The Iowa Board of Education has proposed an administrative rule that would require Iowa school districts to implement the Smarter Balanced Assessments. Our school board recently voted to submit a comment to the Department to oppose the rule. (Thank you, fellow board members!) Here is the letter I wrote to the board to explain why I thought we should submit that comment. The comment we submitted is here.
Dear Fellow Directors,
Thanks for your willingness to consider an item that I asked to put on the agenda about the state’s possible adoption of the Smarter Balanced Assessments.
The State Board of Education is currently considering adopting an administrative rule that would require Iowa school districts to use the Smarter Balanced Assessments instead of the Iowa Assessments that the state has required until now. As part of the rule-making process, the State Board has solicited public comment on the proposal; comments are due by November 3. I believe our board should submit a comment opposing the adoption of the Smarter Balanced tests.
In short, the Smarter Balanced tests will be much, much more expensive than the tests we have been using, both because of the cost of the tests themselves and because of the cost of the technology that will be necessary to administer them. It is not clear whether the state will allocate money to cover those costs. Even if it does, every dollar allocated to pay for the tests is likely to be one less dollar available for state supplemental aid. By requiring these tests, the state will, in effect, be deciding for us that we should redirect a large amount of our spending toward high-tech standardized tests, even if, in our judgment, the money would be better spent on preserving curricular programs, preventing class sizes from growing, or providing additional resources toward schools with particular needs (to name just a few possibilities). I’m afraid that the decision to adopt these tests will affect the state’s ability to provide supplemental aid for years, and could lead to additional rounds of budget cuts like those our district saw in 2014.
The purpose of this letter is to give you some background on the issue; I have attempted to provide links to sources or to more information wherever I could. I am separately attaching a first draft of a possible comment letter that we could submit; I mean it only as a starting point for our discussion if it is helpful.
Currently, Iowa requires schools to administer the Iowa Assessments every year. Because those tests are developed by the University of Iowa, we get them very inexpensively: as of last year, about $4.25 per student.
In 2013, however, the state created an assessment task force to ensure that our state’s assessments would be aligned with the Iowa Core. The task force was charged with choosing a set of Core-aligned assessments and implementing them as of 2016-17.
The task force narrowed its choices down to two possibilities: the Next Generation Iowa Assessments and the Smarter Balanced Assessments. (It eliminated other choices as insufficiently Core-aligned.) The Next Generation tests would cost $15 per student. The Smarter Balanced tests cost significantly more and would need to be supplemented with a separate science test, for a likely total cost between $30 and $40 per student. Those tests would also require an unknown amount of money—almost certainly very substantial—to buy and maintain the necessary technology, since the Smarter Balanced tests would be administered via computer.
The task force recommended the Smarter Balanced Assessments. Its reasoning for doing so appears primarily on pages 17-19 of its report. Although the legislature explicitly required the task force to “consider the costs . . . of providing and administering such an assessment and the technical support necessary to implement the assessment,” the task force did not attempt to estimate the tech costs that would be necessary to implement Smarter Balanced or to identify the sacrifices that would have to be made to pay for the tests. Instead, the task force simply concluded that “the costs of upgrading school technology infrastructures are not likely to be overly burdensome on the whole.” It based that conclusion in part on the assumption that “A 600-student middle school could test its students using only one 30-computer lab,” even though the middle-school assessments are over seven hours long per student.
One member of the task force dissented from the recommendation. The dissent focused on the failure of the task force to estimate the full cost of the Smarter Balanced tests—and particularly the tech costs, which the dissent argued were likely to be “significant and ongoing.” “The Smarter Balanced Assessments divert more time and money from instruction than necessary for accountability purposes,” the dissent concluded. The dissent appears on page 22 of the task force report.
The task force report also included a letter from our own David Dude, writing on behalf of the technology directors of the Urban Education Network of Iowa, raising concerns about the technology costs of any statewide assessment that would require computerized testing. The letter stated that “The UEN technology directors believe it is critical that the state quantify the costs associated with delivery of a technology-based assessment.” The letter described various elements of those costs as likely to be “significant” and “extensive,” as likely to “come at the cost of support to other systems,” and as including “costs at both the state and district level.” His letter appears at page 35 of the task force report.
The act creating the task force required the state Board to “submit to the general assembly recommendations the state board deems appropriate for modifications of assessments of student progress.” Iowa Code 256.7(21)(b)(4). The act also required the state to continue to use the Iowa Assessments (or a successor test produced by the same provider) in the meantime. As a result, after the task force announced its recommendation, the State Board and the state Department of Education lobbied the legislature to pass a bill designating Smarter Balanced as the required assessment. The legislature did not enact the bill, however.
Now the State Board has decided that it has the authority to require the new tests even without legislative approval, via the administrative rule-making process. It’s revealing that the State Board did not take that position until after it failed to persuade the legislature to adopt Smarter Balanced. Given that the act that created the task force explicitly required the State Board to submit recommendations to the legislature, the State Board’s decision to proceed without legislative approval is legally questionable.
Other states’ experiences with Smarter Balanced have not been encouraging. In California, school districts sued the state for reimbursement of the costs of implementing Smarter Balanced, seeking over $100 per student (above and beyond the approximately $250 per student that the state had already given the districts to implement the Common Core). (To the best of my knowledge, that suit is ongoing.) Several states have had serious tech difficulties when administering the tests. (You can read about some of them here and here.) Since 2012, the number of member states in the Smarter Balanced Consortium has declined from 27 to 19.
As you may already know, I’m a skeptic about the increasing reliance on standardized testing to drive educational practices. But you don’t have to be an opponent of standardized testing to be concerned about the very high cost of the Smarter Balanced tests, about the lack of information about just how high that cost might go, and about the lack of discussion about what will get sacrificed to pay for them. If the time does come when the cost of these tests forces additional cuts at the district level, or when our tech limitations cause us problems in running the tests, I want to be able to say that we at least tried to urge the State Board not to impose these tests.
Thanks for considering this issue. If you’re looking for further information about some these issues, Karen Woltman, the task force’s dissenting member, has written extensively about the Smarter Balanced Assessments on her blog, Education in Iowa.