent studies have confirmed that this over-reliance has been associated with grade retention and other school actions that exacerbate dropout rates and student exclusion from school, especially for low-income students of color. This creates the perverse outcome that efforts to raise standards are resulting in fewer students receiving an education. A central part of a solution to these problems is to employ multiple forms of assessment and multiple indicators, while retaining the powerful tools of publicly available assessment information and the critically important focus on equity. A multiple measures approach can help

schools and districts improve student outcomes more effectively because: 1. The use of multiple measures ensures that attention will be given to a comprehensive academic program and a more complete array of important learning outcomes;

2. A multiple measures approach can incorporate assessments that evaluate the full range of standards, including those addressing higher-order thinking and performance skills;

3. Multiple measures provide accountability checks and balances so that emphasizing one measure does not come at the expense of others (e.g. boosting test scores by excluding students from school), but they can give greater emphasis to priority areas; and

4. A multiple measures index can provide schools and districts with incentives to attend to the progress of students at every point on the achievement spectrum, including those who initially score far below or above the test score cut point labeled “proficient.” It can encourage schools to focus on the needs of low-scoring students, students with disabilities, and ELL students, using assessments that measure gains from wherever students begin and helping them achieve growth.

One of the central concepts of NCLB’s approach is that schools and systems will organize their efforts around the measures for which they are held accountable. Because focusing exclusively on a single indicator is both partial and problematic, the concept of multiple measures is routinely used by policymakers to make critical decisions about such matters as employment and economic forecasting (e.g., the Dow Jones Index or the GNP), as well as admissions to college. Successful businesses use a “dashboard” set of indicators to evaluate their health and progress, aware that no single measure is sufficient to understand or guide their operations. Business leaders understand that efforts to maximize short-term profits alone could lead to behaviors that undermine the long-term health of the enterprise. Similarly, use of a single measure to guide education can create unintended negative consequences or fail to focus schools on doing those things that can improve their long-term health and the education of their students. Indeed, the measurement community's Standards for Educational and Psychological Testing mandates the use of multiple sources of evidence for major decisions. NCLB calls for multiple measures of student performance, and some states have developed systems that incorporate such measures, but implementation of the law has not promoted their use for evaluating school progress.

Multiple indicators can counter the problems caused by over-reliance on single measures. Multiple forms of assessment include traditional statewide tests as well as other assessments, developed and used locally or statewide, that include a broader range of formats, such as writing samples, research projects, and science investigations, as well as collections of student work over time. These can be scored reliably according to common standards and can inform instruction in order to improve teaching and learning. Such assessments would only be used for accountability purposes when they meet the appropriate technical criteria, reflect state-approved standards, and apply equitably to all students, as is already the case in Connecticut, Nebraska, Oregon, Vermont, and other states successfully using multiple forms of assessment.

To counter the narrowing of the curriculum and exclusion of important subjects that has been extensively documented as a consequence of NCLB, the new law should also allow states to include other subjects, using multiple forms of assessment, in an index of school indicators. To ensure strong attention is given to reading and math, these subjects can be weighted more heavily. Graduation rates and grade promotion rates should be given substantial weight in any accountability system. Other relevant indicators of school progress, such as attendance and college admission rates, could be included.

Because evidence is clear that multiple assessments are beneficial to student learning and accountability decisions, we hope that the committee will take the step of providing significant funds to assist states and districts to implement systems that include multiple forms of evidence about student learning, including state and local performance assessments. Congress should also require an evaluation of state multiple measures programs to enable sharing of knowledge and improvement of state assessment and accountability systems. A multiple measures approach that incorporates a well-balanced set of indicators would support a shift toward holding states and localities accountable for making the systemic changes that improve student achievement. This is a necessary foundation for genuine accountability.



Advancement Project

Asian American Legal Defense and Education Fund

Asian Pacific American Labor Alliance


Civil Rights Project

Council for Exceptional Children

Japanese American Citizens League

Justice Matters

League of United Latin American Citizens (LULAC)

Learning Disabilities Association of America

National Alliance of Black School Educators (NABSE)

National Association for the Advancement of Colored People (NAACP)

NAACP Legal Defense & Educational Fund, Inc.

National Association for Bilingual Education (NABE)

National Association for the Education and Advancement of Cambodian, Laotian, and

Vietnamese Americans (NAFEA)

National Coalition of ESEA Title I Parents

National Council on Educating Black Children

National Federation of Filipino American Associations

National Indian Education Association

National Indian School Board Association

National Pacific Islander Educator Network (NPIEN)

National Urban Alliance for Effective Education (NUA)

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