The Iowa Board of Education has proposed an administrative rule that would require Iowa school districts to implement the Smarter Balanced Assessments. Earlier this month, the school board of the Iowa City Community School District voted to submit the following comment opposing the rule. A more extended argument for opposing the rule appears here. Comments on the rule are due by November 3; you can read about how to submit one here.
Mr. Phil Wise
Administrative Rules Co-Coordinator
Iowa Department of Education
Grimes State Office Building
Des Moines, IA 50319-0146
Re: Proposed amendments to Chapter 12, “General Accreditation Standards,” Iowa Administrative Code
Dear Mr. Wise:
As the Board of Directors of the Iowa City Community School District, we write to urge you not to approve statewide adoption of the Smarter Balanced Assessments, for these reasons:
First, we are concerned that the state has insufficient information about the full cost of adopting the Smarter Balanced Assessments. In particular, there is insufficient information about how much it will cost to establish and maintain the technological infrastructure that will be necessary to implement these tech-intensive tests. Without information about the full costs of the tests, there is no way to evaluate whether the benefits of the tests are worth the cost.
Second, the partial information that is available indicates that the cost of the Smarter Balanced Assessments will be high. The Smarter Balanced consortium estimates the per-test price of its assessments to be $23.50, and that does not include the cost of the science assessment that the law also requires. The total price is several times higher than the per-student price of the Iowa Assessments, which the state currently requires. The price is also significantly higher than that of the Next Generation Iowa Assessments, which the task force determined was also Iowa-Core-aligned, and which, like the current Iowa Assessments, are produced in Iowa by the Iowa Testing Programs.
Third, we are concerned that the costs of the Smarter Balanced Assessments will fall ultimately on the districts. Even if the state allocates money to pay for the tests, it seems likely that that allocation will result in less money available for state supplemental aid. We are concerned that those costs will force districts to make cuts in instructional programming and other educational needs, at a time when budget dollars are already stretched thin.
Fourth, we are concerned that Iowa districts may not be technologically ready to implement the Smarter Balanced Assessments by the 2016-17 school year as the governing statute would require. See Iowa Code 256.7(21)(b)(2).
Fifth, we are concerned that the State Board of Education does not have the legal authority to adopt the Smarter Balanced Assessments through the administrative rule-making process, given that the governing statute states that the “state board shall submit to the general assembly recommendations” about new assessments. Iowa Code 256.7(21)(b)(4).
Thank you for your consideration,
Board of Directors,
Iowa City Community School District
1725 North Dodge Street
Iowa City, IA 52245