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ELC Comment on Proposed Standards & Assessment Regulations

March 5, 2013

My name is Stan Karp and I appreciate this opportunity to comment on the Department’s proposed regulations on Standards and Assessment on behalf of the Education Law Center.  We have a number of concerns about how the statewide assessment system is “being revised due to the adoption of the Common Core State Standards and Partnership for Assessment of Readiness for College and Careers (PARCC) assessments.”

NJ’s Core content curriculum standards have been accepted by the state Supreme Court as the curricular definition of the “thorough and efficient” education guaranteed to each student by the NJ state constitution. The revision of these standards, therefore, holds significant implications beyond the classroom. The adoption of the “common core” standards in English language arts and math, and their integration with NJ’s existing core standards in seven other subject areas obligates the State to provide the programs and supports necessary to give all students an opportunity to achieve them.

Unfortunately the proposed regulations do not adequately address these issues. For example, the Administrative Code Adoption Process requires the Department to provide “an economic impact statement that describes the cost of implementing the regulation for all who may be affected. The statement should describe actual costs for complying with the regulation or the type of costs and the dollar range of costs.”

But the impact statement accompanying these regulations, which mandate that all districts must align their curricula and instruction with the common core and prepare students for the PARCC assessments, provides none of the required information. Instead, it asserts, “there is no reason to anticipate the curricular modifications will involve increased expenditures for school districts.”

This assertion is contradicted by the Commissioner’s own Educational Adequacy Report, issued last December. That report includes a brief, but detailed, discussion of projected costs of implementing the common core standards. While it acknowledges “assessing the fiscal impact of this move is rather difficult as the standards have not yet been fully put into place,” it cites two national studies, one by the Pioneer Institute that estimated NJ costs to implement common core at more than $500 million and another by the Fordham Foundation which estimated costs of about $200 million. The Commissioner’s report compares Fordham’s lower estimates with the resources provided by NJ’s school funding formula and concludes, “The resources provided in New Jersey’s adequacy model represent sufficient resources for school districts to make this transition.”

However, the Fordham estimates cited in the Commissioner’s report do not include the substantial technology costs required to administer PARCC’s computer-based tests. Moreover, since the Governor’s budgets have underfunded the school funding formula by $4.8 billon since FY2010, hundreds of districts remain below the adequacy levels used as yardstick in the Commissioner’s report. In short, the economic impact statement accompanying these regulations is grossly inaccurate and should be revised to reflect the real costs of these regulations.

We also have many concerns about the common core assessments mandated by these regulations. These assessments are still in development. We think it is inappropriate to mandate assessments before they have been created or field-tested. And we are particularly concerned about the implementation of the assessments at the high school level where they are likely to carry high stakes for graduation.

The Department has already publicly declared that the current high school graduation assessments, the HSPA and AHSA, will be phased out with the current sophomore class. Current freshman will be the first class to take the new PARCC assessments as juniors in spring of 2015. But the Department has not yet outlined the graduation policies that will govern use of these new assessments. The Governor’s College and Career Ready Task Force made a number of recommendations on this issue, including a proposal that the new assessments be phased in without high stakes for graduation for several years. But that recommendation is not reflected in these regulations. Instead the proposed regulations avoid the most immediately pressing issue raised by mandating the PARCC assessments: what they will mean for high school graduation, an issue that will have to be addressed well before the Feb. 2018 sunset date on these regulations.

The proposed regulations require that “District boards of education shall provide each student entering high school and his or her parents or legal guardians with a copy of the district board of education’s requirements for a State-endorsed diploma and the programs available to assist students in attaining a State-endorsed diploma.” In fact, however, districts cannot provide a complete version of those requirements because the state has announced plans to end the current graduation assessments without identifying their replacement.

Some Board members will recall the crisis precipitated several years ago when a badly mismanaged transition from the Special Review Assessment to the Alternative High School Assessment resulted in chaos for thousands of students and families. To avoid a repeat of such disruption, we urge the Board to defer final adoption of these regulations until the Department has conducted a broad public dialogue among all stakeholders and developed consensus around the transparent and equitable assessment policies all our students deserve.

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